Rev. Proc. 2010-49

Rev. Proc. 2010-49
in: Rev. Proc. 2010-49

Rev. Proc. 2010-49

SECTION 1. PURPOSE

This revenue procedure prescribes the loss payment patterns and discount factors for the 2010 accident year. These factors will be used for computing discounted unpaid losses under § 846 of the Internal Revenue Code. See Rev. Proc. 2008-10, 2008-1 C.B. 290, for background concerning the loss payment patterns and application of the discount factors.

SECTION 2. SCOPE

This revenue procedure applies to any taxpayer that is required to discount its unpaid losses under § 846 for a line of business using discount factors published by the Secretary.

SECTION 3. TABLES OF DISCOUNT FACTORS

.01 The following tables present separately for each line of business the discount factors under § 846 for accident year 2010. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 2010, which is 3.81 percent, and by assuming all loss payments occur in the middle of the calendar year.

.02 If the groupings of individual lines of business on the annual statement change, taxpayers must discount the unpaid losses on the affected lines of business in accordance with the discounting patterns that would have applied to those unpaid losses based on their classification on the 2005 annual statement. See Rev. Proc. 2008-10, section 2, for additional background on discounting under § 846 and the use of the Secretary’s tables.

.03 Section V of Notice 88-100, 1988-2 C.B. 439, sets forth a composite method for computing discounted unpaid losses for accident years that are not separately reported on the annual statement. The tables separately provide discount factors for taxpayers who elect to use the composite method of section V of Notice 88-100. See Rev. Proc. 2002-74, 2002-2 C.B. 980.

.04 Tables.

