Form 8950 - Application For Voluntary Correction Program (Vcp) Page 5
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Form 8950 (1-2013)
Page
Procedural Requirements Checklist (Continued)
12 Have you included an explanation of how and why the described qualification failures arose? Include a description of the
applicable administrative procedures for the plan that were in effect at the time the described failures occurred.
13 Have you included a complete description for each qualification failure that is to be resolved by this VCP submission? The
narrative description should include the years in which the failure occurred and the number of employees affected by each
failure.
14 Have you included a detailed description of the method for correcting the failures that the plan sponsor has implemented or
proposes to implement to correct each failure described in this VCP submission? Each step of the correction method must
be described in narrative form and must include specific information needed to support the proposed correction method.
See Rev. Proc. 2013-12, section 11.03.
15 Have you included a description of the administrative measures that have been or will be implemented to ensure that the
qualification failures described in this VCP submission do not recur? See Rev. Proc. 2013-12, section 11.03.
16 For failures involving corrective contributions or distributions, have you included an explanation that provides a detailed,
narrative description explaining the methodology you have used to determine lost earnings and how this is consistent with
EPCRS correction principles? See Rev. Proc. 2013-12, sections 6.02 and 11.03.
17 For failures involving corrective contributions or distributions, have you included detailed and specific calculations for each
affected employee or a representative sample of affected employees? The sample calculations must be sufficient to
demonstrate each aspect of the proposed correction method. See Rev. Proc. 2013-12, section 11.03.
18 For failures involving participant loans that do not comply with section 72(p) requirements, have you included:
• An explanation that contains a detailed description of the failure;
• An explanation that requests income tax reporting relief, and/or a request to report the distribution on Form 1099-R in
the year of correction instead of the year of failure;
• For cases in which income tax reporting relief has been requested, detailed calculations and narrative that describe the
correction proposal and demonstrate compliance with the requirements set forth in Rev. Proc. 2013-12, sections 6.07
and 11.03?
19 For operational failures that have resulted in certain excise taxes, have you included an explanation requesting a waiver of
the excise tax under section 4972, 4973, 4974, or 4979 or additional income tax under section 72(t), as applicable? Where
required, have you included detailed explanations supporting the request? See Rev. Proc. 2013-12, section 6.09, for
information as to when such waivers are available.
20 Have you included an explanation that describes the method(s) that will be used to locate and notify former employees or
beneficiaries? If there are no former employees or beneficiaries affected by the failure described in this VCP submission or
the proposed method of correction, have you provided an affirmative statement to that effect? See Rev. Proc. 2013-12,
section 11.03.
21 If the failures described in this VCP submission include a failure related to transferred assets, as defined in Rev. Proc.
2013-12, section 5.01(7), have you included an attachment that describes the related employer transaction, including the
date of the employer transaction and the date the assets were transferred to the plan?
22 If the failures described in this VCP submission include an operational failure, have you included a copy of the plan
document (and adoption agreement, if applicable) or applicable provisions of the plan document, that were in effect during
the period of failure? See Rev. Proc. 2013-12, section 11.04.
8950
Form
(1-2013)
*37769K01201305*
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