SECTION 4. COMMENTS ON REV.

PROC. 2014–32

Section 7 of Rev. Proc. 2014–32 requested comments as to whether the pilot program should be replaced by a permanent program and how the fee for such a permanent program should be determined. All of the comments received were in favor of replacing the pilot program with a permanent program, and two commenters suggested potential fee structures. Commenters noted that a permanent program is needed so that one-participant and foreign plans, which are prohibited from seeking relief under DOL’s DFVC program, may also seek relief from late-filer penalties.