Fiduciary Correction under VFC Must Be Made for All Employees (Posted August 15, 2001) Technical Tip 18: The following question and answer are from the DOL Q&A Session at the 2000 ASPPA Annual Conference: Under the DOL’s Voluntary Fiduciary Correction program, may the fiduciaries just correct the violations for the nonhighly compensated employees, or must they correct the violations for all employees? DOL Response: Under the Voluntary Fiduciary Correction program, fiduciaries must correct the violations for all employees. There is no distinction made between highly compensated and non-highly compensated employees under the VFC program. Caveat: The answer was drafted by Fred Reish and Brad Huss, the program moderators, based on their understandings of discussions with four senior officials of the Pension and Welfare Benefits Administration (PWBA) of the U.S. DOL. As a result, it does not represent a formal or binding position statement by the PWBA. View all Tips © 2012 Reish Luftman Reicher & Cohen, a Professional Corporation Important notice: Answers are provided as general guidance on the subjects covered in the question and are not provided as legal advice to the questioner's situation. Any legal issues should be reviewed by your legal counsel to apply the law to the particular facts of your situation.