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Corrections Made Easier: IRS Expands the Self-Correction Program
Ferenczy Benefits Law Center, via FIS Relius 
[Guidance Overview] May 3, 2019
"It is expected that the next two-year restatement window for defined contribution plans will run from mid-2020 to mid-2022. The related six-year cycle will end on January 31, 2023. Therefore, if a plan is not restated by January 31, 2023 ... the plan document may no longer be subject to an opinion letter for the most recently expired cycle (i.e., the cycle ended January 31, 2023). In that case, the failure may not be self-correctable, requiring a filing under VCP. Needless to say, this is an odd result, and we hope that it is simply an unintentional glitch caused by the procedure's wording. We hope the question will be clarified (favorably) by the IRS."
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