Summary. Running a retirement plan is an operational discipline, and most failures are administrative rather than investment-related: the wrong compensation definition used for a match, an employee who should have been enrolled and was not, deferrals deposited late, or a plan document that no longer matches practice. This guide covers the year in the life of a plan — the governing documents and restatement cycle, eligibility and entry, the compensation definition that causes more corrections than anything else, contribution types and limits, deposit timing, nondiscrimination testing and safe harbor designs, the reporting and disclosure calendar, loans and distributions, and the correction programs.

A 180-employee company discovers, during a routine review, that its payroll system has been excluding bonuses from the compensation used to calculate the employer match.

The plan document defines compensation as W-2 wages plus elective deferrals, with no exclusions. Payroll was configured in 2016 by someone who is no longer there, and the exclusion was never questioned because nobody compared the payroll configuration to the plan document.

The error affects 140 participants over seven years. The correction requires the employer to contribute the missed match, plus lost earnings calculated from each missed contribution date to the date of correction — a figure that compounds substantially over seven years — for every affected participant, including those who have left.

The total is $412,000, of which roughly a third is earnings.

No investment performed badly. No fiduciary self-dealt. A payroll configuration did not match a document, and nobody checked for seven years.

This is what retirement plan failures actually look like.

The governing documents

The plan document is the legal instrument. Most small and mid-sized employers use a pre-approved plan — a document from a provider that has received an IRS opinion letter — consisting of a basic plan document (the boilerplate) and an adoption agreement (the elections). Larger plans use an individually designed document.

The critical operating rule: the plan must be administered according to its terms. Nearly every operational failure is a mismatch between what the document says and what actually happens.

The restatement cycle. Pre-approved plans must be restated on a cycle the IRS establishes — currently six years for defined contribution plans — onto the provider's newly approved document. Missing a restatement deadline is a document failure that can disqualify the plan, and correcting it through the voluntary correction program requires a filing and a fee.

Interim amendments are required when legislation or regulations change the rules, on deadlines the IRS specifies. Recent legislation has produced a long list, and the amendment deadlines have been extended more than once. Confirm with the document provider that all required amendments have been adopted, and keep the signed copies. An amendment prepared and never signed does not exist.

Discretionary amendments — changes the employer chooses, such as adding a Roth feature, changing the match, or modifying eligibility — must generally be adopted by the end of the plan year in which they are effective, with different rules for amendments reducing benefits.

The summary plan description (SPD) must be furnished to participants within 90 days of becoming covered, and to new participants and beneficiaries thereafter, with an updated SPD every five years if the plan has been amended (ten years if not). A summary of material modifications (SMM) is required within 210 days after the end of the plan year in which a material change was adopted.

What to keep, permanently: the executed plan document and every amendment, the adoption agreement, the IRS opinion or determination letter, the trust agreement, board or committee resolutions adopting the plan and each amendment, the SPD and SMMs, service provider agreements, and the fidelity bond.

Eligibility, entry, and the enrollment failures

Eligibility conditions the plan may impose:

  • A minimum age of up to 21.
  • A service requirement of up to one year of service (1,000 hours in an eligibility computation period), or up to two years if the plan provides full and immediate vesting.
  • Long-term part-time employees must now be permitted to make elective deferrals after completing a reduced number of consecutive years with at least 500 hours — a requirement that SECURE and SECURE 2.0 introduced and shortened, and one that many plans have implemented incorrectly because the tracking is different from the ordinary hours count.
  • Excluded classifications — by job category, location, or entity — subject to coverage testing and to the rule that an exclusion cannot be an indirect service condition.

Entry dates — when an eligible employee actually enters — are specified in the adoption agreement, commonly the first day of the month, quarter, or the semi-annual dates following satisfaction of the conditions. The plan may not require entry later than the earlier of the first day of the plan year or the date six months after the requirements are met.

The recurring failures:

  • Failure to enroll an eligible employee, usually because the eligibility tracking is manual or because a rehire's prior service was not counted. The correction requires a qualified nonelective contribution representing a portion of the missed deferral opportunity, plus the missed match and earnings — with reduced correction available under EPCRS safe harbors if the failure is caught and corrected promptly and the participant is given notice.
  • Enrolling an ineligible employee, which is also a failure, and which is corrected differently.
  • Missing the long-term part-time rules, which apply to employees the plan was designed to exclude.
  • Rehires — service before a break generally counts, and plans routinely restart the clock.
  • Acquired employees — service with a predecessor may be required to be counted under the plan document or the acquisition agreement.

