Catalog Number 66144N www.irs.gov
Form
14568-A (Rev. 8-2016)
For Paperwork Reduction Act information see the current EPCRS Revenue Procedure.
Form 14568-A
(August 2016)
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 good faith amendments or 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 or
discretionary 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 beginning on or after 1/1/2017,
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) For submissions made under Rev. Proc. 2013-12, Schedule 1 may be used to correct the failure to timely adopt a
discretionary amendment required because of the plan’s implementation of an optional law change if the late
amendment was adopted before the expiration of the plan’s remedial amendment cycle that first included the
optional tax law change. If the amendment is not adopted by the deadline above, the result would be that the plan’s
operation would not be consistent with the plan’s terms and you can't use Schedule 1 to report that failure.
(3) All corrective amendments required by Sections II and IV must be properly identified. Separate signed and dated
amendments should be submitted. 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? Check applicable box and follow applicable instruction below:
Yes No
If “Yes,” proceed to (2) of this Section I.
If “No,” STOP - do NOT use this Schedule 1.
In cases where late good faith amendments or 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. For submissions made under Rev. Proc. 2013-12,
discretionary amendments required because of the plan’s implementation of an optional law change that are corrected
after the expiration of the plan’s extended remedial amendment cycle need to be presented as regular operational
failures.
(2) Were the amendments adopted to correct the failure to timely adopt interim amendments or amendments required to
implement optional law changes (as defined in the current EPCRS revenue procedure)?
Yes No
If “Yes,” proceed to (3) of this Section I.
If “No,” STOP - do NOT use this Schedule 1.
