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Difficulty in Implementing Correction after Compliance Statement Issued


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Guest rocnrols2
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Company X files for VCP listing, among other issues, the failure to impose plan-imposed and regulatory suspensions following in-service withdrawals. The proposed correction, refunding deferrals and forfeiting match, is accepted by the IRS and a compliance statemetn is issued. During the period given to implement the correction, it is discovered that due to depletion of account balances by loans and subsequent in-service withdrawals, the correction cannot be implemented for many, if not most, of the partcipants. I know it is possible to modify a correction statement if you go back to the IRS within 30 days and pay a $3,000 compliance fee. Is there any other alternative short of a new VCP filing?

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