SIMPLE IRA & VCP Submission

[SadieJane]

SIMPLE IRA arrangements may use the VCP Procedures. However, some items on the VCP Forms seem inapplicable. For example, an employer with a SIMPLE IRA arrangement does not typically have access to the total Plan assets or the current number of Plan "participants." The employer would know the number of individuals it is currently contributing for and could, perhaps with a lot of work, aggregate all past individuals it contributed for, which still would not necessarily be the same as all current participants.  The instructions do not address exceptions for SIMPLE IRAs for these items. Any thoughts other than to include an attachment saying something along the lines of 'Because this is a SIMPLE IRA arrangement, the employer does not have the amount of plan assets or the number of plan participants." ?
 

[Gary Lesser]

You may be looking at the wrong Forms for a SIMPLE. Have you seen the Model VCP Compliance Statement - Schedule 4 SIMPLE IRAs. 

Form 14568D - Model VCP Compliance Statement - Schedule 4 SIMPLE IRAs.

If you are using more than one schedule (model forms), please explain reasons.. 

Hope this helps.

[SadieJane]

I believe Form 8950 must also be submitted -- it asks for dollar amount of Plan assets and number of participants. 

[Gary Lesser]

Sorry, forgot about that. I have entered "UNKNOWN" and have not had any problems. 

See IRM 21.5.11.3.7  (07-01-2016) regarding the assignment of plan numbers by the sponsor.