Summary of plan correction programs

 

Common plan errors and the appropriate IRS or DOL program to use to fix them.

Failure to timely amend plan to keep it updated with changes in the law

Plan error Apply to
Form 5500 late or missed filing DFVCP
Late or missed deposits of employee salary reduction contributions VFCP
Participant loan failures (for example, loans that exceed the maximum permitted dollar amount) EPCRS

VFCP (for certain failures - after using the EPCRS)

Failure to timely amend plan to keep it updated with changes in the law EPCRS
Plan operational errors arising from the failure to follow plan terms (for example, an employee who meets the plan’s eligibility requirements but is not allowed to participate) EPCRS
Specified plan prohibited transactions (for example, sales or loans between the plan and a party in interest) VFCP