Rev. Proc. 98-22, relating to the employee plans compliance resolution system.
On behalf of Tax Executives Institute, I am pleased to submit the following comments on Revenue Procedure 98-22, which sets forth the Internal Revenue Service's consolidated "Employee Plans Compliance Resolution System" (EPCRS). Section 1.05 of the procedure generally requests comments on Rev. Proc. 98-22 and the administration of EPCRS and specifically requests (1) comments regarding the extent to which a fixed (as opposed to an indefinite) self-correction period encourages prompt, voluntary correction and (2) suggestions for items that should be included in forthcoming guidance on permissible correction methods.
Tax Executives Institute is the principal association of corporate tax executives in North America. Our more than 5,000 members represent the 2,700 leading corporations in the United States and Canada. TEI represents a cross-section of the business community, and is dedicated to the development and effective implementation of sound tax policy, to promoting the uniform and equitable enforcement of the tax laws, and to reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike. As a professional association, TEI is firmly committed to maintaining a tax system that works -- one that is administrable and with which taxpayers can comply.
Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises. We believe that the diversity and professional training of our members enable us to bring an important, balanced, and practical perspective to the issues raised by Rev. Proc. 98-22, relating to the Internal Revenue Service's consolidated employee plans compliance resolution system.
TEI believes that the consolidation of the Internal Revenue Service's procedures and pronouncements on various self-correction programs in the comprehensive fashion set forth in Rev. Proc. 98-22 holds great promise for improving qualified plan compliance. TEI supports the IRS's efforts to devise equitable enforcement programs and procedures that balance the rights and expectations of plan beneficiaries and plan sponsors as well as the government's legitimate interests in regulating the administration of qualified plans. We applaud the release of Rev. Proc. 9822 because we believe that EPCRS and certain of the substantive changes made to the prior procedures and pronouncements cannot help but foster one of the primary purposes of the plan qualification process: to encourage employers to adopt and maintain retirement plans for their employees. In order to promote the prompt, voluntary correction of violations of the complex laws and regulations governing qualified plans once violations are discovered, disqualification should rarely (if ever) be a consequence of such violations. Instead, the consequences of a violation should be proportionate to that violation. As important, IRS guidance should provide certainty concerning the costs that will be incurred if the employer voluntarily discloses and corrects the defect.
Thus, although TEI believes that the IRS's replacement of the indefinite sanctions under the Walk-in Closing Agreement Program (Walkin CAP) with a defined range of compliance correction fees represents an improvement over the prior procedure, we submit that the relief provided to employers by the revenue procedure does not go far enough in the following general areas:
* conforming the IRS's administration of the tax laws relating to qualified plans to general statute of limitations principles and the administration of other provisions of the Code;
* recognizing the difficulty of administering plans to maintain zero defects and the tremendous cost and burden placed on employers with old, complicated plans;
* providing workable safe harbors and guidance about how failures should be corrected (including a procedure permitting limited retroactive amendments of plan documents to conform to the actual operation of the plan, especially where participants benefit from the plan's operation in a nondiscriminatory fashion); and
* limiting the discretion of the IRS's field agents under the Audit Closing Agreement Program (Audit CAP) to disqualify plans or to impose punitive sanctions on employers in respect of plans containing operational or other failures and prescribing sanctions proportionate to the defect.
TEI believes that if the IRS revises the revenue procedure to make the consequences of a violation proportionate to such violation, to permit flexible corrections that are not unreasonable, and to provide certainty about the forms of acceptable corrections, employers will be further encouraged to adopt and maintain plans and to correct failures voluntarily and promptly when they are discovered. The following comments and suggestions address more specifically the concerns summarized above.
