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Limit correction period to 3 years for late deferrals?

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The not-for-profit agency is willing to pay interest on late deposits, but I can't believe that they would be expected to go back more than 3 years to correct the problem. I suppose we could include only 2009 and 2010 in our VFCP filing and see if the DOL asks for more. The actual time period could go back to the beginning of the plan (20 years or so). I'm sure this has come up a zillion times. I would be interested to hear how others have handled this.

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