Minor Modification of VCP Compliance Statement

[KMMB]

Anyone have experience requesting a "minor" modification of a VCP compliance statement? The only example in IRS guidance of a "minor" modification is a compliance statement that listed 200 affected participants; however, after recalculating the failure affected 225 participants. 

In our situation, the applicant got an IRS compliance statement approving a retroactive amendment adding back in a provision missing from a 2015 restatement. The compliance statement was issued over 150 days ago.  The applicant recently discovered an inconsistency between the retroactive amendment and the plan's historic administration, and believes additional clarifying language (no more than a phrase or two) should have been added to the retroactive amendment to achieve the intent of the VCP filing and conform the plan document to the plan's historic and ongoing administration.  

At bottom, we think the fix of the document could have been better, but this is a document issue only; the plan's always been operated as it should have been.

Has anyone had success requesting a "minor" modification of a VCP compliance statement under similar circumstances?

[Bob the Swimmer]

My experience is to contact the Agent assigned to the case directly and communicate the change and if they approve, then change the filing and send it to the Agent. Have had this happen several times as in some cases, circumstances can change and the IRS has been taking much longer to resolve these cases than 5 to 10 years ago.