IRS Reminder That Group VCP Option Is Available for PPA Non-Amenders

The IRS has released a reminder notice that a group submission option is available to correct retirement plan failures to amend timely for provisions of the Pension Protection Act (PPA).

The deadline for signing a restated plan document for PPA provisions was April 30, 2016. Plans may submit individually to correct this missed deadline failure under the IRS’s Voluntary Correction Program (VCP), which is an option within the broader Employee Plans Compliance Resolution System (EPCRS).

The group submission option allows financial organizations and service providers to essentially bundle multiple retirement plans that have this same amending failure, thereby reducing paperwork and cost. Several conditions apply to group submissions, the most basic being that 20 or more plans are required. The submission fee is $10,000 for 20 plans and $250 for each additional plan, up to a maximum of $50,000.