Compensation: the single largest source of failures

Why it matters. The plan document defines compensation for three distinct purposes, and they need not be the same: plan compensation (used to calculate deferrals and employer contributions), testing compensation (§ 414(s)), and the § 415 compensation limit.

The document's definition typically starts from one of the safe harbor definitions — W-2 wages, § 3401(a) wages, or § 415 compensation — plus elective deferrals, and then applies whatever exclusions the adoption agreement elects: bonuses, commissions, overtime, fringe benefits, severance, or reimbursements.

Two rules:

  1. Payroll must be configured to match the document. The failure described at the outset is the most common operational error in the entire retirement plan universe. It is caught by comparing the payroll system's earnings codes, one by one, against the document's definition.
  2. Excluding compensation types can fail § 414(s) testing. A definition that excludes bonuses may be discriminatory if bonuses are disproportionately paid to highly compensated employees, in which case a compensation ratio test must be run and passed.

Other compensation traps:

  • Post-severance compensation — regular pay, and in some cases accrued leave, paid within a defined period after termination is generally included; severance is not.
  • The § 401(a)(17) limit on compensation that may be taken into account, adjusted annually. A participant earning above the limit must have contributions calculated only on the limited amount.
  • Deferrals from bonuses — whether the plan permits a separate election for bonus deferrals, and whether the default election applies.
  • Fringe benefits, imputed income, and third-party sick pay, each of which the payroll system codes somewhere and the document either includes or excludes.

The annual control: a written reconciliation of every payroll earnings code to the plan's compensation definition, signed off by someone who has read both. It takes an hour and prevents the most expensive correction in the field.

Contributions and limits

Elective deferrals — pre-tax, Roth, or both. The § 402(g) annual limit applies per individual across all plans, is adjusted annually, and is the participant's responsibility to monitor across employers — though the plan must correct an excess deferral it can identify, by refunding it with earnings by April 15 of the following year.

Catch-up contributions for participants age 50 and over, with an additional limit. SECURE 2.0 added an increased catch-up limit for participants in a defined age band, and a requirement that catch-up contributions by participants whose prior-year wages from the employer exceed a stated threshold be made on a Roth basis — a provision with a delayed effective date and implementation guidance that should be confirmed against the current rules before the plan is amended.

Employer contributions:

  • Matching contributions, on a formula stated in the document, with a defined match period (per payroll, monthly, quarterly, or annual) and, where the period is not annual, an optional true-up at year end so that participants who defer unevenly are not shortchanged. Whether the plan has a true-up is an adoption agreement election frequently misunderstood.
  • Nonelective contributions, including profit sharing, allocated by a formula — pro rata, integrated with Social Security, or by allocation group under a new comparability design, which requires annual general nondiscrimination testing.
  • Qualified nonelective and qualified matching contributions used in correction and testing.

The § 415 annual additions limit caps total additions to a participant's account for a limitation year at the lesser of a dollar amount (adjusted annually) or 100 percent of compensation. Exceeding it is a failure requiring correction.

Vesting. Elective deferrals, safe harbor contributions, and QNECs are always 100 percent immediately vested. Employer match and nonelective contributions may vest on a schedule — no slower than three-year cliff or six-year graded for a plan that is not top-heavy, and faster where the top-heavy rules apply. Full vesting is required on plan termination, on a partial termination (presumed at a 20 percent turnover rate), and at normal retirement age.

Forfeitures of unvested amounts must be used as the plan document specifies — to reduce employer contributions, to pay plan expenses, or to be reallocated — and must be used timely, generally in the plan year in which they occur or shortly after. Accumulated forfeiture accounts sitting unused for years are a common examination finding, and the Department of Labor has focused on whether the use of forfeitures was a fiduciary decision made prudently.

Deposit timing: the most cited violation

Participant contributions become plan assets when they can reasonably be segregated from the employer's general assets, 29 C.F.R. § 2510.3-102. Until deposited, the employer holds plan assets, and a late deposit is a prohibited transaction — the employer has, in substance, used plan assets for its own purposes.

