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May 2, 2016

IRS Provides VCP Submission Kit for plan sponsors who failed to adopt a new Pre-Approved Defined Contribution Plan by the April 30, 2016 Deadline


The IRS has provided a voluntary correction program (VCP) Submission Kit for plan sponsors who failed to adopt a new Pre-Approved Defined Contribution Plan by the April 30, 2016 deadline.

The following is an excerpt from the IRS notification

“Sponsors of pre-approved defined contribution retirement plans were generally required to sign new plan documents, generally on or before April 30, 2016, that incorporated changes required by the Pension Protection Act (PPA). Defined contribution plans include profit-sharing plans, 401(k) plans, and money purchase pension plans. Pre-approved plans are plan documents that have been approved by the IRS and are sold to plan sponsors through law firms, banks, brokers, other financial institutions or plan administrators. The IRS issued favorable opinion letters approving these plans to the authors of these pre-approved plan documents in March of 2014 (or shortly after March 31, 2014).

Some plan sponsors have a later adoption deadline. If a plan sponsor wishes to convert an existing individually designed plan into a current defined contribution pre-approved plan they have until April 30, 2017 to adopt the pre-approved defined contribution plan.”

Details, including the required documentation and procedures, are available here

Written By

Denise Appleby

Denise is CEO of Appleby Retirement Consulting Inc., a firm that provides IRA resources for financial/ tax/legal professionals. She has over 20 years of experience in the retirement plans field, which includes training and technical consultation.

Denise writes and publishes educational /marketing tools for advisors; available at Denise co-authored several books on IRAs

Denise is a graduate of The John Marshall Law School, where she obtained a Masters of Jurisprudence in Employee Benefits, and has earned 5 professional retirement designations.
She has appeared on numerous media programs, sharing her insights on retirement tax laws.


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