IRS Updates Several Model VCP Compliance Forms

In a recent issue of the Employee Plans News, the IRS has announced the update of several forms used to submit Voluntary Correction Program applications to the IRS. According to the news release, the following changes were made.

• Form 14568, Model VCP Compliance Statement, has updated enforcement section language
• Form 14568-A, Model VCP Compliance Statement – Schedule 1: Plan Document Failures for 403(b) Plans has been redesigned to only apply to 403(b) late amender failures and descriptions of common plan document failures have been standardized
• Form 14568-B, Model VCP Compliance Statement – Schedule 2: Nonamender Failures for IRC 401(a) Plans has been redesigned to only apply to 401(a) late amender failures, with breakouts pre-approved plans, individually designed plans, and interim amendment failures as applicable
• Form 14568-C, Model VCP Compliance Statement – Schedule 3: SEPs and SARSEPs, and Form 14568-D, Model VCP Compliance Statement – Schedule 4: SIMPLE IRAs have been updated with a direct link to the Department of Labor’s (DOL) Voluntary Fiduciary Correction Program (VFCP) calculator, and a standardized narrative for small excess amounts of $250 or less