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Applying EPCRS: What Does 'Under Examination' Mean?
Business of Benefits Link to more items from this source
Oct. 29, 2013
"IRS corrections rules are now based on long experience, and have quite a measure of sophistication and nuance (built of experience) baked into them.... It really shows up in the practical application of the rules. Consider EPCRS' 'Under Examination' rules. If a plan is 'Under Examination' it generally cannot take advantage of the more favorable VCP; and SCP is limited -- meaning the plan sponsor would need to rely upon the more expensive Audit Cap to fix the problems. Applying the 'Under Examination' rules really are interesting, and demonstrates the nuance."

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