"[T]he DOL's regulatory agenda includes publishing a revised VFCP this fall as an interim final rule....[O]nce the interim final rule is published, interested persons should have an opportunity to submit public comments ... Some changes that would make the VFCP more attractive are: [1] Requiring a simplified application that would lower the cost of preparing VFCP applications; [2] Allowing the correction amount due to a plan to be reduced by any payments the plan received during a prohibited transaction period; and [3] Allowing an alternative method of calculating lost earnings."