Voluntarily Correcting Failures to Comply with Post-Issuance Compliance

Voluntarily Correcting Failures to Comply with Post-Issuance Compliance Activities If the persons responsible for ensuring compliance with activities defined in this policy discover that a violation with federal tax laws may have occurred, it may address the violation through the applicable method listed below: A. Taking remedial actions as described in Section 141 of the Internal Revenue Code. B. Utilizing the Voluntary Closing Agreement Program (VCAP) – Section 7.2.3 of the Internal Revenue Manual establishes the voluntary closing agreement program for tax-exempt bonds (TEB VCAP) whereby issuers of tax-exempt bonds can resolve violations of the Internal Revenue Code through closing agreements with the Internal Revenue Service. The applicability of the remedial action regulations and VCAP to Direct Payment BABs is unclear at this time.