The IRS Revenue Procedure 2016-51 modifies the procedures for correcting retirement plan errors under 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.