Ethical EPCRS

Sooner or later, every plan has some kind of operational error or misstep – but there’s some gray in the new guidance from the IRS.

Ever since Rev. Proc. 2019-19 made its appearance, there are some new options – notably the increased availability of the self-correction program (SCP) for loans and document corrections, including:

• New rules for correcting by plan amendment under the SCP.
• The ability to correct certain plan loan failures, including errors relating to the failure to repay a plan loan according to plan terms.
• Reporting of deemed distributions.
• Failure to obtain spousal consent for a plan loan.

It all looks clear enough – but the guidance from the IRS (related to the new Revenue Procedure) is arguably so minimal that it can become a judgement call for the plan sponsor - and for the guidance they are looking to you to provide as to what is suitable for SCP versus VCP.

So – what can you consider – and what should you consider? Have you taken advantage of the new options – and what issues has it raised? How is that different from the way things used to be (way back in March 2019?)?

Ah, it’s the Ethics of EPCRS – join Jennifer Swets and Heather Abrigo for a two-part “EPCRS and Ethics” session at ASPPA Annual – we’ll get into the nitty gritty of your real-life experiences – and explore creative – but ethical – alternatives that can make a real difference for your clients – and your practice.

…and it’s just one of the practice building sessions that make up ASPPA Annual – the nation’s most-valued practice-building event for retirement plan professionals (like you).

Find out more at www.asppaannual.org.