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Posted

You'll need to make the missed safe harbor match along with lost earnings. You need to correct under EPCRS. I'm not sure if you can self correct this failure in the 2 year window or not or if you need a VCP submission.

Failure to correct is a plan qualification issue.

Posted

This should qualify for the two-year window. The qualification defect is operational error of not following plan document.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

Posted

Yes. You're right, 30Rock. Thank you.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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