SECTION 4. DRAFT MODEL

CLOSING AGREEMENTS

Four draft model closing agreements are set forth in Exhibits A through D. Exhibit A would correct inadvertent failures to satisfy the guideline premium require

ments of § 7702. Exhibit B would correct failures to satisfy the requirements of § 7702 or the requirements of § 7702A due to improper accounting for charges for QABs. See Rev. Rul. 2005–6, Alternative C. Exhibits C and D would update the model closing agreements previously provided in Rev. Proc. 2001–42 (for inadvertent MECs) and Rev. Proc. 92–25 (for inadvertent failures to satisfy the diversification requirements of § 817(h)).