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shERPA

VCP Processing grinding to a halt?

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We submitted one last August.  As of today it is still not even assigned.   Anyone else seeing this?

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11 hours ago, shERPA said:

We submitted one last August.  As of today it is still not even assigned.   Anyone else seeing this?

Yep.  We had one that took 19 months with no response, and our normal policy is to "not poke the bear."  We poked the bear, and the initial response was negative.  Took a lot of work to get to the "right" conclusion.

We are currently telling clients that a VCP is a 1 to 2 year process - or more....

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1 hour ago, MoJo said:

Yep.  We had one that took 19 months with no response, and our normal policy is to "not poke the bear."  We poked the bear, and the initial response was negative.  Took a lot of work to get to the "right" conclusion.

We are currently telling clients that a VCP is a 1 to 2 year process - or more....

Do you see any correlation between the complexity of the submission and the response time? 

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5 minutes ago, RatherBeGolfing said:

Do you see any correlation between the complexity of the submission and the response time? 

None.  The one I referenced was a complicated situation (and involved several thousand employees), but we've seen extended periods of time for even simple "loan" corrections.  The interesting thing is, we've seen some resolved within 6 months of filing, and some going on almost 2 years - with not rhyme or reason as to which are taking longer times.  We currently are working on 23 VCP filings - so we've got a pretty good sample....

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Our August submission is an extremely simple document issue, but not eligible for self-correction.  Not even any HCEs in the plan. But how would IRS even know this when it hasn’t been assigned after 8  months? 

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I submitted one in mid-November 2018, and got back a compliance letter dated 1/31/19.

I have two others that were submitted in January and early February 2019 and have not even received back the acknowledgement Letter 5265. 

All three were simple issues. I guess if we get follow up questions on the later two there's some correlation, but it still strikes me as taking a long time to get an acknowledgement/assignment. 

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29 minutes ago, shERPA said:

Our August submission is an extremely simple document issue, but not eligible for self-correction.  Not even any HCEs in the plan. But how would IRS even know this when it hasn’t been assigned after 8  months? 

Wishful thinking, but pre-sorting cases before assigning them could lead to complex matters ending up in pile A (requires more experienced personnel to review and takes more time) and simple matters in pile B (less time)

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4 hours ago, RatherBeGolfing said:

Wishful thinking, but pre-sorting cases before assigning them could lead to complex matters ending up in pile A (requires more experienced personnel to review and takes more time) and simple matters in pile B (less time)

and that is a bad outcome? oh wait, that would lead to government efficiency, never mind.

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of course it would - it makes perfect sense, would improve the flow of simple vcp applications and also ensure that complicated matters get to the right people from the start - which is why it will probably never happen!

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I think it just depends on the type of filings and the regional office that processes them.  We've had a few model loan filings that was closed within 6 months.  

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End of June, no change.  One submitted in August 2018 - still not assigned.  One submitted in December 2018, still not assigned.  One is a relatively simple document issue, another a missed RMD, pretty straightforward.  IRS says call back in 8 weeks.  

VCP is pretty much worthless if turnaround is measured in years. 

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Filed one on May 8 and rec'd compliance statement June 16, amazingly fast but it was a SIMPLE IRA issue so maybe the folks handling SIMPLEs aren't real busy.

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