14568-I

Model VCP Compliance Statement - Schedule 9:Limited Safe Harbor Correction by Plan Amendment

Agency
IRS
Revision
Rev. 9-2017
Fillable fields
156
Pages
5
Official source
IRS form page
Checked
October 21, 2026
Fill 14568-I online
Page 1 of form 14568-I

Form 14568-I: Schedule 9, Limited Safe Harbor Correction by Plan Amendment

Form 14568-I is Schedule 9 of the Model VCP Compliance Statement, titled Limited Safe Harbor Correction by Plan Amendment. It covers four retirement plan failures that the plan sponsor corrects by retroactively amending the plan: an IRC Section 401(a)(17) failure in a defined contribution plan, hardship distributions the written plan did not provide for, plan loans the written plan did not provide for, and early inclusion of otherwise eligible employees.

The form is written for the plan's Applicant and plan sponsor, not for plan participants. It identifies each failure by plan year, states the proposed correction, explains how the failures arose and lists the enclosures that go with the submission.

The form asks for the plan name, the Applicant's EIN and the plan number on each page. You can fill out the PDF free in your browser on this page and download it without an account.

What's on Form 14568-I

Section I-A: IRC Section 401(a)(17) failure

Boxes for contributions or forfeitures, a table of plan years, excess allocations and participants affected, the correction method, the earnings method and how former employees are handled.

Section I-B: Hardship Distribution Failure

A table of hardship distributions by plan year, split between Highly Compensated Employees (HCEs) and Nonhighly Compensated Employees (NHCEs), and the effective date of the corrective amendment.

Section I-C: Plan Loan Failure

A table of participant plan loans by plan year, split between HCEs and NHCEs, and the effective date of the corrective amendment.

Section I-D: Early Inclusion failure

Boxes for the type of early inclusion, the plan's minimum age or service requirements and entry date, a table of affected NHCEs and HCEs, and the amendment's effective date.

Section II: Change in Administrative Procedures

An explanation of how and why the failures arose and the measures that will be or have been put in place so the same failures do not recur.

Section III: Enclosures

The items the plan sponsor encloses, such as copies of the correcting amendments and the plan document in effect before those amendments.

How to fill out Form 14568-I

  1. 1

    Plan identification

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

  2. 2

    Check the failures

    In Section I, check each failure that applies: A, B, C or D. Complete only the parts for the failures checked.

  3. 3

    Fill the plan year tables

    For each failure checked, enter the plan years of the failure and the counts or amounts the table asks for, such as participants affected or distributions made to HCEs and NHCEs.

  4. 4

    Failure A correction details

    Enter the fraction used and the total required contribution before earnings for each year, describe the earnings method, and check whether former employees are affected.

  5. 5

    Effective dates

    For failures B, C and D, enter the effective date of the corrective amendment in the blank at the end of the correction method paragraph.

  6. 6

    Sections II and III

    Explain how and why the failures arose and the measures taken. Then gather the enclosures listed in Section III for the failures checked.

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Where it goes and what goes with it

Part of a VCP submission

The form names the Procedural Requirements Checklist for Form 8950 and says the plan sponsor encloses the Section III items with the submission. The form prints no mailing address of its own.

Required enclosures

Section III marks two items as required: copies of all amendments used to correct the failures, adopted or proposed, and a copy of the plan document in effect before those amendments.

Failure-specific enclosures

Failure A calls for calculations for each affected employee or a representative sample. Failure D calls for a demonstration under IRC Sections 401(a)(4) and 411(d)(6), as the form describes.

Labeled attachments

The earnings method may continue on extra pages labeled "Section IA of Form 14568-I, Description of the Proposed Method of Correction-Earnings" with the plan name, EIN and plan number at the top.

No instructions on the form

The form has no separate instructions. For the Paperwork Reduction Act notice it points to the current EPCRS Revenue Procedure.

Who completes Form 14568-I?

  • Plan sponsors in a VCP submission

    The form says the plan sponsor encloses its listed items in addition to the applicable items on the Procedural Requirements Checklist for Form 8950.

  • Defined contribution plans over the pay limit

    Failure A is for contributions or forfeitures allocated on the basis of compensation in excess of the limit under IRC Section 401(a)(17).

  • Plans that offered hardship withdrawals or loans

    Failures B and C are for hardship distributions or participant loans that were made even though the written terms of the plan did not provide for them.

  • Plans that let employees in early

    Failure D is for employees treated as eligible participants before they met the plan's minimum age or service requirements or before the plan entry date.

The form speaks for the Applicant and the plan sponsor of the retirement plan. Each correction it describes is a retroactive amendment made by the plan sponsor.

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Questions about Form 14568-I

Who fills out Form 14568-I?

The plan's Applicant and plan sponsor. The form describes plan-level failures and the plan sponsor's corrective amendments, so it is not a form for individual participants.

Which failures does Schedule 9 cover?

Four: an IRC Section 401(a)(17) failure in a defined contribution plan, a hardship distribution failure, a plan loan failure, and early inclusion of otherwise eligible employees.

How are the failures corrected on this form?

Each one is corrected by the plan sponsor retroactively amending the plan. For Failure A, the form also describes an additional contribution for other employees, adjusted for earnings.

What if an affected former employee cannot be found?

The form has space for the actions the plan sponsor will take after a mailing to the last known address. It says contributions are made later if the person is located.

What goes with the form?

The applicable items on the Procedural Requirements Checklist for Form 8950, plus the amendments, the prior plan document and any calculations or demonstrations listed in Section III.