Sanctions Are Inappropriate in Certain Circumstances
Section 15.01 of Rev. Proc. 98-22 states that sanction amounts under Audit CAP "will not be excessive and will bear a reasonable relationship to the nature, extent, and severity of the failures." A list of the factors the IRS will consider in fixing the amount of the sanctions is provided in section 15.02. While these general policy pronouncements are welcome, we recommend that the IRS explicitly confirm that sanctions will not be imposed for unintentional, minor, or non-egregious errors. Consistent with tax law principles that generally impose penalties only in cases involving intentional disregard of the tax laws or fraud, sanctions should apply only to egregious qualification failures attributable to gross negligence or fraud. Furthermore, even where the IRS believes sanctions are appropriate, Rev. Proc. 98-22 should be revised to acknowledge that, in many cases, the correction itself constitutes a sufficient sanction. For example, if an employer corrects the failure to notify certain employees of their right to participate in a 401(k) plan by making contributions to the plan on behalf of such employees, such contributions -- which the employer would not have been required to make had the employees been afforded the right to participate -- should be deemed a sufficient sanction. Similarly, additional profit-sharing contributions to the accounts of such employees constitute a sanction in and of themselves because either (1) the company would have made the same dollar amount of contribution (but allocated its original contribution over a larger group of participants) where the plan is based on a fixed dollar amount of profit-sharing contribution or (2) the same percentage-of-compensation contribution will inure to all employees (following the added contribution) where the plan is based on a percentage-of-compensation formula.
In the limited number of cases where the required correction is considered an insufficient remedy in itself the IRS should impose correction compliance fees (similar to those applicable in Walk-in CAP) rather than punitive sanctions for unintentional and non-egregious qualification failures. Moreover, even if the IRS declines to adopt this recommendation, it should provide guidance to taxpayers and revenue agents on the ranges of sanctions that should apply in respect of different types of failures. We believe that such guidance will encourage predictable and equitable application of the IRS's Audit CAP sanction policies.
General Statute of Limitations Principles Should Apply
Although section 5.03 of Rev. Proc. 98-22 seemingly acknowledges the application of the Code's statute of limitations provisions by referring to "open taxable years" in defining the term "Maximum Payment Amount" (which is the basis for computing sanctions under Audit CAP), section 6.02 states that "a Qualification Failure is not corrected unless full correction is made for all participants and beneficiaries, and for all taxable years (whether or not the taxable year is closed)." Consistent with the application of general statute of limitations principles, TEI recommends that Rev. Proc. 98-22 be revised to require that corrections be made only for failures that occurred in years that are then open under the statutes of limitations. Further, it should state expressly that, where a plan is disqualified after a failure to reach resolution under any of the EPCRS programs, the consequences of disqualification will be limited to taxes payable by the plan's trust, the employer maintaining the plan, and the plan's participants in the years then open under the Code.
Disqualifying Failures Should Only Have an Annual Effect
The IRS has taken the position in some cases that, where the operation of a plan in a particular year fails to comply with certain of the Code's qualification requirements, the defect results in disqualification of the plan for all years thereafter until corrected. Such an interpretation, we submit, runs counter to the policy underlying traditional statute of limitations notions as well as conventional income tax concepts. Given the technical complexity of the Code's plan qualification requirements and the virtual impossibility of achieving perfect compliance in every plan year, we recommend that the IRS apply the Code's qualification requirements on an annual, plan-year basis. Specifically, the IRS should limit the effects of qualification failures to disqualification for the year in which the failure occurs, especially in cases involving unintentional or non-egregious errors in the documentation or administration of a plan. Such an approach would be consistent with Treas. Reg [sections] 1.401-1(c), which generally provides that "qualified status must be maintained throughout the entire taxable year of the trust in order for the trust to obtain any exemption for such year." The application of the IRS's current position that disqualification continues until the violation is corrected should be limited to violations of Code provisions that explicitly mandate disqualification until correction is made. TEI's recommended approach would be consistent with the holding in Martin Fireproofing Profit Sharing Plan v. Commissioner, 92 T.C. 1173 (1989), which relies on the terms of section 415 of the Code and the pertinent regulations to conclude that such terms require disqualification until correction of the annual addition limitations is made and suggests that disqualification continues until correction only where the particular Code section that has been violated so requires. Thus, TEI recommends that Rev. Proc. 98-22 be revised to provide that, unless otherwise mandated by the Code, a plan disqualified as a result of a qualification failure is only disqualified for the year in which the failure occurs.
