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Posted

Is there anything that prevents a plan from submitting a VCP for an operational error while a VCP for a nonamender failure is pending?

The plan isn't "under examination" according to the definition in EPCRS.

Posted

Thanks. I need to submit a streamlined VCP tomorrow to correct for late adoption of an interim amendment. We have an operational error we are also working to correct, but it's not ready to submit. The fee for the first is $375 and the fee for the second is $10,000.

We aren't too concerned about the extra $375 as long as we get the amendment corrected by the end of the RAP when we submit our 5300, and we are still eligible to correct for operational error.

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