"We had hoped that the IRS would allow self-correction of loan errors without filing, but they have not done so. But they have significantly reduced the filing fees, thereby relieving one of the impediments that kept plan sponsors from using VCP for the benefit of their participants.... [T]he IRS has adjusted the filing fee related to failure to make required minimum distributions.... One of the most important categories of fixes within EPCRS relates to overpayments ... In an appropriate situation, the employer can pay the overpayment without trying to recover it from the participant, or can amend the plan retroactively to conform to what was done."

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