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Catalog Number 66138J www.irs.gov
Form
14568 (Rev. 11-2019)
Plan name
Plan number
Applicant’s EIN (do not use SSN)
The Applicant requests that the IRS grant the following for plan loan failures that did not comply with IRC
Section 72(p)
With respect to all loans described in this compliance statement, that a deemed distribution corrected pursuant
to this VCP submission not be required to be reported on Form 1099-R and that repayments made by the
correction not result in the affected participant having additional basis in the plan for purposes of determining the
tax treatment of subsequent distributions from the plan.
With respect to all loans described in this compliance statement, that a deemed distribution be reported on Form
1099-R with respect to affected participants for the year of correction instead of the year of the failure.
For one or more plan loans described in this compliance statement that it be permitted to report the loans as
deemed distributions in the year of correction instead of the year of the failure. For other affected plan loans, the
plan sponsor requests relief from reporting them as deemed distributions. Attach additional narrative details that
explain why the relief should be granted and which specific loans will be receiving what type of special relief.
Section VII - Enforcement Resolution (to be completed by IRS only)
The Applicant will neither attempt to nor otherwise amortize, deduct or recover from the IRS any portion of the paid user
fee associated with this submission nor receive any federal tax benefit on account of payment of the fee.
The IRS will not pursue the sanction of revoking the tax-favored status of the plan under Sections 401(a), 403(b), 408(k)
or 408(p) of the IRC on account of the failures described in this compliance statement. This compliance statement
considers only the acceptability of the correction methods including the revisions of administrative procedures described
in the compliance statement and does not express an opinion as to the accuracy or acceptability of any calculations or
other materials included with or provided at any time during the processing of the VCP submission. The reliance provided
by this compliance statement is limited to the specific failures and years specified and does not provide reliance for any
other failure or year. In no event may this compliance statement be relied on for the purposes of concluding that the plan
or plan sponsor was not a party to an abusive tax avoidance transaction. This compliance statement should not be
construed as affecting the rights of any party under any other law, including Title I of the Employee Retirement Income
Security Act of 1974.
This compliance statement expresses no opinion as to whether the plan otherwise satisfies the requirements of the IRC
and is not a letter ruling or a determination letter within the meaning of Revenue Procedure 2019-1 (updated annually)
and Revenue Procedure 2019-4 (updated annually).
This compliance statement is conditioned on (1) there being no misstatement or omission of material facts in connection
with the submission and (2) the completion of all corrections described in this compliance statement within 150 days of the
date of this compliance statement. For governmental plans within the meaning of IRC Section 414(d), corrective plan
amendments required by this compliance statement that fix the operational failures or employer eligibility failure described
in this compliance statement, must be adopted by the later of 150 days after the date of this compliance statement or the
close of the first regular legislative session of the legislative body with the authority to amend the plan that begins on or
after 91 days after the date of this compliance statement.
The IRS will treat the failure to adopt interim amendments, as described in this compliance statement as if they had
been adopted timely for the purpose of making available the extended remedial amendment period set forth in Rev.
Proc. 2007-44 and beginning on January 1, 2017, Rev. Proc. 2016-37, or its successors. However, this compliance
statement does not constitute a determination as to whether the plan amendments, as drafted, comply with the
applicable changes in qualification requirements.
The IRS will treat the failure to timely adopt a written plan, as required under the IRC Section 403(b), Final Treasury
Regulations under IRC Section 403(b) and Notice 2009-3, as if it had been adopted timely for the purposes of
making available the extended remedial amendment period set forth in Announcement 2009-89, Rev. Proc. 2013-22,
Rev. Proc. 2017-18, Rev. Proc. 2019-39, and any future superseding guidance. However, this compliance statement
does not constitute a determination as to whether the written plan, as drafted, complies with the applicable
requirements associated with IRC Section 403(b) and the Final Treasury Regulations under IRC Section 403(b).