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Comments on the Voluntary Fiduciary Correction Program

7. Supplements or Amendments to Applications

   Background: The Program release does not expressly permit or prohibit a fiduciary from supplementing or amending an application.

   Comment: Program applicants may discover additional information after filing their applications that would be relevant to the matters described in the applications. The Program procedure should permit such information to be added to the application so long as the application is still under consideration by the Department.

   Recommendation: The Program procedure should permit an applicant to supplement or amend a pending application to take into account later discovered information about the breaches or violations described in the application, or about related fiduciary breaches or violations that also are eligible for correction under the Program.

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