Has anyone looked at the benefits/costs (not just financial) of filing under the Voluntary Fiduciary Correction Program for delinquent participant contributions under a 401(k) plan? Our client has filed IRS Form 5330 and paid the applicable excise tax and based its calculation on the earnings crediting methodology outlined in Rev. Proc. 2002-47 rather than under VFCP. The two are slightly different in that VFCP provides a "floor" based on IRC section 6621.