Lori H Posted November 19, 2010 Posted November 19, 2010 What is the procedure in VCP filing? For example, a plan was abandoned in calendar year 2005. A new plan(403b) was set up and the TPA failed to terminate the old plan. Distributions from the old plan occurred as well as rollovers into the new plan. A resolution to terminate was not prepared. No 5500's were prepared for the old plan as well as amendments or restating the plan to comply with EGTRRA. When submitting the filing, should the sponsor go ahead and amend, restate and then submit those to the IRS or just outline it's intentions in the filing and wait for approval from IRS. The sponsor has already filed prior 5500's under DFVC. They are aware that their new plan has "tainted" rollover funds. This is a small plan. About 10 participants.
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