IRS expands self correction to certain loan failures

Expanded Self Correction Program - EPCRS Rev. Proc. 2019-19

Only glanced at it, but early Christmas on Easter from the IRS??

"Beginning April 19, 2019 ... SCP is available to correct certain plan loan failures.... Reporting of deemed distributions ... Plan loan statutory failures.... Failure to obtain spousal consent for a plan loan.... Expanding SCP to correct certain plan loan failures by plan amendment.... [T]he Treasury Department and the IRS received comments on permitting the correction of Overpayments under SCP, and are currently developing guidance on these issues."

Rev. Proc. 2019-19

Quote

The Department of Labor’s Voluntary Fiduciary Correction Program (VFC Program), at 71 FR 20262, provides for a no-action letter for a defaulted loan failure corrected under VCP, provided the conditions of the VFC Program are met. Such noaction letters are conditioned under section 7.3(b) of that program on the inclusion of a VCP compliance statement, among other things. The Department of Labor has advised the IRS that it will not issue a no-action letter under section 7.3(b) of its VFC Program unless such failures are corrected under VCP.

Looks like we still need to keep the pressure on the DOL...

13 minutes ago, RatherBeGolfing said:

Looks like we still need to keep the pressure on the DOL...

… and maybe learn from administrative mistakes, to minimize them in the future.

1 hour ago, david rigby said:

… and maybe learn from administrative mistakes, to minimize them in the future.

Absolutely, but VCP for a simple loan fix just adds to the VCP backup.