What is “Walk-In CAP”?

A submission for an Employee Plans Voluntary Closing Agreements, also known as a “Walk-In CAP” is a program offered by the IRS where retirement plan issues that cannot be resolved under the Employee Plans Compliance Resolution System (“EPCRS”) can be corrected with IRS approval. Similar to the Voluntary Correction Program (“VCP”) under EPCRS, the Walk-In CAP is voluntary, but is more informal than VCP. When a qualified plan has failures, the issues that arise may not all fit neatly under EPCRS. Below is a table summarizing some key features of a VCP versus a Walk-In CAP submission.