Tables of Factors to be Used to Discount Unpaid Losses Incurred in Accident Year 2010
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(Interest rate: 3.81 percent)
Lines of Business
Accident and Health (Other Than Disability Income or Credit Disability Insurance)
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Taxpayers that do not use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the 2010 and later taxable years.
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount all unpaid losses in this line of business that are outstanding at the end of the 2010 taxable year.
Auto Physical Damage
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
201089.409689.409610.590410.377497.9889
201199.684810.27520.31520.303796.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years0.15760.15760.154798.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
Commercial Auto/Truck Liability/Medical
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201023.671823.671876.328270.540692.4174
201147.542523.870852.457548.906993.2316
201266.684719.142133.315331.266993.8514
201381.510514.825818.489517.352693.8509
201490.05488.54439.94529.306293.5944
201594.73114.67635.26894.898392.9653
201697.06022.32922.93982.711892.2448
201798.11741.05721.88261.737992.3179
201898.86920.75181.13081.038291.8115
201999.11600.24670.88400.826393.4738
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.24670.63730.606495.1568
20210.24670.39060.378296.8210
2022 and later years0.24670.14390.141298.1478
Taxpayers that use the composite method of Notice 88-100 should use 95.9976 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Composite
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201034.700434.700465.299659.610491.2876
201158.607623.907241.392437.523290.6525
201271.760813.153228.239225.551490.4822
201381.49879.737918.501316.603389.7412
201487.84886.350112.151210.766088.5998
201591.42263.57398.57747.534887.8456
201693.40571.98316.59435.801487.9763
201794.22800.82225.77205.184789.8241
201895.48751.25954.51254.098990.8346
201996.35600.86853.64403.370292.4859
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.86852.77542.613694.1702
20210.86851.90691.828395.8774
20220.86851.03831.013097.5588
2023 and later years0.86850.16980.166698.1478
Taxpayers that use the composite method of Notice 88-100 should use 96.2071 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Fidelity/Surety
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201025.232825.232874.767271.306395.3711
201161.102535.869838.897537.476496.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years19.448719.448719.088598.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
Financial Guaranty/Mortgage Guaranty
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20107.78247.782492.217688.488895.9565
201162.139054.356537.861036.477896.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years18.930518.930518.579998.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
International (Composite)
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201034.700434.700465.299659.610491.2876
201158.607623.907241.392437.523290.6525
201271.760813.153228.239225.551490.4822
201381.49879.737918.501316.603389.7412
201487.84886.350112.151210.766088.5998
201591.42263.57398.57747.534887.8456
201693.40571.98316.59435.801487.9763
201794.22800.82225.77205.184789.8241
201895.48751.25954.51254.098990.8346
201996.35600.86853.64403.370292.4859
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.86852.77542.613694.1702
20210.86851.90691.828395.8774
20220.86851.03831.013097.5588
2023 and later years0.86850.16980.166698.1478
Taxpayers that use the composite method of Notice 88-100 should use 96.2071 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Medical Malpractice — Claims-Made
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20104.94254.942595.057585.586090.0359
201119.936914.994480.063173.569491.8892
201244.348924.412055.651151.499692.5402
201364.837420.488535.162632.586792.6741
201480.253015.415619.747018.121791.7692
201585.79075.537714.209313.169992.6850
201691.27225.48158.72788.086792.6547
201793.33142.05936.66866.296794.4240
201896.12572.79423.87433.689795.2335
201997.65381.52812.34622.273396.8916
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2020 and later years1.52810.81820.803098.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Medical Malpractice — Occurrence
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20101.58781.587898.412283.041884.3816
20114.47202.884295.528082.267087.1650
201217.773813.301882.226272.886688.6416
201335.881418.107664.118657.214389.2320
201452.944717.063347.055342.008889.2755
201568.434815.490131.565227.827088.1571
201679.561611.126820.438417.550385.8696
201785.81986.258214.180211.842783.5160
201890.12674.30699.87337.905780.0721
201990.37010.24349.62997.959082.6486
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.24349.38658.014285.3803
20210.24349.14318.071688.2805
20220.24348.89988.131291.3639
20230.24348.65648.193094.6469
2024 and later years0.24348.41308.257298.1478
Taxpayers that use the composite method of Notice 88-100 should use 89.4537 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Miscellaneous Casualty
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201072.906472.906427.093626.249396.8838
201193.583620.67716.41646.182096.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years3.20823.20823.148898.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery))
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201052.588052.588047.412044.429793.7097
201180.044927.457019.955118.147390.9409
201286.16256.117513.837512.605791.0982
201390.74524.58279.25488.416890.9453
201493.90063.15556.09945.522590.5422
201595.76131.86074.23873.837190.5259
201696.87551.11413.12452.848191.1536
201797.67150.79602.32852.145692.1445
201898.03290.36151.96711.859194.5101
201998.68100.64811.31901.269696.2555
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.64810.67090.657798.0252
2021 and later years0.64810.02280.022498.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.0254 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Other (Including Credit)
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201067.952867.952832.047230.891196.3926
201189.460921.508110.539110.154196.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years5.26955.26955.171998.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
Other Liability — Claims-Made
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20105.87965.879694.120483.837089.0742
201118.873512.993881.126573.792190.9593
201241.684022.810558.316053.362691.5059
201362.532220.848337.467834.154091.1557
201473.520710.988526.479324.259491.6166
201582.00368.482917.996416.540891.9114
201688.62796.624411.372110.421691.6420
201790.71072.08289.28938.696593.6193
201894.84394.13325.15614.816793.4178
201996.26891.42493.73113.548495.1017
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20201.42492.30622.231796.7713
2021 and later years1.42490.88120.864998.1478
Taxpayers that use the composite method of Notice 88-100 should use 97.1192 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Other Liability — Occurrence
