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New EPCRS Procedure: Electronic Submission of VCP and Not a Whole Lot More
Ferenczy Benefits Law Center Link to more items from this source
[Guidance Overview]
Oct. 4, 2018

"Practitioners who have been hoping that this version of EPCRS would permit problem participant loans to be self-corrected and better identify what constitutes an 'insignificant' error will be disappointed. While acknowledging that these issues are outstanding, the new EPCRS does not address them. The raison d'être for the new procedure is to outline that, beginning in 2019, VCP submissions will be made electronically."

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