News & Analysis as of

Benefit Plan Sponsors Self-Correction Programs Employee Retirement Income Security Act (ERISA)

Jackson Lewis P.C.

Exciting Update: Self-Correction for Delinquent Contributions Now Possible Under the DOL’s VFCP

Jackson Lewis P.C. on

On January 14, 2025, the Employee Benefits Security Administration (EBSA) within the Department of Labor (DOL) updated its Voluntary Fiduciary Compliance Program (VFCP). The VFCP allows plan officials to correct certain...more

Seyfarth Shaw LLP

The DOL May Not Actually Want to Hear From You: New Guidance Streamlining the Voluntary Fiduciary Correction Program

Seyfarth Shaw LLP on

The DOL updated its voluntary fiduciary correction program (“VFCP”) which was introduced over 20 years ago to allow plan sponsors to corrected enumerated fiduciary breaches. The amended VFCP now allows for self-correction of...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - January 2025

The January Monthly Minute highlights a recent Texas court decision holding ESG investing violated ERISA and a new development in the J&J prescription drug case that found plaintiff lacked standing to sue, and also digs into...more

Miller Canfield

IRS Weighs in on Inadvertent Benefit Overpayments

Miller Canfield on

Earlier this week, the IRS released Notice 2024-77, which provides much-anticipated guidance related to the handling of so-called “inadvertent benefit overpayments” from qualified retirement plans under the SECURE 2.0 Act. ...more

Holland & Hart - The Benefits Dial

Simply Irresistible…To Not Seek Recoupment of Overpayments

by Lyn Domenick Many retirement plan errors are inadvertent and involve small dollar amounts. However, the work involved in correcting such errors can be time consuming and burdensome. Fortunately, SECURE 2.0 provides that...more

McDermott Will & Emery

DOL Proposes Significant Changes to VFCP Program

McDermott Will & Emery on

On November 21, 2022, the US Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released a proposed amendment and restatement of the Voluntary Fiduciary Correction Program (VFCP), along with a...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Just correct those errors

We all know that when we make a mistake, it’s best that we correct them. Yet too many plan sponsors take a gamble by not self-correcting errors made in their plan...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Don’t ask for trouble with plan provisions

One of my biggest tasks as an ERISA attorney is helping plan sponsors out with voluntary compliance and self-correction programs. Many of these problems that have to be fixed are as a result of the plan document saying one...more

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