Updated VCP model compliance statements; check the status of your VCP submission

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Check the Status of your VCP Submission

You can find out if your Voluntary Correction Program submission has been assigned to a specialist at IRS.gov/VCPstatus. Just compare the date of your confirmation email to the date of the most recent VCP submissions that have been assigned to a specialist.

Revised VCP Model Compliance Statement and Schedules

The IRS updated several fill-in VCP forms to revise outdated information, provide clarity, and make it easier to present some late amender failures that impact 401(a) and 403(b) retirement plans.

Plan sponsors can use the model compliance statement and schedules to make an IRS Voluntary Correction Program (VCP) submission. The model schedules (Forms 14568- A to 14568-I) contain standardized methods plan sponsors can use to correct common mistakes using VCP. 

We’ve made changes to the following fill-in forms:

Form 14568, Model VCP Compliance Statement

• Updated enforcement section language

Form 14568-A, Model VCP Compliance Statement - Schedule 1: Plan Document Failures for 403(b) Plans

• Redesigned form applies only to 403(b) late amender failures
• Provides a framework to present late amender failures that involve IRC 403 plans
• Standardized descriptions for some very common 403(b) plan document failures

Form 14568-B, Model VCP Compliance Statement - Schedule 2: Nonamender Failures for 401(a) Plans

• Redesigned form applies only to 401(a) late amender failures
• Failures grouped by pre-approved plans vs individually designed plans
• Failure descriptions for pre-approved plans include the latest failures
• Provides a framework to present failures involving individually designed plans not timely to comply with the Required Amendments List, or the Cumulative List (prior to 2017)
• Legit late interim amendment failures affecting a pre-approved plan would be presented as an “Other” failure in Section I C

Form 14568-C, Model VCP Compliance Statement - Schedule 3: SEPs and SARSEPs

• Updated direct link to the DOL VFCP calculator
• Standardized narrative involving small excess amounts increased to $250

Form 14568-D, Model VCP Compliance Statement - Schedule 4: SIMPLE IRAs

• Updated direct link to the DOL’s VFCP calculator
• Standardized narrative involving small excess amounts increased to $250

No changes have been made to the other forms in the Form 14568 series (Form 14568-E through Form 14568-I).

Interim Guidance on EPCRS: Notice 2023-43

The IRS released guidance in the form of Q&A’s on changes made by the SECURE 2.0 Act to the Employee Plans Compliance Resolution System of voluntary correction programs for retirement plans. Notice 2023-43 provides interim guidance for taxpayers in advance of an update to EPCRS as outlined in Revenue Procedure 2021-30.

For more information on the correction programs available to correct mistakes in your retirement plan, go to IRS.gov/FixMyPlan.