Sooner or later, every plan has some kind of operational error or misstep – but there’s some gray in the new guidance from the IRS.
Ever since Rev. Proc. 2019-19 made its appearance, there are some new options – notably the increased availability of the self-correction program (SCP) for loans and document corrections, including:
- New rules for correcting by plan amendment under the SCP.
- The ability to correct certain plan loan failures, including errors relating to the failure to repay a plan loan according to plan terms.
- Reporting of deemed distributions.
- Failure to obtain spousal consent for a plan loan.
It all looks clear enough – but the guidance from the IRS (related to the new Revenue Procedure) is arguably so minimal that it can become a judgement call for the plan sponsor - and for the guidance they are looking to you to provide as to what is suitable for SCP versus VCP.
So – what can you consider – and what should you consider? Have you taken advantage of the new options – and what issues has it raised? How is that different from the way things used to be (way back in March 2019?)?
Ah, it’s the Ethics of EPCRS – join Jennifer Swets and Heather Abrigo for a two-part “EPCRS and Ethics” session at ASPPA Annual – we’ll get into the nitty gritty of your real-life experiences – and explore creative – but ethical – alternatives that can make a real difference for your clients – and your practice.
…and it’s just one of the practice building sessions that make up ASPPA Annual – the nation’s most-valued practice-building event for retirement plan professionals (like you).
Find out more at www.asppaannual.org.
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