On September 28, the Internal Revenue Service (IRS) released
Rev. Proc. 2018-52, which provides an updated statement of the
correction programs under the Employee Plans Compliance Resolution
System (EPCRS). Generally, EPCRS allows sponsors of tax-qualified
retirement plans to correct failures that would otherwise cause a
plan to run afoul of the qualification requirements of Sections
401(a), 403(a), 403(b), 408(k), or 408(p) of the Internal Revenue
Code of 1986, as amended (Code).
According to Rev. Proc. 2018-52, the primary purpose of
publishing a revised EPCRS was to set forth new submission
procedures under the Voluntary Compliance Program (VCP).
Specifically, beginning April 1, 2019, plan sponsors must submit
VCP applications (and pay applicable user fees) electronically
through the www.pay.gov website. Submissions must be
converted into a single PDF document before being uploaded and may
not exceed a 15MB size limitation. A sponsor with a lengthy
VCP application
