DCPensionGal

Top hat plan never filed statement with DOL so we are taking it through DFVCP. Do we simply file the top hat statement and pay the $750, or must we also complete and file the several page application (which application does NOT indicate this as one of the items for which this is to be filed, see below): Transactions Corrected Check which transactions listed in the VFCP you have corrected: Delinquent Participant Contributions and Participant Loan Repayments to Pension Plans Delinquent Participant Contributions to Insured Welfare Plans Delinquent Participant Contributions to Welfare Plan Trusts Loan at Fair Market Interest Rate to a Party in Interest Loan at Below-Market Interest Rate to a Party in Interest Loan at Below-Market Interest Rate to a Non-Party in Interest Loan at Below-Market Interest Rate Due to Delay in Perfecting Plan’s Security Interest Loans Failing to Comply with Plan Provisions for Amount, Duration or Level Amortization Default Loans Purchase of an Asset by a Plan from a Party in Interest Sale of an Asset by a Plan to a Party in Interest Sale and Leaseback of Real Property to Employer Purchase of Asset by a Plan from a Non-Party in Interest at More Than Fair Market Value Sale of an Asset by a Plan to a Non-Party in Interest at Less Than Fair Market Value Holding of an Illiquid Asset Previously Purchased by a Plan Payment of Benefits Without Properly Valuing Plan Assets on Which Payment is Based Duplicative, Excessive, or Unnecessary Compensation Paid by a Plan Expenses Improperly Paid by a Plan Payment of Dual Compensation to a Plan Fiduciary Correction Amount

I've heard that some high level players are saying that IRS is no longer accepting applications for Vol Sub Minor Modifier determination letters in the client's name for Cycle 3 Restatements but haven't seen anything in writing. I'm sure these folks' comments were misunderstood - right?

Yes, they came out just now

sorry I hit send too quickly, it appears they are requiring the checklist this year.

it didnt used to be a requirement but Ive had reviewers require it