Missed Employer Contributions

[MBCarey]

We have a plan that missed making contributions for two employees when they were eligible last year because the participant did not return an enrollment form.

We have determined that the client will need to make up the contributions plus earnings. Are they also obligated to file under the Voluntary Correction Program or is that only for employee deferrals.

[Belgarath]

I wouldn't say that in general this would need to be corrected under VCP. Generally, this could be corrected using SCP as an insignificant failure, depending upon the good old facts and circumstances.