On December 31, 2012, the IRS released its long anticipated new procedures under its Employee Plans Compliance Resolution System (“EPCRS”). See Revenue Procedure 2013-12 which is available at http://www.irs.gov/Retirement-Plans/New-Revenue-Procedure-Updates-EPCRS. Among other changes, the new revenue procedure opens the door to correcting 403(b) plan document failures (including both failure to adopt a required amendment in a timely manner and failures to follow a written plan document) and provides a 50% discount on the normal VCP fee if (a) the only failure is a late adoption of a written 403(b) document and (b) the submission is filed before 12/31/2013.
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