VCP for Two Plans

[Randy Watson]

I'm doing a VCP submission for two plans sponsored by the same employer. Can I prepare one checklist and one Appendix D or do I have to prepare separate submissions?

[Guest Sieve]

Even though VCP is a for plan sponsors to make corrections, VCP iteslf is a per-plan process and not a per-employer process (among other things, note that Appendix D asks for the name of a single plan). So, the process does not anticipate multiple plans being part of a single submission (even if there is only one plan sponsor), unless it is a group submission made by a prototype or VS sponsor. So, each per-plan (i.e., separate) VCP submission has its own VCP fee.

I would not complicate the filing by submitting separate VCP applications in one filing or with one cover letter--you'd be begging for one of the applications to be misplaced or otherwise delayed. I'd file each with its own cover letter.

[Peanut Butter Man]

In this situation, I prepare two completely separate application packages in separate envelopes and then mail them together in one larger envelope. I also add a paragraph in each cover letter stating that I've submitted another plan of the same employer for correction at the same time. This permits the IRS to pair the submissions together and send them to the same agent or the same group to be worked on.

[Guest Sieve]

PB Man -- You're luckier than me with your "two-fer" experiences. Whenever I've done that with fdl applications, the plans have been sent to different districts!