Top Hat DFVCP submission

[DCPensionGal]

Top hat plan never filed statement with DOL so we are taking it through DFVCP.  Do we simply file the top hat statement and pay the $750, or must we also complete and file the several page application (which application does NOT indicate this as one of the items for which this is to be filed, see below): 

Transactions Corrected Check which transactions listed in the VFCP you have corrected:

Delinquent Participant Contributions and Participant Loan Repayments to Pension Plans

Delinquent Participant Contributions to Insured Welfare Plans

Delinquent Participant Contributions to Welfare Plan Trusts

Loan at Fair Market Interest Rate to a Party in Interest

Loan at Below-Market Interest Rate to a Party in Interest

Loan at Below-Market Interest Rate to a Non-Party in Interest

Loan at Below-Market Interest Rate Due to Delay in Perfecting Plan’s Security Interest

Loans Failing to Comply with Plan Provisions for Amount, Duration or Level Amortization

Default Loans

Purchase of an Asset by a Plan from a Party in Interest

Sale of an Asset by a Plan to a Party in Interest

Sale and Leaseback of Real Property to Employer

Purchase of Asset by a Plan from a Non-Party in Interest at More Than Fair Market Value

Sale of an Asset by a Plan to a Non-Party in Interest at Less Than Fair Market Value

Holding of an Illiquid Asset Previously Purchased by a Plan

Payment of Benefits Without Properly Valuing Plan Assets on Which Payment is Based

Duplicative, Excessive, or Unnecessary Compensation Paid by a Plan

Expenses Improperly Paid by a Plan

Payment of Dual Compensation to a Plan Fiduciary

 

Correction Amount

[Luke Bailey]

DCPensionGal, I think you are confusing DFVCP with VFCP (Voluntary Fiduciary Correction Program). Just Google(TM) "Top Hat DFVCP" and click the EBSA hit, then follow the instructions to both file (late) online and pay the $750 through the website.