The rule: deposit as soon as the amounts can reasonably be segregated, and in no event later than the 15th business day of the month following the month in which the amounts were withheld. That outer limit is not a safe harbor. It is a maximum, and the Department of Labor has said so repeatedly.

The small plan safe harbor: for plans with fewer than 100 participants, deposit within seven business days of withholding is deemed timely.

For large plans, the operative standard is the employer's own demonstrated capability. If the payroll provider can transmit within two days — and most can — then two days is what "reasonably segregated" means for that employer, and a five-day deposit is late. Examiners look at the employer's fastest historical deposit as evidence of what is achievable.

Why it matters disproportionately:

  • It is reported on the Form 5500, on a line the Department of Labor screens.
  • It is the most common trigger for a DOL investigation of a small plan.
  • Correction requires depositing the contributions plus lost earnings, calculated at the greater of the actual investment return or an interest rate the DOL specifies, and paying an excise tax under § 4975 reported on Form 5330 — unless corrected under the Voluntary Fiduciary Correction Program, which provides relief from the excise tax for eligible transactions meeting the class exemption's conditions.
  • It is personal fiduciary exposure for whoever controls the deposit.

The control: a written deposit schedule, an automated transmission where possible, a monthly reconciliation of amounts withheld to amounts deposited, and a named person accountable. Loan repayments withheld from payroll are subject to the same rule and are forgotten more often than deferrals.

Nondiscrimination testing

Coverage, § 410(b) — the plan must cover a sufficient percentage of non-highly compensated employees, measured by the ratio percentage test or the average benefit test.

ADP and ACP tests, §§ 401(k)(3) and 401(m)(2) — the average deferral percentage and average contribution percentage of highly compensated employees (HCEs) may not exceed that of non-highly compensated employees (NHCEs) by more than the permitted spread.

Who is an HCE: a more-than-5-percent owner in the current or preceding year, or an employee whose compensation in the preceding year exceeded a threshold adjusted annually (with an optional top-paid group election). Ownership attribution under § 318 pulls in family members, which surprises family businesses constantly.

Failing the test requires correction by the end of the following plan year — through corrective distributions of excess contributions to HCEs (with earnings, and taxable to them), QNECs to NHCEs, or a recharacterization. Distributions made more than 2½ months after the plan year end trigger a 10 percent excise tax on the employer, reported on Form 5330 — and for plans with eligible automatic contribution arrangements the window extends to six months.

Top-heavy testing, § 416 — if key employees hold more than 60 percent of account balances as of the determination date, the plan is top-heavy and must provide a minimum contribution (generally 3 percent of compensation) to all non-key participants employed on the last day, and must use an accelerated vesting schedule. Small plans with concentrated ownership are frequently top-heavy and do not realize it.

Safe harbor designs eliminate ADP, ACP, and top-heavy testing in exchange for a required, immediately vested employer contribution:

  • Basic match — 100 percent of the first 3 percent deferred plus 50 percent of the next 2 percent.
  • Enhanced match — at least as generous at every level.
  • Nonelective — 3 percent of compensation to all eligible employees regardless of deferral.
  • QACA safe harbor, paired with automatic enrollment, permitting a lower required contribution and a two-year vesting schedule.

Safe harbor plans require an annual notice to participants before the plan year for match-based designs, and SECURE eliminated the notice requirement for nonelective safe harbor designs while permitting a mid-year election to adopt a nonelective safe harbor within specified deadlines. Mid-year amendments to safe harbor plans are restricted; check the guidance before changing anything mid-year.

Automatic enrollment. SECURE 2.0 requires most new plans established after its enactment date to include automatic enrollment with an escalating default rate, subject to exceptions for small and new employers. Existing plans are grandfathered. An eligible automatic contribution arrangement (EACA) permits permissible withdrawals within a window and extends the ADP correction period; a qualified automatic contribution arrangement (QACA) provides safe harbor status.

Reporting, disclosure, and the annual calendar

Form 5500 — the annual return/report, filed electronically through EFAST2, due the last day of the seventh month after the plan year end (July 31 for a calendar-year plan), extendable 2½ months by filing Form 5558. Penalties for late filing are substantial and are assessed by both the DOL and the IRS; the Delinquent Filer Voluntary Compliance Program provides sharply reduced penalties for filings made before the DOL initiates contact.

