14568-B

Model VCP Compliance Statement - Schedule 2: Nonamender Failures for IRC 401(a) Plans

Agency
IRS
Revision
Rev. 7-2023
Fillable fields
21
Pages
2
Official source
IRS form page
Checked
October 21, 2026
Fill 14568-B online
Page 1 of form 14568-B

Form 14568-B: Model VCP Compliance Statement, Schedule 2: Nonamender Failures

Form 14568-B is Schedule 2 of the Model VCP Compliance Statement. It covers nonamender failures for IRC 401(a) plans: cases where, in the form's words, the plan was not amended to comply with applicable legislative and regulatory requirements by the applicable deadlines under Internal Revenue Code Section 401(b).

The form is completed for a retirement plan by the Applicant or the plan sponsor and is part of a VCP submission. It identifies the missed amendments, states that corrective amendments were adopted retroactively, describes the steps taken so the failures do not recur, and lists the documents enclosed with the submission.

The form has no separate instructions. For Paperwork Reduction Act information it points to the current EPCRS Revenue Procedure. You can fill out the form free in your browser on this page and download it without an account.

What's on Form 14568-B

Plan identification

Plan name, Applicant's EIN and plan number. The form says to include them on each page of the compliance statement, including attachments.

Section I.A: pre-approved plans

Boxes for the 2004, 2006, 2010, 2012 and 2017 Cumulative Lists, each with the adoption deadline and the announcement or notice the form cites.

Section I.B: individually designed plans

Two boxes, for the Cumulative List and the Required Amendments List, each with space to list the items the plan was not timely amended for.

Section I.C: all IRC 401(a) plans

Boxes for amendments required for a favorable determination letter and for other nonamender failures, with space to specify them.

Section II: proposed method of correction

A printed statement that the amendments were adopted retroactively to the effective dates of their provisions and that signed copies are enclosed.

Sections III and IV: procedures and enclosures

Space to describe the steps taken so the failures will not recur, then the list of documents the plan sponsor encloses.

How to fill out Form 14568-B

  1. 1

    Identify the plan

    Enter the plan name, the Applicant's EIN and the plan number at the top of both pages and on every attachment.

  2. 2

    Section I.A

    Check each Cumulative List box that applies to a pre-approved plan that was not adopted by the deadline printed beside it.

  3. 3

    Section I.B

    For each item the plan was not timely amended for, list the year of the list, the IRS notice and, for the Cumulative List, the cycle and required adoption date. Label any attachment with the title the form gives.

  4. 4

    Section I.C

    Check the determination letter box, or check Other and specify the late amender failure, attaching labeled pages if needed.

  5. 5

    Section III

    Describe the steps the plan sponsor has taken or will take to ensure the failures will not recur.

  6. 6

    Section IV

    Gather the enclosures the form lists: signed and dated corrective amendments, the plan document in effect before them, and the most recent determination letter if there is one.

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Where it goes and what goes with it

Part of a VCP submission

The form refers to itself as part of a VCP submission. It prints no separate mailing address or deadline.

Enclosures

Copies of all signed and dated amendments used to correct the failures, a copy of the plan document in effect before them, and a copy of the most recent determination letter, if applicable.

Labeling attachments

Each attachment carries the label the form specifies, such as "Section I.C. of Form 14568-B, Identification of Other Nonamender Failures", and the plan name, Applicant's EIN and plan number at the top of each page.

Paperwork Reduction Act

The form says to see the current EPCRS Revenue Procedure for Paperwork Reduction Act information.

Who completes Form 14568-B?

  • The Applicant or plan sponsor

    The form states that the Applicant (or the plan sponsor) adopted amendments to correct the failures and encloses copies with the VCP submission.

  • Employers using pre-approved plans

    Section I.A lists eligible employers using a pre-approved defined contribution or defined benefit plan who failed to adopt it by the deadline the form names for each Cumulative List.

  • Sponsors of individually designed plans

    Section I.B covers changes required by the Cumulative List for plans on the 5-year remedial amendment cycle before January 1, 2017, and by the Required Amendments List.

  • Any IRC 401(a) plan

    Section I.C covers amendments required as a condition for a favorable determination letter and any other late amender failure not listed above.

The form is completed for an IRC 401(a) plan by the Applicant (or the plan sponsor) and enclosed with a VCP submission to the IRS. It is not a form an individual plan participant files.

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Questions about Form 14568-B

What is a nonamender failure on Form 14568-B?

The form describes a plan that was not amended to comply with applicable legislative and regulatory requirements by the applicable deadlines under IRC Section 401(b).

Who completes Form 14568-B?

The form refers to the Applicant (or the plan sponsor) of an IRC 401(a) plan, as part of a VCP submission.

What documents go with it?

The form lists signed and dated corrective amendments, the plan document in effect before them, and the most recent determination letter, if applicable.

Does Form 14568-B have instructions?

No separate instructions are linked to it. The form points to the current EPCRS Revenue Procedure for Paperwork Reduction Act information.

Which plans does Form 14568-B cover?

Its title limits it to IRC 401(a) plans: pre-approved plans, individually designed plans and any 401(a) plan with other nonamender failures.