Correction where latest Opinion Letter does not consider TRA '86???

[chris]

Rev. Proc. 2001-17 seems to require that a plan have, at the least, an opinion/notification/determination letter that considered TRA '86 in order to correct. What about situation where last letter did not consider TRA '86??? The opinion letter employer has with respect to prototype clearly says it is not considering TRA '86.

[chris]

After a little closer reading, it seems that the plan would be able to correct under the general procedures of VCP. As a result, a higher fee will apply.