Pension Protection Act Blog

In one of the clearer statements from the IRS in recent memory, the IRS provided a short and sweet statement about Appendix F to VCP applications. In Revenue Procedure 2007-49, which updates the Employee Plans Compliance System (EPCRS) as restated last year, the IRS states:

Section 11.01 of Rev. Proc. 2006-27 is supplemented to provide the following. The Appendix F format should not be modified. In addition, since it is a document that is executed by the Internal Revenue Service, it should not be submitted under the letterhead of the plan sponsor or the plan sponsor’s authorized representative. The failure to provide the information required by Appendix F in the format provided for by Appendix F may result in the application being returned as an incomplete submission.

I don’t think the IRS could have been clearer than that statement. If you are tempted to modify Appendix F when completing a VCP application, just don’t.

If you haven’t had the opportunity to complete a VCP application lately, Appendix F is from Rev. Proc. 2006-27, the update to EPCRS which the IRS released last year. Appendix F appears on page 999.

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