Voluntary Correction of Retirement Plan Defects

March 19, 2013

On March 19, 2013, Morgan Lewis presented the first installment of the 2013 Plan Sponsor Basics webinar series, which focuses on the day-to-day issues that many plan sponsors face in the design and operation of their retirement plans.

This webinar discussed how to voluntarily correct defects that may arise with a plan's written terms or its operation, with a particular emphasis on the updated version of the Employee Plans Compliance Resolution System (EPCRS) voluntary correction program guidance that was recently issued by the Internal Revenue Service.

Topics included:

  • A general overview of EPCRS and the structure of "component" programs (self-correction, voluntary compliance, and audit-cap programs)
  • Key updates and refinements established as part of the updated version of EPCRS
  • A walk-through of several common plan defects and corrections, including eligibility failures, automatic enrollment defects, and the failure to timely commence distributions at an employee's required beginning date
R. Randall Tracht | Partner, Pittsburgh
Carly E. Grey | Associate, Washington, D.C.
Julia L. Bringhurst, CEBS | Senior Benefits Advisor, Philadelphia