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The Newest EPCRS: All Good News (Except When It's Not)
Ferenczy Benefits Law Center
[Guidance Overview] July 21, 2021 "Under Rev. Proc. 2021-30 ... a plan may self-correct an operational failure or a document failure up until the last day of the third plan year following the plan year of the failure. Similarly, the deadline for self-correcting an ADP/ACP failure is now the last day of the fourth plan year following the plan year of the failure.... Rev. Proc. 2021-30's change [for fixing a failure to enroll a participant in a 401(k) plan] relates primarily to the elimination of the QNEC requirement for automatic enrollment plans under a special 'safe harbor' rule. " |
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