I don't think this could be corrected under VCP; as it really doesn't amount to an operational failure of the plan. Instead, it involves a failure of the payer to properly report the distributions.
Good Luck!
If for some unlikely reason the above doesn't work for you, you also have the option of amending your 2017 return to treat your IRA contributions as nondeductible (you'll have to forever track those contributions on Form 8606 an nontaxable basis). Unfortunately it's too late to recharacterize those contributions as Roth contributions.
Oh my God make this effective 12/31/18. Someone botched that one in my opinion, and you have 3 days to fix it, can I get a "Hallelujah!" A day makes all the difference in the world in one sense (by eliminating even a shadow of doubt), and no difference at all in another sense (because really what practical/logistical difference does it make?).
To resolve that issue, draft the split effective December 31, 2018 along with the transfer agreement. Effective at that time, those balances will become assets of the new plan (that are merely housed in plan 001 until transferred). You can actually, then, reflect that appropriate portion of the year end balances on the Form 5500 as a transfer out of plan 001 and a transfer in to plan 002.
Good Luck!
GBurns, I'm not sure what you are asking but we effectively treat insurance just like any other asset:
If BOY value = $1000
Premiums = $500
EOY value = $1400
then there was a $100 loss.
Yes we use CSV for mutual funds (not that we see B shares any more) and annuities.