VCP turnaround time

[Sully]

I'm getting ready to submit a VCP filing and was wondering about the expected turnaround time.

The filing deals with 9 employees being excluded from the 401(k) plan for part of the year.

Thanks in advance.

[Alf]

At least a year if no Determination Letter application (seriously) and longer if there is an application.

[401 Chaos]

I agree with Alf. The most recent one we closed was submitted in mid-May 2004 and was concluded in mid-June 2005.

That one did not include a determination letter request but did involve several defects over multiple years and was pretty complicated. Things moved fairly fast once it was assigned for review and the individual agent began working on it but it sat in a black hole for 11 months. I understand that the IRS is seriously backlogged with requests and limited in resources for the program.

It is also my understanding that the nature of the defect / correction does not significantly impact the overall time involved as they take the applications in pretty much the order they are received. For example, a discrete defect with a clear, by-the-book correction such as the exclusion of eligible employees will likely take just as long to conclude as a very complex application because the easy ones don't get flagged or screened out along the way. I would appreciate hearing if others have had a different experience.