The American Society of Pension Professionals & Actuaries filed a letter with the U.S. Department of Labor asking that it modify the Voluntary Fiduciary Correction Program as it applies to late deposits of elective deferrals under the Employee Retirement Income Security Act.

ERISA requires elective deferrals and loan repayments to be paid to a plan as soon as administratively feasible. However, DOL has recognized that well-meaning plan sponsors may occasionally fail to meet this requirement and permits the correction of these types of mistakes through the voluntary program.

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