Which form: Form 5500 for larger plans, Form 5500-SF for eligible small plans, and Form 5500-EZ for one-participant plans. The participant-count methodology for determining large-plan status and the audit requirement was changed to count participants with account balances rather than eligible participants, which removed many plans from the audit requirement.

The plan audit. Plans above the participant threshold must attach an independent qualified public accountant's report. Selecting and monitoring the auditor is a fiduciary function, and the DOL has repeatedly found deficiencies in employee benefit plan audits. Do not select on price alone; ask about the firm's employee benefit plan practice and peer review results.

Participant disclosures:

  • Summary Annual Report — within nine months after the plan year end, or two months after the Form 5500 extension.
  • 404a-5 participant fee disclosure — annually, plus quarterly statements of fees actually charged.
  • Benefit statements — quarterly for participant-directed plans, annually otherwise, including a lifetime income illustration at least annually.
  • Safe harbor notice, where applicable, generally 30 to 90 days before the plan year.
  • Automatic enrollment notice, where applicable.
  • QDIA notice — annually, for plans using a qualified default investment alternative.
  • Blackout notice — 30 to 60 days before a blackout period.
  • Special tax notice (402(f)) before an eligible rollover distribution.
  • SPD and SMMs, on the schedules above.

408(b)(2) service provider disclosure must be received by the plan fiduciary before entering into or renewing an arrangement with a covered service provider. A fiduciary that does not obtain and review it loses the prohibited transaction exemption for paying that provider — a technical failure with real consequences.

Fidelity bond, ERISA § 412 — required for every person who handles plan funds, at 10 percent of plan assets handled, with a minimum and a maximum. This is separate from fiduciary liability insurance, which is optional and protects the fiduciaries rather than the plan. Most plans have the bond and lack the insurance.

Loans, distributions, and withdrawals

Participant loans, if the plan permits them, must satisfy § 72(p):

  • Limit: the lesser of $50,000 (reduced by the highest outstanding balance in the prior 12 months) or 50 percent of the vested balance.
  • Term: five years, or longer for a principal residence loan.
  • Repayment: substantially level amortization, at least quarterly.
  • Rate: a reasonable rate of interest.
  • Documentation: an enforceable agreement and adequate security.

A loan failing these requirements is a deemed distribution, taxable to the participant. A default — missed payments beyond the plan's cure period, which may extend to the last day of the calendar quarter following the quarter of the missed payment — likewise. Missed repayments during an unpaid leave of absence are subject to specific rules, and repayments must resume on return.

In-service distributions are permitted only as the document allows: at age 59½, after a stated period of participation, from rollover accounts, or on a hardship.

Hardship distributions require an immediate and heavy financial need and an amount not exceeding the need. The rules were substantially liberalized: the requirement to take a plan loan first was eliminated, the six-month suspension of deferrals was eliminated, and earnings on deferrals and safe harbor contributions became available. Employers may rely on the participant's written certification that the need qualifies and that it cannot be relieved by other resources, unless the employer has actual knowledge to the contrary. SECURE 2.0 added several new penalty-free distribution categories — for emergency personal expenses, domestic abuse victims, terminal illness, and federally declared disasters, among others — each with its own limits and repayment rules.

Distributions on termination. The document specifies timing. Automatic cashouts of small balances are permitted, with mandatory rollover to an IRA for balances above a threshold and below the cashout limit, which SECURE 2.0 increased.

Required minimum distributions, § 401(a)(9). The beginning age was raised by SECURE and again by SECURE 2.0, on a schedule keyed to birth year. The excise tax for a missed RMD was reduced, with a further reduction for timely correction. Roth accounts in employer plans are no longer subject to pre-death RMDs. Beneficiary rules following SECURE's 10-year rule are intricate and have been the subject of extended regulatory guidance.

Rollovers. The plan must permit direct rollovers of eligible rollover distributions, provide the 402(f) notice, and apply 20 percent mandatory withholding to eligible rollover distributions paid to the participant rather than rolled directly.

QDROs. The plan must have written procedures for determining the qualified status of a domestic relations order, must notify the parties, and must segregate the amounts pending determination.

Missing participants and uncashed checks are a growing enforcement focus. Maintain census accuracy, use search methods the DOL has identified as best practices, document every attempt, and treat uncashed distribution checks as plan assets until properly distributed.

Correction programs

Errors are expected. What matters is finding and fixing them.

