Catalog Number 66144N www.irs.gov
Form
14568-A (Rev. 11-2019)
For Paperwork Reduction Act information see the current EPCRS Revenue Procedure.
Form 14568-A
(November 2019)
Department of the Treasury - Internal Revenue Service
Model VCP Compliance Statement - Schedule 1: Interim
Nonamender Failures
OMB Number
1545-1673
Include the plan name, Applicant’s EIN and plan number on each page of the compliance statement, including attachments
Plan name
EIN Plan number
Instructions:
1. Schedule 1 can be used to report the correction of a failure to timely adopt interim amendments. A compliance statement issued for a
Schedule 1 failure results in the corrective amendment being treated as if it had been timely adopted for purposes of determining the
availability of the extended remedial amendment period. Thus, an Applicant may use Schedule 1 for the failure to adopt a required
interim amendment ONLY if the corrective amendment was adopted before
the expiration of the plan’s extended remedial
amendment
cycle (as determined under Rev. Proc. 2007-44 and after December 31, 2016, Rev. Proc. 2016-37) for that amendment. If the
corrective amendment was adopted after the expiration of the remedial amendment cycle, then the plan sponsor can use Form
14568-B, Model VCP Compliance Statement Schedule 2: Other Nonamender Failures and Failure to Adopt a 403(b) Plan Timely.
2. All corrective amendments required by Sections II and IV must be properly identified. Submit separate signed and dated
amendments. If the amendments are incorporated into a signed and dated restated document, the information in the VCP
submission must specify the page and section of the document that contains the amendment.
Section I - Identification of Failures
1. Were the amendments used to correct the failures under this Schedule 1 adopted before the expiration of the applicable extended
remedial amendment cycle
Yes No
If “Yes,” proceed to line 2 of this Section I
If “No,” STOP - do NOT use this Schedule 1
In cases where late interim amendments are corrected after the expiration of the plan’s extended remedial amendment cycle, use
Form 14568-B, Model VCP Compliance Statement Schedule 2: Other Nonamender Failures and Failure to Adopt a 403(b) Plan
Timely.
2. Were the amendments adopted to correct the failure to timely adopt interim amendments
Yes No
If “Yes,” proceed to line 3 of this Section I
If “No,” STOP - do NOT use this Schedule 1
3. The Applicant has indicated that the plan sponsor did not timely adopt amendments for the following:
(List each statutory, regulatory or other requirement for which the plan was not timely amended, and specify for each requirement the
published cumulative list in which the requirement appears and the location of the corrective amendment in the documents included
with the VCP submission (for example, by amendment number and paragraph number, or in the case of a restated plan, by page and
section number). Do not use a general statement referring only to a cumulative list or statute. For instance, the following description
would not be acceptable: “All interim amendments associated with the 20XX cumulative list [or the Pension Protection Act of 2006
(PPA)] were not timely adopted.”)
(Attach additional pages as needed. Label the attachment “Form 14568-A, Section I line 3 Identification of Interim Nonamender
Failures” and include the plan name, Applicant’s EIN and plan number on each page.)
