"The new and 'improved' (there are those quotes again) VFCP leaves little ambiguity with respect to loan errors that are self-corrected via EPCRS. To obtain DOL relief, a plan fiduciary must now use DOL's new online web portal to submit information about the correction. To be clear, the information to be submitted isn't especially onerous; however, compiling the required supporting documentation is pretty much just as time-consuming as preparing a full-blown approval application."  MORE >>