EBSA Announces Voluntary Correction Program Events

An Employee Benefit Security Administration (EBSA) Voluntary Fiduciary Correction Program (VFCP) Workshop will be held in Pasadena, California, on January 26, and Voluntary Fiduciary Correction Program and Abandoned Plan Workshops will be held in Detroit, Michigan, on March 20, and in Fort Wright, Kentucky, on January 27 and April 23.     

 The workshops will discuss the following Employee Retirement Income Security Act (ERISA) transactions that are eligible for correction under the VFCP: 

 • Delinquent Participant Contributions to Retirement Plans, or Insured Welfare Plans, or Welfare Plan Trusts.  

 • Fair Market Interest Rate Loans Between Employee Benefit Plans and Parties-in-Interest (PIIs).  

 • Below Market Interest Rate Loans with Parties-in-Interest, or Nonparties-in-Interest.  

 • Below Market Interest Rate Loans to PIIs or Non PIIs due to delays in perfecting loan collateral security.  

 • Participant Loan Amount Exceeds Plan Limitations.  

 • Participant Loan Duration Exceeds Plan Limitations.  

 • Default Participant Loans.  

 • Purchase of Assets by Plans from Parties-in-Interest.  

 • Sale of Assets by Plans to Parties-in-Interest.  

 • Sale and Leaseback of Property to Sponsoring Employers.  

 • Purchase of Assets from Non PIIs at other than Fair Market Value (FMV).  

 • Sale of Assets to Non PII at other than FMV.  

 • Holding of Illiquid Assets Previously Purchased by Plan Benefit Payments based on improper Valuation of Plan assets.  

 • Payment from a Plan of duplicate, excessive, or unnecessary compensation.  

 • Expenses Improperly Paid by a Plan including Settlor fees.  

 • Payment from a Plan of dual compensation to Plan fiduciaries.  

 In addition, the workshops in Detroit and Fort Wright will cover the DoL’s Abandoned Plan Program and who may qualify as a Qualified Termination Administrator (QTA).   

 Attendees can receive one-on-one assistance with respect to either the Voluntary Fiduciary Correction or Abandoned Plan Programs.  

 More about the Pasadena event is available at http://www.dol.gov/ebsa/pdf/workshopflyers/vfcpCA012612.pdf.  

 More about the Detroit event is available at http://www.dol.gov/ebsa/pdf/workshopflyers/vfcpABPlanMI.pdf.