Description of the Proposed Method of Correction
The plan sponsor has made (or will make) nonforfeitable contributions on behalf of all eligible NHCEs. Each eligible
NHCE will receive a contribution equal to a uniform percentage of compensation. The uniform percentage is equal to
the difference between the (1) ADP that would have been required for an HCE’s deferral percentage to have passed
the nondiscrimination test and (2) the actual ADP for NHCEs. (Example: In a particular plan year, an HCE defers 10%
of compensation. The ADP for NHCEs for the same plan year is 5% of compensation. However, for the plan to pass
the nondiscrimination test, the ADP should have been 8% of compensation. The corrective contribution on behalf of
each eligible NHCE will be equal to 3% of compensation.) The corrective contribution made on behalf of each NHCE
will also be adjusted for earnings. Earnings will be calculated from the last day of the plan year for which the failure
occurred through the date of the corrective contribution. The corrective contribution (adjusted for earnings) will be
made to each affected NHCE’s SARSEP IRA. If an affected employee does not have a SARSEP IRA, a SARSEP IRA
will be established for that employee. Earnings will be calculated for an affected NHCE’s account on the basis of one
of the following methods (check one)
Actual investment results of the affected NHCE’s SARSEP IRA.
The interest rate incorporated in the Department of Labor’s Voluntary Fiduciary Correction Program Online
Calculator (VFCP Online Calculator) ( ), since the actual earnings of
the affected NHCE’s SARSEP IRA cannot be ascertained.
Actual investment results for years in which data is available, or the rate incorporated in the VFCP Online
Calculator for years in which the actual earnings of the affected NHCE’s SARSEP IRA cannot be ascertained.
The VFCP Online Calculator was or will be used for the following year(s)
The total corrective contribution (before adjusting for earnings) on behalf of the affected NHCEs for each plan year is
Former employees affected by the failure (check one)
There are no former employees affected by the failure.
Affected former employees (or if deceased, their estate or known beneficiary) will be contacted, and corrective
contributions will be made to their SARSEP IRA. To the extent that an affected former employee or beneficiary
cannot be located following a mailing to the last known address, the plan sponsor will take the actions specified
below to locate that employee or beneficiary.
After such actions are taken, if an affected employee or beneficiary is not found but is located at a later date, the
plan sponsor will make corrective contributions to the affected SARSEP IRA at that time.
Catalog Number 66147U