Voluntary Compliance Program (VCP) Fees

The following general fees apply to single submissions involving qualified retirement plans established under IRC 401(a) or IRC 403(b). For VCP submissions made on or after January 1, 2017, refer to Rev. Proc. 2017–4, Appendix A.08 to determine specific fee amounts and for additional information on special definitions and conditions. You can also find the current fees on the IRS website at https://www.irs.gov/retirement-plans/voluntary-correction-program-fees.


Higher fees may apply where the submission involves egregious failures. Reduced fees may apply in certain circumstances:

  • Failures only involving late adoption of interim amendments

  • Other nonamender failures submitted within 1 year of expiration of the extended remedial amendment period

  • Late adoption of amendments required to obtain determination letter

  • Certain loan failures

  • Operational failures involving required minimum distributions

  • Submissions for SEPs, SARSEPs and SIMPLE IRAs

  • Orphan plans

  • Minor modification of a previously issues compliance statement


© Boutwell Fay LLP 2017, All Rights Reserved. This handout is for information purposes only, and may constitute attorney advertising. It should not be construed as legal advice and does not create an attorney-client relationship. If you have questions or would like our advice with respect to any of this information, please contact us. The information contained in this article is effective as of July 28, 2017.



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