The formulas
- Factor for each period = (1 + annual rate / 365)^days - 1, daily compounding (366 in a leap year)
- Each later period applies its factor to principal plus earnings to date
- Interest on lost earnings paid after the recovery date is computed the same way
How it works
The Voluntary Fiduciary Correction Program, as restated in January 2025, computes lost earnings at the corporate underpayment rate under Code section 6621(a)(2) for each quarter from the loss date to the recovery date, using the Revenue Procedure 95-17 factors, which incorporate daily compounding. Each later quarter's factor is applied to the principal plus the earnings to the end of the prior quarter. Enter a separate segment whenever the quarterly rate changes.
If lost earnings are paid after the recovery date, interest on them runs from the recovery date to the payment date in the same way. If lost earnings and interest exceed $100,000, the program substitutes the section 6621(c)(1) rates. Plan officials may use the department's online calculator or a manual calculation; self-correctors must use the online calculator, so treat this tool as a check on that output.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
What is the loss date for late participant contributions?
Under the program, the date the contributions could reasonably have been segregated from the employer's general assets; the self-correction component uses the date of withholding or receipt.
Where do I find the quarterly rates?
The program notice says the underpayment rates are displayed on EBSA's website alongside the online calculator.
Sources
Runs in your browser. The figures you type are not sent to CORAA or stored. Check the result against your firm's methodology before relying on it.