Excluded Eligible Employees from DB Plan

[mariemonroe]

Plan improperly excluded several employees from participating in a DB plan since the Plan's inception. EPCRS addresses how to handle this situation in a DC plan context, but not in a DB plan context? Has anyone ever dealt with this situation before in a DB plan? Any suggestions?

[Belgarath]

The Revenue Procedure 2006-27 does actually provide for a correction. See Appendix A, .05(1).

Now, if the correction is not "insignificant" and is "significant" but beyond the correction period, then you may have to do the Appendix A fix through a VCP submission, but that's not generally that big a deal where the correction is straightforward, such as a situation you are describing.

[mariemonroe]

Oops. Not sure how I missed that. Thanks!