Business of Benefits

Business of Benefits

Category Archives: EPCRS

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The “Best Efforts” Standard of the 403(b) EPCRS

Posted in EPCRS
For 403(b) late adopters of plan documents,the VCP submission is conditioned upon adoption of a plan document which is intended to comply with 403(b); the plan, in operation, must have acted in accordance with a reasonable interpretation of 403(b) during the period of time for which relief is requested; and, for that period, the plan sponsor must have engaged in a compliance review, under which it used its best efforts to find operational problems and to correct them in accordance with the principles under EPCRS. For Audit CAP, this also appears to be the required correction.… Continue Reading

The EPCRS and Audit Test of the 403(b) Regulations

Posted in 403(b), EPCRS
Now with EPCRS, we are told, being on the verge of release, and with 403(b) audits beginning to enter a new, what I would call "normalized" stage, the 2007 regs will truly be put to the test.Where this will have its impact is when you have to drill down and attempt to apply the regs in detail to any particular fact circumstance....… Continue Reading
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