Catalog Number 66138J www.irs.gov
14568 (Rev. 9-2017)
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
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 such
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 such 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 Internal Revenue Code (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 2017-1 (updated annually)
and Revenue Procedure 2017-4 (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 one hundred
fifty (150) days of the date of this compliance statement.
The IRS will treat the failure to adopt interim amendments or amendments for optional law changes, 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 any such
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 IRC
Section 403(b) regulations 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 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
IRC Section 403(b) regulations.