The Department of Labor (DOL) should be finalizing its proposed update to the Voluntary Fiduciary Correction Program in “the next few months,” according to a representative of the Employee Benefit Security Administration (EBSA).
The DOL previously proposed last fall, to permit certain errors to be self-corrected. It would allow a plan sponsor to fix the error and inform EBSA after the fact, instead of seeking pre-approval. Eligible errors would include salary deferrals that are invested or loan repayments that are deposited in an untimely manner, provided the cost of error does not exceed $1,000 and is not more than 180 days old. This is believed by EBSA to represent the majority of the fiduciary errors made in plan administration.
While self-correction may cut down on my billing for these applications, I think self-correction will help plan sponsors out in fixing errors.
