Section of Taxation
Submission to the Executive Branch

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Comments on the Voluntary Fiduciary Correction Program

  1. Use of Program Information

    Background: Successful applicants will receive a no-action letter that limits the ability of the Department to take enforcement action as to the specific matters covered in the Program application. However, the Program release states that the Department may initiate investigations where it becomes aware of possible criminal behavior, any material misrepresentations or omissions in the Program application, or other abuse of the Program; also, use of the Program does not preclude action by other governmental agencies. There is no discussion of the possible use of Program application information outside the Program.

    Comment: The Department should not use the information disclosed in applications to target particular plans or companies for ERISA enforcement investigations outside the Program. To do so would discourage use of the Program and any type of voluntary disclosure to the Department. By comparison, the IRS, recognizing this problem, has committed (albeit informally) not to use information provided through its voluntary correction programs in targeting companies for audits.

    Recommendation: The Department should provide assurance that it will not use Program application information to target companies for ERISA enforcement investigations.

Contents | Summary | Introduction | 1 | 2 | 3 | 4 | 5 | 6 | 7