NAPA Net - Polling Places 051719

Are Your Plan Sponsor Clients Self-Correcting?

The IRS recently made it easier (and less costly) to fix certain operational issues without the need for an IRS filing or payment of a user fee. If you missed it, the IRS made it a truly “good” Friday when, in a major victory for the advocacy efforts of the American Retirement Association, new rules under the IRS’ Employee Plans Compliance Resolution System (EPCRS) were announced that now allow the self-correction program (SCP) to permit correction of certain plan document failures and certain plan loan failures, including the ability to correct defaulted plan loans, the failure to obtain spousal consent on a plan loan, and the failure of permitting plan loans that exceed the number of plan loans permitted under the terms of the plan. The revenue procedure also provides an additional method of correcting operational failures by plan amendment under SCP.

All of which may have inspired the question from a reader.

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* 1. Do your plan sponsor clients use the DOL and IRS correction programs?

Yes, those that need to.

No, they have no need to.

Yes, but only because I encourage them to.

No, but they should.

I have no earthly idea.

Any comments?

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* 2. To what extent do they use the program(s)?

Some.

A lot.

Not much.

Almost never.

I've no earthly idea.

Something else? Comments on that interest?

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* 3. Have you talked to them about the newly expanded EPCRS program?

Not yet.

Yes.

No.

To some, yes.

What newly expanded EPCRS program?

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* 4. Would you/they like to see further expansions in the self-correction programs?

Not sure.

Yes.

I've no idea.

No.

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* 5. If so, what?

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* 6. Any other comments about the self-correction programs, the need for self-correction programs, the use of self-correction programs, the cost of self-correction programs, the lack of knowledge about self-correction programs, the lack of use of self-correction programs, or life in general?

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* 7. What is your role working with retirement plans?

Advisor

Provider

TPA

Plan sponsor

Recordkeeper

Other (please specify)

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* 8. What size plans do you PRIMARILY work with?

Under $10 million in assets

$10-$20 million

$20-$50 million

$50-100 million

$100 million - $250 million

$250 million - $500 million

Above $500 million

Other (please specify)

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* 9. Suggestions for future survey questions?

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* 10. All responses are anonymous and confidential, of course - but if you'd like me to know who you are, or allow for a response, you can leave your email below...