Abolish or Liberalize The "Not Under Examination" Requirement
Under Rev. Proc. 98-22, plans that are "Under Examination" may not avail themselves of the Voluntary Compliance Resolution Program (VCR) or Walk-in CAP. The term "Under Examination" is broadly defined in section 5.06 to include not only a plan being under an actual examination but also situations where the plan's sponsor or representative has received oral or written notification of an impending examination or referral for examination. Although this definition and condition for availability of VCR or Walk-in CAP may be defensible in respect of smaller employers and their plans, which are only infrequently or occasionally examined by the IRS, it is neither workable nor equitable when applied to large employers in the Coordinated Examination Program (CEP) or similar employers (such as "district-level" CEP taxpayers) whose income tax returns are essentially always under examination or that have received "notice" of a pending examination. In addition, large employers frequently conduct internal audits of plan operational compliance. Because such audits are extremely time consuming, a large employer that has discovered an inadvertent operational violation may well still be gathering data regarding the scope and degree of its violation (and assessing appropriate corrective measures) at the time the IRS gives notice of an impending examination or referral for examination. Hence, the application of the "Under Examination" standard may preclude relief for taxpayers with the most complex plans or the highest risk of operational defects simply because the plans are examined as part of, or in connection with, the employers' income tax audit cycle. TEI recommends that the not-under-examination requirement either not apply to such employers' plans or that the IRS circumscribe the requirement so that it applies solely to failures specifically identified by IRS either in (1) a prior examination and for which the failure remains uncorrected (or substantially the same failure has recurred) or (2) a current examination of the employer.
At a minimum, the IRS should clarify that the reference to "plan sponsor" in the representation set forth in section 12.03(9) to the effect that "neither the plan nor the plan sponsor is Under Examination" is limited to plan sponsors subject to examination by the Exempt Organizations Division as specified in the first paragraph of section 5.06. Moreover, the IRS should, at a minimum, also clarify the "Under Examination" definition in section 5.06 by stating that a reference by a revenue agent to an examination of an employer's pension or profit-sharing contribution deduction -- whether made orally or in writing in a letter, Information Document Request, audit plan, or other similar document issued in connection with the income tax examination of the employer -- does not constitute notice of an impending "examination of a Form 5500 series or other Employee Plans examination" within the meaning of section 5.06. In other words, an examination of an employer's pension or profit-sharing deduction is not, and should not be deemed to be, equivalent to notice of an impending examination or referral for examination of the plan to which the contributions are made.
A Fixed Self-Correction Period Would Not Encourage Prompt, Voluntary Correction
Since many operational defects can remain undiscovered over a number of years and because of the substantial time and effort required to determine the extent of significant operational defects and the likely cost of correction, TEI believes that an indefinite correction period is appropriate. A fixed correction period will discourage employers from undertaking remedial efforts because of the likelihood that the correction period would expire before the employer ascertains the scope and nature of the defect as well as the cost and manner of effecting alternative corrections.
Broader Exceptions to Requirement of "Full Correction"
Section 6.02 of Rev. Proc. 98-22 provides that, in order for an employer to utilize any of the self-initiated correction programs (the Administrative Policy Regarding Self-Correction (APRSC), VCR, and Walk-in CAP, and possibly even the IRS-initiated Audit CAP), the employer must make a "full correction...with respect to all participants and beneficiaries, and for all taxable years (whether or not the taxable year is closed)." The "full correction" requirement is tempered somewhat by section 6.02(4), which provides special exceptions permitting an employer to --
a) use reasonable estimates in making corrections where it is not possible to make the precise calculations that would be required in order to make a full correction;
b) omit making distributions to participants or beneficiaries where the reasonable direct costs (to the plan or the employer) of processing and delivering the distribution to the participant exceeds the amount of the distribution and the corrective distribution to the participant or beneficiary is $20 or less; and
c) avail itself of certain prescribed procedures to mitigate the requirement to locate all current and former participants to whom additional benefits would be due in order to effect full correction.
Although these exceptions seemingly flow from the statement in Rev. Proc. 98-22 that full correction may not be required in situations where it is "unreasonable or not feasible" for the employer to make a full correction, the mitigating factors appear to be exclusive. If the exceptions set forth in sections 6.02(4)(a)-(c) are representative exceptions and not exclusive, TEI recommends that this be made clear. More fundamentally, if the exceptions are intended to be exclusive, we submit that the revenue procedure is too restrictive.
