"It is unclear how the VCP program will be applied, since non-governmental 457(b) plans generally cannot be corrected under the [EPCRS] ... However, the Revenue Procedure states that the IRS may consider submissions by tax-exempt entities -- to correct unfunded section 457(b) deferred compensation plans that were erroneously set up to benefit rank and file employees -- if the plan has been operated in a manner similar to a qualified plan. It is unknown how the IRS will react when they encounter 457(b) plan errors by tax-exempt entities that do not fall within this narrow area of consideration."

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