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Anonymous VCP Submissions

If you maintain a retirement plan, you may make an anonymous submission through the Voluntary Compliance Program (VCP) (Rev. Proc. 2013-12, section 10.10) if you:

  • haven’t been operating your plan according to the written document or the Internal Revenue Code;
  • want to propose an alternative way to correct plan errors under the Employee Plans Compliance Resolution System (EPCRS); and
  • don’t want to identify yourself to the IRS.

However, carefully consider some of the differences between coming in anonymously, as opposed to disclosed, before making an anonymous VCP submission:

  1. If the IRS can’t agree with you on a correction and closes the case without issuing a compliance statement, you’re entitled to a refund of 50% of your VCP compliance fee.

  2. The IRS doesn’t know either the plan or the applicant’s identity until the applicant discloses it, so the IRS may audit the plan before you disclose the identity of the plan and the plan sponsor to the IRS.

  3. The IRS doesn’t give priority to processing anonymous VCP submissions.

  4. Preparing an anonymous submission may require extra time because you must remove identifying information from any supporting documents (for example, you must redact the applicant and the plan’s identity before submitting documents, etc.).

Additional resources

Page Last Reviewed or Updated: 03-Apr-2017