EPCRS — the IRS Employee Plans Compliance Resolution System — addresses failures that would jeopardize the plan's qualified status. Three components:

  • Self-Correction Program (SCP). No filing, no fee, no IRS involvement. SECURE 2.0 expanded it substantially, permitting self-correction of most eligible inadvertent failures — including many that previously required a filing — at any time before the failure is identified by the IRS, provided the plan has established practices and procedures reasonably designed to promote compliance and the correction is completed within a reasonable period. Certain failures, including egregious failures, diversion of assets, and abusive tax avoidance transactions, remain ineligible.
  • Voluntary Correction Program (VCP). A submission to the IRS with a proposed correction and a user fee, producing a compliance statement. Used for failures outside self-correction, and where the employer wants written IRS assurance.
  • Audit Closing Agreement Program (Audit CAP). Correction after the IRS finds the failure, with a negotiated sanction that is materially more expensive.

Correction principles. The correction should put the plan and participants in the position they would have been in had the failure not occurred, should be reasonable and appropriate, and should be applied consistently. EPCRS provides safe harbor correction methods for the most common failures — missed deferral opportunity, improper exclusion, incorrect compensation, missed contributions, and excess allocations.

Earnings must be restored on any corrective contribution, calculated from the date the contribution should have been made.

Notable safe harbors worth knowing:

  • Automatic enrollment failures — a correction method requiring no missed deferral contribution if corrected within a defined period and the participant is notified, provided the plan begins correct deferrals promptly.
  • Missed deferral opportunity — a QNEC of a percentage of the missed deferral (reduced where corrected promptly), plus the missed match and earnings.
  • De minimis amounts, where correction may be limited.

VFCP — the Department of Labor's Voluntary Fiduciary Correction Program — addresses fiduciary breaches, most commonly late deposit of participant contributions. It provides a no-action letter and, where the applicable class exemption's conditions are met, relief from the § 4975 excise tax. Recent updates added a self-correction component for eligible late-deposit transactions meeting defined conditions, which materially reduces the burden for the most common failure.

DFVCP — the Delinquent Filer Voluntary Compliance Program — for late Form 5500 filings, with capped penalties far below the statutory amounts, available only before DOL contact.

The pattern to avoid: discovering a multi-year failure, recognizing that the calculation is painful, and deferring it. Every year of delay adds a year of lost earnings and moves the failure closer to being found rather than disclosed.

An annual calendar

Every payroll

  • Deferrals and loan repayments withheld correctly per elections.
  • Deposit within the plan's demonstrated capability, and no later than the applicable outer limit.
  • Reconcile amounts withheld to amounts deposited.

Monthly

  • New hire eligibility tracking and entry date processing.
  • Enrollment confirmations and election changes processed.
  • Loan and distribution processing reviewed.

Quarterly

  • Participant benefit statements distributed.
  • Fee disclosure of amounts actually charged.
  • Investment committee meeting: performance review, watch list actions, fee review, and minutes.
  • Forfeiture account reviewed and applied per the document.

Annually

  • Compensation reconciliation — every payroll earnings code compared to the plan's definition, in writing.
  • Census data validated before it goes to the recordkeeper. Bad census data is the source of most testing errors.
  • Nondiscrimination testing — coverage, ADP/ACP if not safe harbor, top-heavy, and § 415 limits.
  • Corrective distributions or QNECs completed within the deadlines.
  • Form 5500 filed, with the plan audit attached if required.
  • Summary Annual Report distributed.
  • 404a-5 annual fee disclosure.
  • Safe harbor, automatic enrollment, and QDIA notices distributed on schedule.
  • Fidelity bond confirmed adequate against current assets; fiduciary insurance reviewed.
  • Fee benchmarking — recordkeeping in dollars per participant, advisory fees, and investment expense ratios, with a share class eligibility check.
  • Investment policy statement reviewed and followed.
  • Committee training, and confirmation that each member has acknowledged their role in writing.
  • Plan document confirmed current: restatement cycle, interim amendments signed, discretionary amendments adopted by year end.
  • Beneficiary designations reviewed for completeness.
  • Missing participant search efforts documented.

Every three to five years

  • Recordkeeper and adviser benchmarking or RFP.
  • Plan design review against workforce demographics and objectives.
  • Comprehensive operational self-audit.

A worked example

Bellhaven Tools, 190 employees, engages counsel after a participant complaint about a delayed match.

