Revised DOL VFCP program to be announced soon

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.

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