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Posted

I believe it was late 2022 that the DOL issued proposed changes to VFCP to allow for a "self correction" option under VFCP.  

Can anyone tell me if that option is available at this time?

Thanks very much.

Posted

Here’s the reopening of the comment period:

https://www.govinfo.gov/content/pkg/FR-2023-02-14/pdf/2023-02545.pdf.

That comment period closed April 17, 2023.

https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202310&RIN=1210-AB64

One year would be quick in rulemaking time, especially when other topics consumed attention.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted
13 minutes ago, Peter Gulia said:

One year would be quick in rulemaking time, especially when other topics consumed attention

I think I heard that the the proposed rule has left OMB and is back at EBSA, but I'm not 100% sure.

ASPPA/ARA submitted a pretty lengthy comment letter during the first comment period. 

 

 

Posted

@Gilmore the proposed rule was met with a less than enthusiastic response as noted in the attached review, and in the comments from ASPPA found here:

https://www.asppa.org/news/ebsa-proposes-adding-self-correction-component-vfcp

and here https://www.asppa-net.org/news/ara-pushes-additional-changes-vfcp-self-correction-option

To answer your question, I don't see that the option is available at this time, and it seems as if there are several decisions that a plan would need/want to consider if the option, unmodified, was available now.

 

ferenczylaw.com-FLASHPOINT DOL Embraces Self-Correction Somewhat Kind of Unenthusiastically The New Proposed VFCP.pdf

Posted

Thanks everyone.  I was on the DOL site and did not see anything other than the normal VFCP information so I wanted to make sure I wasn't missing something.  Thanks for confirming.

  • 10 months later...

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