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201013.659413.659486.340675.192987.0887
201124.838911.179575.161166.667288.6992
201241.779216.940358.220851.947389.2247
201358.499516.720341.500536.890788.8921
201469.519711.020330.480327.068088.8049
201577.75138.231622.248719.712388.6000
201684.22436.473015.775713.868287.9089
201783.2275\-0.996816.772515.412291.8899
201888.85245.624911.147610.268492.1130
201991.38522.53288.61488.079093.7807
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20202.53286.08205.806295.4658
20212.53283.54923.446897.1162
2022 and later years2.53281.01640.997698.1478
Taxpayers that use the composite method of Notice 88-100 should use 96.9123 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Private Passenger Auto Liability/Medical
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201042.610842.610857.389254.242094.5161
201171.582728.971928.417326.790094.2735
201284.694713.112015.305314.451294.4197
201392.35567.66107.64447.196394.1386
201496.23693.88123.76313.516093.4328
201597.92751.69072.07251.927492.9997
201698.77190.84441.22811.140592.8686
201799.26920.49730.73080.677392.6773
201899.50530.23610.49470.462593.4984
201999.64400.13870.35600.338995.1810
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.13870.21740.210596.8431
2021 and later years0.13870.07870.077398.1478
Taxpayers that use the composite method of Notice 88-100 should use 97.1586 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Products Liability — Claims-Made
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20101.02591.025998.974184.573785.4504
201111.792710.766788.207376.826187.0971
201229.364217.571670.635861.849987.5618
201355.165525.801244.834537.918384.5738
201483.417128.251616.582910.578263.7897
201564.8933\-18.523835.106729.854685.0396
201682.334617.441417.665413.221674.8445
201786.39864.064013.60149.584670.4680
201876.3310\-10.067623.669020.207485.3750
201978.79102.460021.209018.470987.0899
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20202.460018.749016.668288.9018
20212.460016.289014.796990.8395
20222.460013.829012.854292.9509
20232.460011.369110.837695.3250
2024 and later years2.46008.90918.744198.1478
Taxpayers that use the composite method of Notice 88-100 should use 91.2831 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Products Liability — Occurrence
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20105.04665.046694.953480.954985.2575
201113.69358.646986.306575.229287.1651
201228.254114.560671.745963.260088.1723
201341.308313.054258.691752.369789.2284
201459.369318.061040.630735.963188.5121
201573.071713.702426.928323.372386.7946
201674.66121.589525.338822.643389.3621
201778.98334.322121.016719.102490.8912
201886.12317.139813.876912.555690.4784
201988.69312.570011.306910.415592.1160
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20202.57008.73698.193893.7837
20212.57006.16695.887595.4689
20222.57003.59693.493397.1193
2023 and later years2.57001.02691.007998.1478
Taxpayers that use the composite method of Notice 88-100 should use 96.2670 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Reinsurance — Nonproportional Assumed Property
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201012.945812.945887.054281.183993.2567
201160.179647.233839.820436.151890.7872
201280.822520.642919.177516.496786.0213
201384.94304.120515.057012.927085.8537
201485.66800.725014.332012.680888.4791
201580.0452\-5.622919.954818.892994.6784
201686.70136.656113.298712.831096.4830
201797.253310.55202.74672.568893.5201
201897.67210.41882.32792.239996.2189
201998.80781.13571.19221.168097.9772
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2020 and later years1.13570.05640.055498.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.0716 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Reinsurance — Nonproportional Assumed Liability
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201032.591732.591767.408355.198181.8862
201133.39950.807866.600556.478184.8014
201235.49482.095364.505256.495187.5823
201344.03218.537355.967949.949289.2461
201464.829920.797935.170130.661987.1818
201566.43581.605933.564230.193989.9588
201677.809711.373822.190319.755889.0289
201782.44384.634117.556215.786989.9222
201884.19441.750715.805614.604792.4025
201987.92233.727912.077711.362994.0821
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20203.72798.34987.997695.7823
20213.72794.62194.504197.4510
2022 and later years3.72790.89400.877598.1478
Taxpayers that use the composite method of Notice 88-100 should use 97.2504 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Reinsurance — Nonproportional Assumed Financial Lines
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
20108.47838.478391.521783.123690.8239
201128.047519.569371.952566.352192.2165
201260.435132.387539.564935.881390.6897
201382.444822.009717.555214.823384.4382
201490.27207.82719.72807.413276.2044
201585.3168\-4.955114.683112.744286.7951
201688.37773.060811.622310.111286.9983
201789.99341.615710.00668.850388.4442
201881.6664\-8.326918.333617.671696.3891
201991.04919.38278.95098.785198.1478
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2020 and later years98.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.0675 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.
Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary and Theft)
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201044.575644.575655.424453.676496.8407
201188.426341.850713.573713.077896.3467
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
2012 and later years6.78696.78696.661298.1478
Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2012 taxable year.
Workers’ Compensation
Tax YearEstimated Cumulative Losses Paid (%)Estimated Losses Paid Each Year (%)Unpaid Losses at Year End (%)Discounted Unpaid Losses at Year End (%)Discount Factors (%)
------------------
201019.041019.041080.959070.220886.7362
201140.244221.203259.755851.292885.8374
201257.149716.905542.850336.022584.0661
201367.860110.710432.139926.482582.3975
201475.53997.679724.460119.666880.4034
201580.11574.575819.884315.753979.2278
201682.18282.067217.817214.248079.9677
201784.40452.221715.595512.527280.3259
201885.51951.115014.480511.868581.9618
201986.28550.766113.714511.540284.1460
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2010 accident year and that are outstanding at the end of the tax year shown.
20200.766112.948411.199386.4920
20210.766112.182310.845589.0265
20220.766111.416310.478291.7830
20230.766110.650210.096994.8047
2024 and later years0.76619.88429.701198.1478
Taxpayers that use the composite method of Notice 88-100 should use 89.9627 percent to discount unpaid losses incurred in this line of business in 2010 and prior years and that are outstanding at the end of the 2020 taxable year.

DRAFTING INFORMATION

The principal author of this revenue procedure is Sarah E. Swan of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure, contact Ms. Swan at (202) 622-8443 (not a toll-free call).

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