The IRS has announced a new option that some providers may use where clients fail to timely sign required Document. Rather than making a submission through VCP, the IRS has announced a procedure whereby some can obtain instead a Closing Agreement.
Document Excerpt
Previously, the only way an employer could correct not signing a pre-approved defined contribution (DC) retirement plan by the deadline was to complete a submission under the Voluntary Correction Program (VCP) as outlined in 1 below. A new option, 2 below, allows the financial institution or service provider that offers the plan document to request a Closing agreement on behalf of all adopters who missed the deadline.
Link
https://www.irs.gov/Retirement-Plans/Correct-the-Failure-to-Adopt-the-Preapproved-Plan-by-the-Applicable-Deadline