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Rules Governing Practice before IRS

New Revenue Procedure Updates EPCRS

Revenue Procedure 2015-27, released March 27, 2015, modifies but does not replace the Employee Plans Compliance Resolution System (EPCRS) Revenue Procedure 2013-12. Changes include:

  • Recoupment. Clarifies correction rules for overpayments made to participants and requests public comments on recoupment of plan overpayments
  • Excess contributions. Modifies the Self-Correction Program (SCP) for IRC Section 415(c) failures
  • Fees. Lowers compliance fees for certain VCP submissions
  • Submission forms. New acknowledgement letter form and other VCP model document changes
  • Miscellaneous. Miscellaneous modifications to correction rules and revision of citations and cross references

Revenue Procedure 2013-12 not superseded

Use Revenue Procedure 2015-27 with the existing EPCRS revenue procedure – the new revenue procedure does not completely replace the existing guidance. Revenue Procedure 2015-27 modifies only specific targeted sections of Revenue Procedure 2013-12.

Correction of overpayment failures

The revenue procedure clarifies existing correction rules for overpayments paid to plan participants. Plans have some flexibility to correct this plan failure and don’t have to secure overpayments from affected plan participants or beneficiaries in every situation.

Request for comments – For a limited time, the IRS is requesting comments from the public on expanding EPCRS correction rules to provide additional guidance on the recovery or recoupment of overpayments. (See sections 3.02(4) and 7.)

Self-correction of Section 415(c) failures

Plan sponsors can use SCP to correct certain recurring excess annual additions if they act within a specified time. The timeframe to distribute excess annual additions is increased from 2 ½ months to 9 ½ months.

VCP fees

  • Required minimum distributions – Reduced fees may apply to a larger group of plan sponsors if a plan’s sole failure is late payment of required minimum distributions and affects 300 or fewer plan participants. Plans must meet specific conditions to qualify for reduced fee.
  • Participant loans that do not comply with IRC 72(p) – Plan sponsors may be eligible for new reduced fees based upon the number of participants with bad loans. They must meet specific conditions to qualify for the reduced fee.

Submission forms

  • New IRS Acknowledgement Letter (replaces Appendix D) – Applicants who want a written acknowledgment letter from the IRS for their VCP submission must include a partially completed IRS Letter 5265. Fill in the applicant’s name, address, and plan name and number. Appendix D is superseded and no longer permitted.
  • Required use of IRS forms – If a VCP applicant wishes to use model VCP documents, the plan sponsor must submit the current version of Form 14568 (and, if applicable, Forms 14568-A through 14568-I).
  • Appendices C and D removed – Appendix C, Appendix C Schedules and Appendix D are no longer part of Revenue Procedure 2013-12 because they were replaced by official IRS forms and letters.

Required determination letter applications

The revenue procedure clarifies when a plan sponsor is required to submit a determination letter application to the IRS when they are resolving qualification failures by adopting retroactive plan amendments, including IRS pre-approved plans.

Expanded correction period for determination letter applicants

The correction period for adopting certain corrective plan amendments is extended if the plan sponsor submits a required determination letter application concurrently with a VCP submission.

Locating lost participants

Reference to the discontinued Social Security letter forwarding program has been removed.


Several items in Revenue Procedure 2013-12 are revised to update citations or cross-references.

Table of Rev. Proc. 2013-12 sections modified

Topic Rev. Proc. 2015-27 section(s) Revises Rev. Proc. 2013-12 section(s)
Overpayments 3.02, 4.06 and 4.07 6.06(3) and 6.06(4)
415(c) failure - self-correction 4.01 4.04
VCP fees - late RMDs 4.12 12.02(2)
VCP fees - loans 4.13 12.02(3)
Acknowledgement letter 4.11 11.11
Required Form 14568 series 4.09 11.01 and 11.02
Appendices C and D removed 4.09 and 4.17 11.02 and 11.02; and
removes Appendix C, Appendix C Schedules and Appendix D
Required determination letter application 4.05 6.05(1), 6.05(2) and 6.02(3)(c)
Expanded correction period 4.08 10.07(9)
Locating lost participants 4.04 6.02(5)(d)
Miscellaneous - updated cross reference 4.02 4.11
Miscellaneous - updated cross reference 4.03 5.01(3)(c)
Miscellaneous - eligible party 4.10 11.10
Miscellaneous - updated cross reference 4.14 12.06(2)
Miscellaneous - updated cross reference 4.15 Appendix A .08
Miscellaneous - updated example 4.16 Appendix B, section 2.07(2)(b), example 26

Effective date

  • The revenue procedure is generally effective July 1, 2015.
  • Plan sponsors may elect to apply provisions on or after March 27, 2015.

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