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What is the correction for a missing document?

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Assume the only 403(b) failure an employer seeks IRS relief on is the employer's failure to adopt a written plan.

If an employer adopts a written plan and files a VCP submission and pays the $500 (for 20 or fewer participants), is there anything the IRS will require ?


Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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So long as the written document is effective January 1, 2009, and the VCP submission is filed with the proper fee, that seems to be the only correction required.  See:


Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

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