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Coordination of 2 VCPs for plan document failure going at once


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Guest B2Randolph
Posted

Does anyone know how to coordinate to VCP filings? I am preparing one for failure to sign plan documents timely (including the initial plan doc) and there has already been one filed (with a determ letter request) for a Late Amended GUST document.

I'm pretty sure I should coordinate these, but I don't know how.

Any help anyone?

Posted

Revenue Procedure 2003-44, Section 10.08(4) indicates that "[a] Plan Sponsor

that discovers additional unrelated Qualification or 403(b) Failures after its initial submission may request that such failures be added to its submission. However, the Service retains the discretion to reject the inclusion of such failures if the request is not timely, for example, if the Plan Sponsor makes its request when processing of the submission is substantially complete."

To "coordinate" the filings I would contact the representative listed in the VCP acknowledment letter for the original submission and provide the appropriate control number.

...but then again, What Do I Know?

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