Self Correction - THM and Gateway Allocations

[52626]

Plan is cross tested. Since 2013, THMs were not allocated, and the cross tested allocation was done incorrectly by the recordkeeper. Bottom line,  the coverage testing was not satisfied each year, and participants did not get the gateway.

Can we self correct?  2013 is outside the 2 year correction period, so will this year need to be submitted under VCP?  The recordkeeper is no help and said it is the client's decision to file or not.

 

Client is going to make the accounts whole, including lost income.

[Mike Preston]

Clearly not an insignificant failure eligible for SCP after the two-year period.  File VCP or it remains subject to disqualification.