Gilmore Posted April 4, 2024 Posted April 4, 2024 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.
Peter Gulia Posted April 4, 2024 Posted April 4, 2024 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. Gilmore 1 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
RatherBeGolfing Posted April 4, 2024 Posted April 4, 2024 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. Gilmore 1
Paul I Posted April 4, 2024 Posted April 4, 2024 @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 Gilmore 1
Gilmore Posted April 4, 2024 Author Posted April 4, 2024 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.
Angershark Posted February 15 Posted February 15 I know this is an older thread but hope you saw this just happened last month and begins in March I think.
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