"Although the new guidance allows plan sponsors to correct plan document failures without formal IRS approval, they have a limited time period in which to do so. This underscores the importance of periodically reviewing plan documents and catching errors quickly.... Because operational failures based on a misunderstanding of plan document provisions can sometimes continue for extended periods of time, and SCP is available for long-term errors only if those errors are 'insignificant,' there may be additional pressure on the boundaries of that standard."  MORE >>