Survey of Retirement Plan Practitioners; Improving the Employee Plans Compliance Resolution System (EPCRS)

December 14, 2007

Re: Survey of Retirement Plan Practitioners on Improving the EPCRS

Dear Retirement Plan Practitioner:

The IRS Advisory Committee on Tax Exempt and Government Entities is undertaking to formulate recommendations on improvement of the Employee Plans Compliance Resolution System. These recommendations will address, but not be limited to, the directive to the Secretary of the Treasury under the Pension Protection Act of 2006, Section 1101, requiring EPCRS be modified as follows:

  1. Increasing the awareness and knowledge of small employers concerning the availability and use of the program;
  2. Taking into account special concerns and circumstances that all employers face with respect to compliance and correction of compliance failures;
  3. Extending the duration of the self-correction period under the Self-Correction Program for significant compliance failures;
  4. Expanding the availability to correct insignificant compliance failures under the Self-Correction Program during audit; and
  5. Assuring that any tax, penalty, or sanction that is imposed by reason of a compliance failure is not excessive and bears a reasonable relationship to the nature, extent, and severity of the failure.

The ACT Committee is anxious to present the IRS with specific ideas, reasonable solutions, alternative fee schedules and other constructive suggestions.

We are confident the Tax-Exempt/Government Entities division of the IRS will carefully consider the ACT's report as they have in the past, and the ACT would like the survey results to be as inclusive of practitioners' views as possible.

Please enter as much information below as you wish.

If you'd prefer to send a Word document, please email it to marcia@wagnerlawgroup.com.

THANK YOU so much for participating in this very important process. Your contribution will make a difference!

Very Truly Yours,

Susan D. Diehl
sdiehl@penserv.com
215-444-9812

On behalf of the ACT members:

Dodi Walker Gross
Michael M. Spickard
Daniel J. Schwartz
Michael S. Sirkin
Marcia S. Wagner
Susan D. Diehl

(Note: we thank BenefitsLink.com for helping us publish the survey and collect the responses.)

Survey of Retirement Plan Practitioners; Improving the Employee Plans Compliance Resolution System (EPCRS)

1. Please provide specific ideas, reasonable solutions, alternative fee schedules and other constructive suggestions for improvements to the Employee Plans Compliance Resolution System. If possible, you might wish to address one or more of these specific issues:

  1. Increasing the awareness and knowledge of small employers concerning the availability and use of the program;
  2. Taking into account special concerns and circumstances that all employers face with respect to compliance and correction of compliance failures;
  3. Extending the duration of the self-correction period under the Self-Correction Program for significant compliance failures;
  4. Expanding the availability to correct insignificant compliance failures under the Self-Correction Program during audit; and
  5. Assuring that any tax, penalty, or sanction that is imposed by reason of a compliance failure is not excessive and bears a reasonable relationship to the nature, extent, and severity of the failure.

(OK to enter as much text as desired; the size of the box below does not limit the amount of text that can be typed or pasted in.)

2. If you would like to us to provide you with information about the committee's recommendations to the IRS, enter your name and email address.

Name:
Email address:



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