In addition, the specific exceptions set forth in sections 6.02(4)(a) and (b) should be revised. Specifically, section 6.02(4)(a), which permits corrections to be made on an estimated basis, should be broadened and specific examples of acceptable estimates should be provided with respect to common operational defects. For example, Rev. Proc. 98-22 should provide that, where employees are improperly excluded from participation in a 401(k) plan, the employer should be entitled to estimate the rate of deferrals that such employees would have deferred had they been offered participation in the plan. We also submit that section 6.02(4)(b), which waives the requirement that employers make distributions to affected participants for distributable amounts of $20 or less where the direct costs of processing and delivering the distribution exceed the amount of the distribution, is too limited to be of significant value. In accordance with Rev. Proc. 98-22's statement that full correction should not be required if such correction is "unreasonable or not feasible," section 6.02(4)(b) should be revised to remove the $20 threshold and to provide that the requirement that an employer make distributions to affected participants will be waived in circumstances where the amount of the distribution does not materially exceed the costs of calculating, processing, and delivering the distribution to the participant or beneficiary, including applicable overhead and amounts paid to outside consultants to locate and review records, develop databases, and perform calculations.
In large, complex plans with a substantial number of years of operation, employers may expend millions of dollars in order to retrieve ancient records, build computerized data bases, locate all affected participants and employees, and attempt to fully and precisely correct all failures. Such costs themselves are punitive and may discourage prompt, voluntary correction of defects. As a result, TEI recommends that Rev. Proc. 9822 be revised to provide additional exceptions to the requirement of "full correction." Specifically, we recommend that the IRS excuse "full correction" where:
* the failures are de minimis, based upon the number of participants affected by the defect (relative to the total number of participants in the plan) and the number of dollars involved in the failure (relative to the total assets in the plan); or
* the failures are so remote in time that it is impossible or prohibitively expensive for the employer to find and correct the failures.
The following examples illustrate the cost involved in trying to find and correct failures in various situations and underscore the need for the IRS to adopt a reasonable and practical approach with respect to Rev. Proc. 98-22's requirement that an employer find and fully correct all failures.
Example 1. For various reasons,
many employers who
have maintained plans for
many years may no longer
have access to records regarding
Such records may be unavailable
because they were
destroyed either in a flood,
fire, or other casualty or even
in the ordinary course of
business pursuant to the
company's adherence to its
recordkeeping policy. In other
cases, companies may
have sold divisions or subsidiaries
and, in connection
with such sales, transferred
the records for transferred
employees to the new employer;
in many such cases,
the new employer may have
either subsequently destroyed
such records or retransferred
pursuant to another, subsequent
sale of the business.
Inasmuch as it is likely impossible
for an employer to
obtain records or other information
former employees, it is unreasonable
to require such
employers to make corrections
with respect to such
Example 2. Many employers
employ large numbers of
part-time employees or experience
turnover. If such an employer
discovers a defect affecting
either of these types of
employees, it can be unreasonably
burdensome or expensive
for the employer to
find every participant or
employee affected by the possible
Example 3. As discussed below,
the inadvertent exclusion
of employees entitled to
participate in a 401(k) plan
is not an uncommon plan
defect. Because of the voluntary
nature of contributions
to 401(k) plans, it is likely
impossible to determine accurately
what "full correction"
requires. Hence, it is
unduly punitive to require
an employer to make the
maximum contribution that
employees might have made
had they been permitted to
participate in the plan.
More Flexibility and Guidance Is Required Regarding Permissible Correction Methods
We recommend that Rev. Proc. 98-22 be revised to provide additional guidance on acceptable methods of correction, including prescribed safe harbors for acceptable methods of correction. The IRS has, through its examinations of employee plans and the operation of its various correction programs, garnered a substantial amount of experience in identifying the most prevalent forms of plan failures and, moreover, has likely devised consistent corrections policies to address those failures. Hence, we believe that the IRS should develop a procedure to ensure that taxpayers and revenue agents are apprised of the corrections that are considered acceptable. Under Rev. Proc. 98-22, the only correction methods that are fully prescribed are those under the Standardized VCR Procedure. In TEI's view, these corrections are too narrow and inflexible to address the bulk of cases.
