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SPARK Institute Comment Letter to IRS on Elimination of Reduced VCP Fees (PDF)
The SPARK Institute Link to more items from this source
[Opinion]
Feb. 23, 2018
"[SPARK is] concerned that the elimination of the alternative fees for VCP submissions involving failures to timely adopt amendments, to satisfy the required minimum distribution rules, or to correct plan loan failures could deter plan sponsors from submitting such issues for correction, resulting in more frequent adverse tax consequences for affected participants. We therefore ask that the Service reinstate the alternative VCP user fees for submissions regarding [these] failures, and allow such issues to be fully resolved through the Self Correction Program (SCP)."

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