News & Analysis as of

Retirement Plan › Voluntary Correction Program › Employee Retirement Income Security Act (ERISA)

Snell & Wilmer

Five Things to Know about the DOL’s New VFCP Self-Correction Feature Taking Effect Next Week

Snell & Wilmer on

By Amberlee Lapointe On January 14, 2025, the DOL’s Employee Benefits Security Administration (“EBSA”) released updates to its Voluntary Fiduciary Correction Program (“VFCP”), along with a News Release and Fact Sheet...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

Morrison & Foerster LLP

Sorry I’m Late: New Guidance on Late Contributions

Morrison & Foerster LLP on

Twenty (20!) years after it last issued guidance, the DOL’s Employee Benefits Security Administration has finally released an updated Voluntary Fiduciary Correction Program (VFCP). VFCP is a program that permits retirement...more

Bricker Graydon LLP

Too Little, Too Late? Plan Contribution Timing Requirements and How to Correct Delays

Bricker Graydon LLP on

One of the most basic duties of a defined contribution plan sponsor is to ensure that that there is no delay and participants’ salary deferral elections are correctly and timely deposited into the retirement plan. Not only is...more

Groom Law Group, Chartered

DOL Reopens Comment Period for Voluntary Fiduciary Correction Program Changes

Groom Law Group, Chartered on

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

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

DOL to amend the DFVCP Program

Ary Rosenbaum - The Rosenbaum Law Firm P.C. on

Employee Benefit Security Administration plans to amend and restate its Voluntary Fiduciary Correction Program (VFCP)...more

Holland & Hart - The Benefits Dial

Every bond you break, every step you take, I’ll be watching you . . . Plan operational failures can also result in a fiduciary...

Holland & Hart - The Benefits Dial on

Plan sponsors are typically aware that operational errors threaten a retirement plan’s qualified status under the Internal Revenue Code if they remain uncorrected. What may come as a surprise, however, is that operational...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Just correct those errors

Ary Rosenbaum - The Rosenbaum Law Firm P.C. on

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

Sheppard Mullin Richter & Hampton LLP

For Tax-Exempt Employers: 403(b) Retirement Plan Compliance Opportunity

Sheppard Mullin Richter & Hampton LLP on

Tax-exempt employers have a special opportunity to fix compliance concerns with their 403(b) retirement plans. They have through March 31, 2020 – the “Remedial Amendment Period” (RAP) – to retroactively self-correct...more

Fisher Phillips

Is There An Elephant In The Room?

Fisher Phillips on

401(k) Plan documents can read like Russian novels. They are often long and difficult to understand, so it’s no surprise that administrative errors in operating such plans happen frequently. Common errors include omitting or...more

Morgan Lewis

IRS Updates and Expands Qualification Correction Program

Morgan Lewis on

New provisions for correcting operational and plan document errors take effect on April 1. On December 31, 2012, the Internal Revenue Service (IRS) updated its Employee Plans Compliance Resolution System (EPCRS) through...more

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