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The New 403(b) EPCRS Rules: It's, Um, Complicated
Business of Benefits Link to more items from this source
[Guidance Overview]
Jan. 7, 2013

"Be prepared to work hard when you need to take a 403(b) plan through the new EPCRS process under Rev Proc 2013-12 ... especially if you have to use the VCP process, or are defending an audit under CAP. It is going to be complicated.... This is not necessarily the fault of the drafters of the Rev Proc. They were stuck with a very difficult task: to try to make something which is fundamentally different from a 401(a) plan still fit uniformly into the 401(a) correction scheme."

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