Without a flexible correction policy and reasonable safe harbors, employers are unsure about the scope of their obligations to make "full correction." The potentially enormous costs of full correction for violations that may have occurred many years ago have so far inhibited many employers from using the various components of the EPCRS program (because, for example, they might have concluded that the potential exposure outweighs the possibility that the IRS will discover the defect during an examination). To encourage prompt, voluntary corrections, Rev. Proc. 9822 should permit flexible corrections and should set forth additional guidance, including safe harbor correction methods. The following are examples of issues that a flexible correction policy and guidance should address.
 In prescribing the manner in which to correct earnings to be allocated to the account of individuals erroneously excluded from a self-directed plan with multiple investment fund options, section 6.02(3)(a) of Rev. Proc. 98-22 states that a plan is permitted to use the highest rate earned by the plan for a particular year so long as most of the participants receiving the corrective allocation are not highly compensated employees. Although of some utility to employers, TEI recommends that the revenue procedure provide safe harbors permitting the use of weighted average earnings rates (or even reasonable estimates of weighted average earnings rates if information is unavailable regarding exact rates of return) for the plan's results for the participants as a whole or for a group of participants to which the excluded participant belonged. Requiring the employer to use hindsight to pick the "highest" or optimum rate of return from among multiple investment choices available to participants in a self-directed plan is unduly punitive for employers. The more numerous the investment options, the more frequent the asset valuation dates, and the more frequently participants are permitted to switch among investments, the greater the "highest rate" of return for the year will be and the higher the burden imposed on an employer simply to calculate what the correction should be. In effect, the more opportunities the employer affords participants to maximize investment gains and minimize losses (in accord with the spirit of section 404(c) of ERISA), the greater the potential correction burden on the employer. Requiring employers to determine an optimum return would be especially onerous, for example, in plans where plan assets are valued daily and participants are permitted to switch investments on a daily basis.
 Rev. Proc. 98-22 should provide guidance permitting, in limited circumstances, retroactive amendments of plan documents to conform with the operation of the plan, especially where the nondiscriminatory operation of the plan affords greater benefits or features to employees. For example, assume an employer intends to amend its plan to reduce the eligibility period for participation in the company 401(k) plan. To effect that objective, a company might communicate its intention widely (say, through a general employee newsletter or benefits bulletin), revise its plan enrollment forms as well as benefit summaries provided to new hires, reprogram its payroll and benefits information systems, and operate the plan consistently with the new, shorter eligibility rule. The sole misstep in carrying out the revised benefit policy is a failure to amend the plan document (or the summary plan description) to conform with the company's intended and actual operation of its plan. We believe Rev. Proc. 98-22 should be revised to permit retroactive plan amendments under such circumstances.
 Rev. Proc. 98-22 should provide more guidance in respect of employees who are not offered timely elections to participate in 401(k) plans whether because of recordkeeping or other failures that credit the employees with insufficient eligibility service or because of other failures to alert employees of their right to participate in the plan. Such failures are common in industries with high turnover rates or large numbers of part-time employees. Hence, a more flexible approach to correction should be permitted where the employee's participation in the plan is elective (as can be the case in defined contribution plans) rather than mandatory (as is more often the case in defined benefit plans). Rev. Proc. 98-22 fails to provide guidance distinguishing the correction methods in such cases other than to state that corrective allocations under a defined contribution plan should (1) restore the plan to the position it would have been in had the failure not occurred and (2) restore participants to the positions they would have been in had the failure not occurred (including adjustments to the participants' accounts to reflect earnings and forfeitures that would have been credited to their accounts).
Moreover, under Appendix A to Rev. Proc. 98-22 (which prescribes standard correction methods for plans availing themselves of the streamlined "Standardized VCR Procedure" (SVP) under VCR), the only authorized correction method for the improper exclusion of an employee from an elective 401(k) plan is for the employer to make a contribution to the plan on behalf of the employee equal to the "actual deferral percentage" for the group of either highly or non-highly compensated employees to which the employee belongs and to make additional contributions for any employer matching contribution or voluntary non-401(k) contributions that the employee could have made, on the same group-average basis. While this correction is literally required only for plans electing to correct under SVP, the IRS's National Office reportedly requires a comparable correction for filings that are made outside of SVP.
