According to the announcement, the update to the VFC program includes:
- expansion and simplification of eligible transactions;
- streamlined documentation and clarified eligibility requirements;
- a model application form;
- clarification of what constitutes “under investigation” allowing more entities to qualify for the program, and
- relief from civil penalties for transactions involving health and welfare plans.
A final amendment to add the sale of illiquid assets and certain settlor expense violations to the existing VFC Program’s class exemption also will be included in the update.
The update will be published in the April 19 Federal Register and will be effective thirty days after publication.