IRS Lists Top Mistakes in Voluntary Correction Program Submissions

The IRS has issued a summary of the top mistakes made by plan administrators utilizing the Voluntary Correction Program (VCP). As a reminder, the VCP is a way for retirement plans to receive IRS approval on corrections to plan documents or operational failures that would otherwise jeopardize the plan's tax-favored or qualified status. Thus, it is important the submission is free of errors to avoid denial of the submission or a delayed approval.

The top errors include:

• Failure to combine PDF documents into a single PDF file that does not exceed 15MB
• Failure to pay the correct VCP user fee, which is based on plan assets or listing an incorrect bank account/routing number
• Incorrect completion of Pay.gov Form 8950
  • The name of the plan sponsor doesn't match the name on the other documents in the submission
  • Incorrect EIN provided
  • An officer of the plan sponsor didn't sign the form
• Insufficient narrative provided
  • The descriptions of the failure(s) or corrective changes are not detailed enough
  • The submission does not identify a plan qualification failure under IRC Section 401(a)
• Failure to include a copy of the plan document

Please see the guidance for a complete discussion and for helpful resources including instructional videos and helpline numbers.

Top Mistakes in VCP Submissions »