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Has anyone done an Anonymous VCP submission through pay.gov yet? I'm wondering how to handle the payment. They only take ACH and credit cards. Doesn't seem very anonymous.

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I have not - but wouldn't the third party handle the payment? Same as when it was paper? When checks were sent the sponsor couldn't send a check in with their information, so a third party (an attorney maybe) would have to facilitate payment to maintain anonymity. I suppose a cashier's check could have been used and it wouldn't have identifying information. 

So if the attorney has an escrow or trust account, that's what I would expect the payment to come from, not the plan sponsor's account or CC. 

What about a pre-paid visa card or something similar? they could load it with the amount of the fee for a one-time use?

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2 hours ago, Griswold said:

Has anyone done an Anonymous VCP submission through pay.gov yet? I'm wondering how to handle the payment. They only take ACH and credit cards. Doesn't seem very anonymous.

We have an account into which we deposit all the 20% withholding for cash distributions; then we transmit the funds from our omnibus account.  If we were to do an Anonymous VCP, the client would write us a check, we would deposit it in our omnibus account, and then we would make the payment (either by our credit card or ACH).  It is the client that is anonymous, not us.

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I haven't done one since the online filing requirement - but in the past, when we've done them, we've used outside counsel - and they wrote the check.  I would assume that if we do another, we'd provide them with the funds and they would use their "corporate credit card" to facilitate the filing.

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