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Self-Correcting Qualified Retirement and 403(b) Plan Mistakes: New IRS Procedures and Guidance for Plan Sponsors

New IRS Rev. Proc. 2019-19 and 2018-52: Challenges and Opportunities Under the Employment Plans Compliance Resolution System

Note: CPE credit is not offered on this program

Recording of a 90-minute premium CLE webinar with Q&A

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Conducted on Tuesday, July 9, 2019

Recorded event now available

or call 1-800-926-7926

This CLE course will provide ERISA counsel and advisers guidance on the new IRS procedures for correcting benefit plan mistakes and errors for plan sponsors and administrators. The panel will discuss the recent changes to the IRS Employment Plans Compliance Resolution System (EPCRS), available options under the Self-Correction Program (SCP) and Voluntary Compliance Program (VCP), the Audit Closing Agreement Program (Audit CAP), and an in-depth analysis of the procedures necessary to correct benefit plan errors and mistakes under new changes to the EPCRS.


The IRS has significantly expanded the availability of plan sponsors to self-correct errors or failures in their benefits plans under the EPCRS. Tax-qualified retirement and 403(b) plan sponsors must grasp a complete understanding of the new options under the EPCRS and procedural nuances to maintain their plan's qualification.

IRS Revenue Procedure 2019-19 expands the SCP allowing plan sponsors to avoid penalties and potential claims. The SCP, if specific requirements are met, enables plan sponsors to correct certain plan document failures, make retroactive amendments, and correct loan failures and lack of spousal consent issues. Before this expansion, plan sponsors were forced to have these failures corrected by submission to the VCP, or in the case of an audit, the Audit CAP, subject to IRS review and increased risk of losing the plan's tax-qualified status.

ERISA counsel and advisers must consider all available correction programs for sponsors of retirement plans to accurately determine the best course of action to protect the tax-favored retirement benefits offered to their employees.

Listen as our panel discusses the available correction programs under the EPCRS, recent procedural changes to the VCP and SCP, understanding the Audit CAP, and offers in-depth guidance on the procedures necessary to correct benefit plan errors and mistakes.



  1. Available correction programs under the Employee Plans Compliance Resolution System
  2. Recent procedural changes to the Voluntary Correction Program
  3. New IRS Rev. Proc. 2019-19 expanding the Self-Correction Program
  4. Corrections through the Audit Closing Agreement Program
  5. Determining the best courses of action and best practices for ERISA counsel


The panel will review these and other key issues:

  • What programs are available under the IRS Employee Plans Compliance Resolution System?
  • How do I determine which program will be optimal for plan sponsors to maintain qualification?
  • What are the recent changes and potential pitfalls of the Voluntary Correction Program?
  • What are the challenges and opportunities under Rev. Proc. 2019-19 in expanding the Self-Correction Program?
  • Managing audits and making corrections under the Audit Closing Agreement Program
  • Avoiding procedural pitfalls and best practices to maintain a plan's tax qualification


Bokert, Mark
Mark E. Bokert

Davis + Gilbert

Mr. Bokert is co-chair of the firm's Benefits + Compensation Practice Group. His practice encompasses nearly all...  |  Read More

Kaye, T. Katuri
T. Katuri Kaye

Trucker Huss

Ms. Kaye focuses her practice primarily on qualified retirement plans, including defined benefit and defined...  |  Read More

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