Department of the Treasury - Internal Revenue Service
                                                                                                      OMB Number 
Form 14568-B          Model VCP Compliance Statement - Schedule 2:                                    1545-1673
(July 2023)
                      Nonamender Failures for IRC 401(a) Plans
Include the plan name, Applicant’s EIN, and plan number on each page of the compliance statement, including attachments.
Plan name

Applicant’s EIN                                     Plan number

Section I - Identification of Failures
The plan identified above was not amended to comply with the applicable provisions of the following legislative and regulatory 
requirements by the applicable deadlines in accordance with Internal Revenue Code (IRC) Section 401(b) and the regulations 
thereunder:
A. Pre-approved Plans:
The changes required by the 2004 Cumulative List (Notice 2004-84) for an eligible employer using a pre-approved defined 
contribution plan who failed to adopt the pre-approved plan by April 30, 2010, as required by Announcement 2008-23.
The changes required by the 2006 Cumulative List (Notice 2007-3) for any eligible employer using a pre-approved defined benefit 
plan who failed to adopt the pre-approved plan by April 30, 2012, as required by Announcement 2010-20.
The changes required by the 2010 Cumulative List (Notice 2010-90) for any eligible employer using a pre-approved defined 
contribution plan who failed to adopt the pre-approved plan by April 30, 2016, as required by Announcement 2014-16.
The changes required by the 2012 Cumulative List (Notice 2012-76) for any eligible employer using a pre-approved defined 
benefit plan who failed to adopt the pre-approved plan by July 31, 2020, as required by Notice 2018-5 and Notice 2020-35.
The changes required by the 2017 Cumulative List (Notice 2017-37) for any eligible employer using a pre-approved defined 
contribution plan who failed to adopt the pre-approved plan by July 31, 2022, as required by Announcement 2020-7.

B. Individually Designed Plans:
For individually designed plans subject to the 5-year remedial amendment cycle prior to January 1, 2017, the changes required by 
the Cumulative List.
(For each statutory regulatory or other requirement for which the plan was not timely amended, list each item, and specify the year 
of the Cumulative List including a reference to the IRS notice, the applicable cycle and required adoption date for the applicable 
cycle. Attach additional pages as needed. Label the attachment “Section I.B. of Form 14568-B, Identification of Failures, The 
Changes required by the Cumulative List” and include the plan name, Applicant’s EIN, and plan number at the top of each page.)

The changes required by the Required Amendments List applicable to individually designed plans.
(For each statutory regulatory or other requirement for which the plan was not timely amended, list each item and specify the year 
of the Required Amendments List including a reference to the IRS notice that includes the item. Attach additional pages as 
needed. Label the attachment “Section I.B. of Form 14568-B, Identification of Failures, The Changes required by the Required 
Amendments List” and include the plan name, Applicant’s EIN, and plan number at the top of each page.)

Catalog Number 66146J                 www.irs.gov                                              Form 14568-B (Rev. 7-2023)
For Paperwork Reduction Act information see current EPCRS Revenue Procedure.

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Plan name

Applicant’s EIN                                  Plan number

C. All IRC 401(a) Plans:
Amendments required as a condition for a favorable determination letter.
Other (specify the late amender failure not listed above) (Attach additional pages as needed. Label the attachment “Section I.C.of 
Form 14568-B, Identification of Other Nonamender Failures” and include the plan name, Applicant’s EIN, and plan number at the 
top of each page.)

Section II - Description of Proposed Method of Correction
The Applicant (or the plan sponsor) adopted amendments that satisfy the requirements of all the items checked in Section I of this 
Form 14568-B, retroactively to the effective dates of the specific provisions contained in the amendments. Copies of the signed and 
dated amendments and/or restated plan documents (where applicable) are enclosed with this VCP submission.

Section III - Change in Administrative Procedures
The Applicant indicated the plan sponsor has taken (or will take) the following steps to ensure that the failures will not recur:

Section IV - Enclosures
The plan sponsor encloses the following documents, as appropriate, with this VCP submission:
•   Copies of all signed and dated amendments used to correct the failures.
•   A copy of the plan document in effect prior to any of the amendments used to correct the failures.
•   A copy of the most recent determination letter issued with respect to the plan (if applicable).

Catalog Number 66146J   www.irs.gov                                                                   Form 14568-B (Rev. 7-2023)