"The rules for correction by plan amendment have been greatly loosened by [Rev. Proc. 2019-19]. Such correction is appropriate in instances in which a plan was not operated in accordance with its terms. Such an operational failure may be corrected under SCP by an appropriate plan amendment if three conditions are satisfied ... In determining whether a plan loan failure can be corrected under SCP, the first question is whether the failure is one covered by the [DOL's] Voluntary Fiduciary Correction Program (VFCP). The VFCP provides for a no-action letter for a defaulted loan failure corrected under VCP, provided the conditions of the VFCP are met. However, the same relief does not apply if the loan failure is corrected under SCP."  MORE >>