Proposed Changes to the Department of Labor’s Voluntary Fiduciary Correction Program

Miller Johnson

On November 21, 2022, the Department of Labor (DOL) published proposed changes to its Voluntary Fiduciary Correction Program (the VFCP Program). The VFCP Program is designed to encourage employers that sponsor retirement plans to voluntarily comply with ERISA by correcting certain prohibited transactions and submitting those corrections to the DOL for approval. If the corrections are approved, the DOL will issue a “no-action” letter to the employer. The proposed changes are some of the first updates to the VFCP Program in over 15 years, and notably, they provide for a new self-correction process for delinquent participant contributions and loan repayments. These are two of the most common types of prohibited transactions under ERISA. In this webinar, Brett Liefbroer helps you learn more about the VFCP Program, when it may be necessary to make corrections under the VFCP Program, and the proposed changes.

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