Form 14568 Department of the Treasury - Internal Revenue Service (August 2016) Model VCP Compliance Statement OMB Number 1545-1673 Include the plan name, Applicant's EIN, and plan number on each page of the compliance statement, including attachments Section I - Identifying Information 1. Applicant's name 2. Applicant's EIN (do not use SSN) 4. Plan name 3. Plan number Section II - Applicant's Description of Failures Attach additional pages, as needed. Label the attachment "Section II. Applicant's Description of Failures." List and number each failure separately. If using the Form 14568 Schedules, specify the Schedule(s) that are included and attach them to this compliance statement. Section III - Applicant's Description of the Proposed Method of Correction Attach additional pages, as needed. Label the attachment "Section III. Applicant's Description of the Proposed Method of Correction." Describe the correction method for each failure listed in Section II. If using the Form 14568 Schedules, specify the Schedule(s) that are included and attach them to this compliance statement. Section IV - Applicant's Proposed Procedures to Locate and Notify Former Employees or Beneficiaries Attach additional pages, as needed. Label the attachment "Section IV. Applicant's Proposed Procedures to Locate and Notify Former Employees or Beneficiaries." Describe the method(s) that will be used to locate and notify former employees and beneficiaries, or provide an affirmative statement that no former employees or beneficiaries were affected by each failure listed in Section II or will be affected by the correction methods described in Section III. Section V - Applicant's Proposed Revision to Administrative Procedures Attach additional pages, as needed. Label the attachment "Section V. Applicant's Proposed Revision to Administrative Procedures." Please include an explanation of how and why the failures arose and a description of the measures implemented (or will be implemented) to ensure that the same failures do not occur in the future. If using the Form 14568 Schedules, specify the Schedule(s) that are included and attach them to this compliance statement. Section VI - Requests Related to Excise Taxes, Additional Tax, and Tax Reporting The Applicant requests that the Internal Revenue Service ("Service") not pursue the following taxes under the Internal Revenue Code ("Code") (attach supporting rationale) Excise tax under Code section 4972 with respect to failure(s) number Excise tax under Code section 4973 with respect to failure(s) number Excise tax under Code section 4974 with respect to failure(s) number Excise tax under Code section 4979 with respect to failure(s) number Imposition of additional tax under Code section 72(t) with respect to failure(s) number Catalog Number 66138J www.irs.gov For Paperwork Reduction Act information see the current EPCRS Revenue Procedure. American LegalNet, Inc. www.FormsWorkFlow.com Form 14568 (Rev. 8-2016) Page 2 Applicant's EIN (do not use SSN) Plan name Plan number The Applicant requests that the Service grant the following for plan loan failures that did not comply with Code section 72(p) With respect to all loan(s) 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 loan(s) described in this compliance statement, that a deemed distribution be reported on Form 1099-R with respect to affected participant(s) for the year of correction instead of the year of the failure. For one or more plan loan(s) described in this compliance statement that it be permitted to report the loan(s) as deemed distributions in the year of correction instead of the year of the failure. For other affected plan loan(s), 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 Service 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 Service will not pursue the sanction of revoking the tax-favored status of the plan under §§ 401(a), 403(b), 408(k), or 408(p) of the Internal Revenue Code ("Code") on account of the failure(s) described in this compliance statement. This compliance statement considers only the acceptability of the correction method(s) including the revision(s) 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 Agreement expresses no opinion as to whether the Plan otherwise satisfies the requirements of the Code and is not a letter ruling within the meaning of Revenue Procedure 2016-1 (and subsequent successors) and Revenue Procedure 2016-4 (and subsequent successors) or a determination letter within the meaning of Revenue Procedure 2016-6 (and subsequent successors). 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 Service will treat the failure to adopt interim amendments or amendments for optional law changes, as described in this compliance statement as if they ha