"The Pension Rights Center recommends that the three-year limitation period remain applicable for fiduciaries using the prohibited transaction exemption for delinquent contributions.... [If] the Department chooses to eliminate the three-year limitation period, [PRC recommends] that such a change only be made on a trial basis so that the Department can monitor how often employers are using the VFC Program without the three-year limitation, and that the Department also prohibit use of the exemption in the case of a third failure to timely deposit participant contributions or loan repayments."  MORE >>