The various rules and regulations associated with maintaining a 401(k), 403(b) or other retirement plan can often be overwhelming and challenging to follow. That’s why the IRS allows plan sponsors to disclose and resolve various plan errors using the Employee Plan Compliance Resolution System (EPCRS). The system which includes three types of correction programs and is designed to allow plan sponsors to correct errors before plan disqualification occurs. For minor issues, plan sponsors are allowed to correct basic mistakes using the self-correction program (SCP). While helpful for many Atlanta plan sponsors, in early April the IRS (EPCRS Revenue Procedure 2019-19) made additional changes that expand the scope of errors which can be resolved using the program. It’s now easier to fix certain plan document issues and operational failures, including plan loan issues, without having to make disclosures. To help clients, prospects and others become familiar with the changes, Wilson Lewis has provided a summary below.
Effective Date
The changes outlined in EPCRS Revenue Procedure 2019-19 are effective as of April 19, 2019.
Summary of Key Changes
Electronic Submission Requirement
It’s important to note that any submissions to the Voluntary Correction Program are now required to be completed electronically using the pay.gov website. While there was a period where both paper or electronic filings were accepted, the deadline for transition passed on March 31, 2019. This means that plan sponsors that have an error requiring a VCP submission will be required to disclose the error, corrective actions and pay the related fee online.
Contact Us
The recent changes to EPCRS offer more flexibility to Atlanta plan sponsors in resolving their plan document, loan and other failures. While these changes make it easier to resolve errors, it’s essential to maintain a robust compliance program to ensure your plan is operating according to stated regulations and plan documents throughout the year. If you have questions about the recent changes or need assistance with your 401k, 403(b) or other retirement plan audit, Wilson Lewis can help. For additional information call us at 770-476-1004 or click here to contact us. We look forward to speaking with you soon.
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