Missed RMD and VCP fee

[cathyw]

I'm a little uncertain about the fee exception in Rev Proc 2013-12 (as updated by Rev Proc 2015-27) Section 12.02(2). Does the reduced fee apply whether or not the plan sponsor requests a waiver of the 4974 excise tax?

The language states that the reduction applies only if "...the failure would result in the impostiion of the excise tax". So I can read this to mean that if there's a waiver request and the IRS won't go after the participant to impose the fee then the reduction doesn't apply, and if there's no waiver request so the IRS can go after the participant to impose the fee then the reduction does apply.

Am I reading this too narrowly?

Thanks to all.