Am I reading Rev. Proc. 2000-16 correctly?
It appears to me that the fee for the VCR program is based strictly on the most recently filed 5500 at the time of the submission. So if a plan had 1,050 participants at the time of the operational failure but no more than 1000 were shown on the most recently filed 5500 at the time of submission, the fee would be based on no more than 1,000 participants, correct?
Also, it appears to me that even if the VCR covers multiple failures, including failures in different years, there is still only one fee for the submission, again based strictly on the numbers from the most recently filed 5500 at the time of submission, correct?