VFCP Notice to Interested Persons

[ERISA11]

Who is considered an "interested person" for purposes of the VFCP notice under PTE 2002-51 (as amended in 2006)? Has anyone taken the position that (or asked the DOL whether) it is limited to only those participants and beneficiaries affected by the failure, or must the notice be given to all participants/beneficiaries in the plan (like the determination letter NIP)? I could not find any guidance on this, so just wondering about other practitioner's thoughts/experiences.

[Flyboyjohn]

I take the conservative position and provide it to all participants and beneficiaries.

However, in late deposit situations my clients usually decide to file the 5330s rather than rile up the participants with the notice.

[ERISA11]

Many thanks for the response. Very helpful.