While the aforementioned correction technique can be justified in the context of the streamlined SVP approach, the impossibility of determining which employees would have deferred compensation, the unreasonableness of assuming that 100 percent of the affected employees would have participated at the maximum deferral permitted, and the cost to the employer of making additional contributions to the plan that it otherwise would not have made make Rev. Proc. 98-22 extraordinarily stringent. We recommend that the revenue procedure be revised to --
1) permit an employer to exclude from the correction calculation improperly excluded employees who were subsequently offered participation and who, with notice that an employer-funded make-up contribution might well depend on participation, elect not to defer any compensation; and
2) allow the remaining improperly excluded employees who participated to contribute the amounts that they would have contributed had they been offered the right to participate in the plan with the employer contributing (a) the portion of such amounts that the employee paid in income taxes and that the employee would not have paid as income taxes had the employee made the contribution in the correct year, (b) the applicable matching contribution, and (c) the applicable earnings.
In addition to expressly permitting
this correction method, Rev.
Proc. 98-22 should confirm that
such correction method is an exception
to section 6.02(3)'s general
principle that "[c]orrective allocations
should come only from
As an alternative to the recommendation in item (2) above, Rev. Proc. 98-22 should expressly permit employers to make an aggregate contribution based on a reasonable estimate of the amounts that the excluded class of employees (other than employees who were subsequently offered participation and elected not to defer any compensation) would have deferred -- for example, using average contribution rates for the group of employees to which the excluded employee belonged (such as part-time employees) -plus the aggregate amount of any employer matching contributions and earnings thereon. The employer would then allocate the gross contribution among the accounts of the excluded employees (other than employees who were subsequently offered participation and elected not to defer any compensation) in the ratios of their compensation. This correction method should be permitted if the gross contribution would not result in a violation of the Code's actual deferral or actual contribution percentage requirements.
 Another area where Rev. Proc. 98-22 should provide specific guidance on corrections is where a plan has erroneously included employees who should not have been covered by the plan, whether because the terms of the plan did not cover them or because the Code prohibited their coverage (such as in the case of a plan with a 401(k) feature that improperly covered employees of an employer's tax-exempt affiliate during the period of 1987 through 1996 in violation of section 401(k)(4)(B) of the Code). Does "full correction" require that the erroneous contribution and earnings allocations be distributed to the improperly covered employees? If so, are the distributions ineligible for rollover into an IRA or another qualified plan? TEI recommends against concluding yes to either question, but Rev. Proc. 98-22's general principle, that a plan should be restored to the position it would have been in had the failure not occurred and that assets should generally stay in the plan, fails to provide any meaningful guidance on the subject. In light of the 1996 amendment to section 40 l(k)(4)(B) of the Code (which generally permits tax-exempt employers to maintain qualified cash or deferred arrangements effective for plan years beginning after December 31, 1996), TEI believes that a 401(k) plan that improperly covered employees of an employer's tax-exempt affiliate during the period 1987 through 1996 should be permitted to retain the erroneous contributions and earnings allocations within the plan (and the employees remain participants) or that the erroneously included employees should be permitted to transfer such amounts to an IRA, SEP, or a separate qualified plan.
In sum, we recommend that the IRS use the experience, knowledge, and information that it has gained in the thousands of cases that it has considered and closed under the VCR and Walk-in CAP programs since their inception in 1992 and 1994, respectively, to provide examples describing the types of failures it has considered, the corrections it has approved and, where appropriate, to establish such corrections as safe harbors. This will promote fairness, predictability, and consistency in the administration of the tax laws. As important, employers will be encouraged to correct their plans.
Statistical Sampling and Testing Methods Should Be Permitted
Given the tremendous cost and administrative burdens involved in trying to find various kinds of operational failures that could expose a plan to the risk of disqualification, Rev. Proc. 98-22 should expressly authorize employers to utilize statistical sampling and other testing techniques to determine the incidence of failures. Consistent with our previous comments, IRS should not require the employer to make any correction if the incidence of the failure is de minimis taking into account the size of the plan and all other relevant facts and circumstances.
Tax Executives Institute appreciates this opportunity to present its views on Rev Proc. 98-22. If you should have any questions about the Institute's position or if we can be of any assistance, please do not hesitate to contact either David L. Klausman, chair of TEI's Federal Tax Committee, at (408) 765-6592 or Jeffery P. Rasmussen of the Institute's legal staff at (202) 638-5601.
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|Title Annotation:||IRS Revenue Procedure 98-22|
|Date:||Jul 1, 1998|
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