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How long to process a VFCP submission?


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Posted

We are about to file a VFCP submission for late deposit of elective deferrals. Does anyone have a sense for how long it will take the DOL to get to, and process, the submission under the revised VFCP? Thanks.

Posted
We are about to file a VFCP submission for late deposit of elective deferrals. Does anyone have a sense for how long it will take the DOL to get to, and process, the submission under the revised VFCP? Thanks.

We submitted a VFCP package to the DOL October 20, 2005 and received a No Action letter dated December 23, 2005. We're talking 1 and 1/2 years of deferral delinquency - no small matter - so I was impressed. We're also talking a tremendously organized binder of clearly outlined data so that the DOL could follow everything clearly. I imagine the presentation of data can impact the time involved.

Posted

If you submit *all* requested information/documents (including proof of all relevant payments), your calculation of lost earnings is correct, and there are no quibbles about the earliest reasonable segregation date, then it is possible for you to receive a No Action letter as early as the week it is received by the DOL. Of course, if you apply for the excise tax exemption option with the notice to interested parties, then there is a 30 day comment period that you would need to wait out.

However, I think I've only seen one application that contained all the required documents. The delays usually come from requesting missing information and waiting for it to be received.

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