"The Proposal includes a new Self-Correction Component of VFCP (SCC), but it is very limited, and unlike self-correction under the IRS's procedures [EPCRS], it requires that a notice be provided to the DOL for the self-correction to be valid. Further, the DOL emphasizes repeatedly in its new procedure the ways in which plan sponsors, fiduciaries, and others are not fully protected under VFCP and SCC ... The Proposal and the amended PTE are not effective and cannot be used until approved by the [OMB] and finalized by the DOL. The DOL is asking for comments from the public about the Proposal and the PTE by January 17, 2023."  MORE >>