How To Fix A Broken Plan
ASPPA Benefits Council New England
Compliance issues impact even the best-administered plans. The Employee Plans Compliance Resolution System (EPCRS) is a road map of how to respond when good plans go bad. With Revenue Procedure 2008-50, the IRS published its first complete update to EPCRS in two years. This new incarnation provides some useful additions for correcting common 401(k) failures, but there are also a number of issues yet to be addressed. It is no surprise to practitioners that egregious failures carry higher penalties, but EPCRS now defines "egregious" in a manner that could subject seemingly minor failures to much higher sanctions.
At this program, David A. Guadagnoli presented "How To Fix A Broken Plan" at an ASPPA Benefits Council New England seminar on May 14, 2009. He walked attendees through some of the more significant changes to EPCRS and provided case studies to illustrate how to apply the correction principles to actual client situations. David also discussed the resources available on the IRS's EPCRS Web page, including the 401(k) Fix-It Guide and the Top Ten Issues for 401(k) plans.