Section 4. Required Representations or Explanation of the Corporation

1. Except as provided by Section 5 of this Corporate Governing Provision Statement, provide the following representations required by section 3.06(2)(c)(ii)(C) and (D) of Rev. Proc. 2022-19:

A. The Corporation’s S election was inadvertently invalid or terminated solely because of the adoption of one or more non-iden tical governing provisions.

B. The Corporation and each applicable shareholder satisfy all of the requirements set forth in section 3.06 of Rev. Proc.

2022-19.

C. Except as provided by section 4.2 of this Corporate Governing Provision Statement, the Corporation responds in the neg ative to each requested statement set forth in section 7.01(4) or (5) of Rev. Proc. 2022‑1, 2022-1 I.R.B. 1, or any successor revenue procedure (statements regarding whether the same or a similar issue was previously ruled on or whether a request involving the same or a similar issue was submitted or is currently pending).

D. The corporation and each applicable shareholder acted reasonably and in good faith in correcting or removing each non-iden tical governing provision upon discovery.

2. Required Explanation. If the Corporation has a positive response to any requested statement set forth in section 7.01(4) or (5) of Rev. Proc. 2022-1 (or any successor revenue procedure), the Corporation must provide an explanation for each such response as part of the description of all relevant facts required by section 3.06(2)(c)(ii)(B)( 4 ) of Rev. Proc. 2022-19.