Gudgergirl Posted January 28, 2011 Posted January 28, 2011 So I just concluded a VCP in which the Plan Sponsor failed to include several employees in its DB Plan. We received a compliance statement and the Plan Sponsor has made a contribution on behalf of the omitted participants. One of the omitted participants is 77. Had the contribution made on time, the participant would have been receiving RMDs for a couple of years now. I have never run across this issue before. Has anyone else ever dealt with it? I know EPCRS offers a mechanism to fix RMDs that are not processed in a timely manner. Does anyone think I need to do another filing to correct late RMDs?
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