On January 1, 2025, Department of Labor (DOL) posted the 2024 Form 5500 series forms and instructions on the EFAST2 website. These forms and instructions direct filers wanting more information about the DOL's Voluntary Fiduciary Correction Program (VFC Program or VFCP) to specific federal register citations, and list the date the prior current documents were published (2006). Guidance published in 2025 makes those citations outdated.
On January 15, 2025, the DOL published updates to the VFCP in the Federal Register by way of a new final rule and updated PTE 2002-51 revising and improving the separately administered VFCP used by plans to self-report and correct certain fiduciary violations. Use of the updated VFCP was effective on March 17, 2025. Click here for information on the VFCP.
Filers of a 2024 Form 5500 or Form 5500-SF should refer to these updated citations, See 90 Fed. Reg. 4192 (Jan. 15, 2025) and 90 Fed. Reg. 3667 (Jan. 15, 2025), in place of the outdated 71 Fed. Reg. 20261 (Apr. 19, 2006) and Fed. Reg. 20135 (Apr. 19, 2006) in cases where they need to find more information on the VFCP. You can find these cites for the VFCP and accompanying PTE in the following places of the 2024 Form 5500 and Form 5500-SF instructions:
2024 Form 5500 instructions at:
- Line 9a of Schedule DCG at page 37.
- Schedule G, Part III, Schedule, Nonexempt Transactions, Tip Box at page 42.
- Schedule H, Line 4a instructions at page 49.
- Schedule H, Line 4d instructions Tip Box at page 50.
- Schedule I, Line 4a instructions Tip Box at page 58.
- Schedule I, Line 4d instructions Tip Box at page 59.
2024 Form 5500-SF instructions at:
- Line 10a instructions at page 15.
- Line 10b instructions, Tip Box at page 15.