Updated IRS Procedures for Correcting Plan Errors

The IRS Revenue Procedure 2016-51 modifies the Employee Plans Compliance Resolution System (EPCRS). This revenue procedure is effective January 1, 2017, and supersedes the prior revenue procedures applicable to EPCRS.

Some Key Changes Include

  • The requirement for a plan sponsor to submit a determination letter application to the IRS when correcting qualification failures that include a plan amendment no longer applies.
  • Fees associated with the Voluntary Correction Program (VCP) are now user fees and no longer set forth in the EPCRS revenue procedure.
  • Availability of Self-Correction Program (SCP) for significant failures has been modified to provide that, for qualified individually designed plans, a determination letter need not be current to satisfy the Favorable Letter requirement.

A full listing of the changes applicable in Revenue Procedure 2016-51 is included in the IRS’ article Updated Retirement Plan Correction Procedures.

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