The self-audit finds:

  1. The compensation error described at the outset — bonuses excluded from match compensation for seven years, affecting 140 participants.
  2. Late deposits — deferrals transmitted 9 to 12 business days after each payroll for the past four years, while the payroll provider is capable of two days.
  3. Six employees who met eligibility and were never enrolled, spanning three years.
  4. A forfeiture account of $61,000 that has accumulated for five years without being applied.
  5. Long-term part-time employees never tracked for the reduced-service deferral eligibility.
  6. Two required interim amendments prepared by the document provider and never signed.

The corrections:

  • Compensation error — corrected under SCP as an eligible inadvertent failure, since the plan has established practices and procedures. The employer contributes the missed match plus earnings: $412,000. Payroll is reconfigured, and a written annual reconciliation control is established.
  • Late deposits — corrected under VFCP, depositing lost earnings for each late payroll, filing the application, and obtaining a no-action letter with excise tax relief under the class exemption. Deposits move to a two-business-day automated transmission.
  • Missed enrollments — corrected under the EPCRS safe harbor: a QNEC representing the missed deferral opportunity, plus the missed match and earnings, with notice to each participant.
  • Forfeitures — applied per the document to reduce the current year's employer contribution, with the committee documenting the decision.
  • Long-term part-time tracking implemented, with a corrective enrollment for the affected employees.
  • Amendments signed, with a memorandum documenting the timing, and reviewed for whether a VCP filing is needed for the delay.

Governance changes: a plan committee with a charter and quarterly meetings; a written annual compliance calendar; the compensation reconciliation control; a fee benchmarking exercise that reduces recordkeeping from $131 to $64 per participant; and fiduciary liability insurance obtained alongside an increased fidelity bond.

Total cost: roughly $520,000 in corrections and fees. Cost had it been found by the IRS on examination: the same corrections, plus an Audit CAP sanction, plus the excise tax without VFCP relief — and without the ability to self-correct.

Frequently asked questions

How fast must we deposit deferrals? As soon as they can reasonably be segregated. For plans under 100 participants, within seven business days is deemed timely. For larger plans, the standard is your own demonstrated capability — not the 15th business day, which is an outer limit rather than a safe harbor.

We used the wrong compensation for the match. Now what? Correct it: contribute the missed amounts plus earnings for every affected participant, including former employees. Most such failures are self-correctable, and the calculation grows every year it is deferred.

Do we have to enroll part-time employees? Employees who complete the reduced number of consecutive years with at least 500 hours must be permitted to make elective deferrals. Confirm the current requirement and check whether your tracking captures it.

Can we use forfeitures to pay our matching contribution? Only as the plan document allows, and the decision to use them for one permitted purpose rather than another is a fiduciary decision that should be documented.

What is a safe harbor plan? A design providing a required, immediately vested employer contribution in exchange for exemption from ADP, ACP, and top-heavy testing. It is the standard answer for a plan that consistently fails testing.

Do we need a plan audit? It depends on the participant count under the current methodology, which counts participants with account balances rather than all eligible employees — a change that removed many plans from the requirement.

Is a fidelity bond the same as fiduciary insurance? No. The bond is required and protects the plan against dishonesty. Fiduciary liability insurance is optional and protects the fiduciaries. Most plans have the first and lack the second.

We found a multi-year error. Should we correct it? Yes, promptly. Self-correction is broadly available for eligible inadvertent failures, the cost grows with every year of earnings, and correction after IRS discovery is materially more expensive.

Conclusion

A retirement plan is a legal document operated by a payroll system, and nearly every failure is a divergence between the two.

Three controls prevent most of it. Reconcile compensation annually — every payroll earnings code against the plan's definition, in writing. Deposit deferrals at the speed you are actually capable of, and reconcile withheld to deposited every month. And read the plan document at least once a year, against how the plan is actually being run, with someone accountable for the differences.

Everything else — testing, filings, notices, loans, distributions — is a calendar. The failures that produce six-figure corrections are almost always in the two items above, running quietly for years because nobody compared the configuration to the document.

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This guide is provided for general informational purposes and does not constitute legal or tax advice. Contribution limits, thresholds, effective dates, and correction program terms change annually and with legislation. Consult qualified ERISA counsel and the plan's advisors before relying on any figure or correcting a failure.