News & Analysis as of

Employee Plans Compliance Resolution System Employee Benefits Fiduciary Duty

Holland & Knight LLP

2025 Revisions to the VFCP: Key Changes to Correction and Compliance Options

Holland & Knight LLP on

Historically, the IRS' Employee Plans Compliance Resolution System (EPCRS) has provided employers structured options for correcting retirement plan failures. Under this framework, certain operational errors qualified for...more

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Bass, Berry & Sims PLC

Updated Voluntary Fiduciary Correction Program for ERISA Plans Includes Self-Correction Features

Bass, Berry & Sims PLC on

As announced in our previous HR Law Talk blog post, on January 15, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published a much anticipated amended and restated version of the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOL Releases Final Rule for Self-Correction Under the Voluntary Fiduciary Compliance Program

On January 14, 2025, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released its long-awaited final rules regarding changes to the Voluntary Fiduciary Compliance Program (VFCP). The new...more

Groom Law Group, Chartered

DOL Reopens Comment Period for Voluntary Fiduciary Correction Program Changes

The Department of Labor (“DOL”) recently announced (88 Fed. Reg. 9408, Feb. 14, 2023) that it will reopen the public comment period on proposed amendments to DOL’s Voluntary Fiduciary Correction Program (“VFCP”) and its...more

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