In 2012, an employer permitted an employee to roll assets over from her previous employer's plan. Somebody just realized that the plan document does not permit rollovers. My initial thought was that this can be self corrected under EPCRS by amending the plan. But after reading Rev. Proc. 2013-12, Section 4.05(2), rollovers are not mentioned in Section 2.07 of Appendix B which means that the employer must go through the VCP correction program. Does anyone else think that this is a bit extreme for this type of error?