With Revenue Procedure 2015-27, the IRS has made several modifications to the most recent restatement of The Employee Plans Compliance Resolution System (“EPCRS”) (found in Rev. Proc. 2013-12, 2013-4 I.R.B. 313). In general, the EPCRS sets forth a system of correction programs for sponsors of retirement plans that are intended to satisfy certain Internal Revenue Code (“Code”) sections, but have failed to meet those requirements for some period of time. EPCRS includes the Self-Correction Program (“SCP”), the Voluntary Correction Program (“VCP”) and the Audit Closing Agreement Program (“Audit CAP”).
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