Final Regulations

Federal Register / Vol. 63, No. 243 / Friday, December 18, 1998 / Rules and Regulations
compliance with this AD, if any, may be
obtained from the Los Angeles ACO.
(h) Special flight permits may be issued in
accordance with sections 21.197 and 21.199
of the Federal Aviation Regulations (14 CFR
21.197 and 21.199) to operate the airplane to
a location where the requirements of this AD
can be accomplished.
(i) Except as provided by paragraphs
(b)(1)(ii)(B), (b)(2)(ii), (b)(3), (c)(1)(ii),
(c)(2)(ii), (d)(2), and (e) of this AD, the actions
shall be done in accordance with McDonnell
Douglas Service Bulletin DC9–53–280, dated
December 1, 1997; or McDonnell Douglas
Service Bulletin DC9–53–280, Revision 01,
dated July 30, 1998. This incorporation by
reference was approved by the Director of the
Federal Register in accordance with 5 U.S.C.
552(a) and 1 CFR part 51. Copies may be
obtained from The Boeing Company, Douglas
Products Division, 3855 Lakewood
Boulevard, Long Beach, California 90846,
Attention: Technical Publications Business
Administration, Dept. C1–L51 (2–60). Copies
may be inspected at the FAA, Transport
Airplane Directorate, 1601 Lind Avenue,
SW., Renton, Washington; or at the FAA,
Transport Airplane Directorate, Los Angeles
Aircraft Certification Office, 3960 Paramount
Boulevard, Lakewood, California; or at the
Office of the Federal Register, 800 North
Capitol Street, NW., suite 700, Washington,
DC.
(j) This amendment becomes effective on
January 22, 1999.
Issued in Renton, Washington, on
December 11, 1998.
Darrell M. Pederson,
Acting Manager, Transport Airplane
Directorate, Aircraft Certification Service.
[FR Doc. 98–33389 Filed 12–17–98; 8:45 am]
BILLING CODE 4910–13–U

DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 602
[TD 8796]
RIN 1545–AU05

Notice, Consent and Election
Requirements of Sections 411(a)(11)
and 417 for Qualified Retirement Plans
Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulations.
AGENCY:

This document contains
regulations that provide guidance
concerning the notice and consent
requirements under section 411(a)(11)
and the notice and election
requirements under section 417 for
qualified retirement plans. These
regulations finalize proposed
regulations published in the Federal
Register on September 22, 1995. In
order to avoid delay in the
SUMMARY:

commencement of distributions, the
regulations generally allow distributions
to commence, with spousal consent if
required, in less than 30 days after a
participant receives a notice of
distribution rights if the participant
affirmatively so elects to have the
distributions commence. The
regulations affect employers that
maintain qualified plans, and
participants and beneficiaries in those
plans.
DATES: These regulations are effective
December 18, 1998.
FOR FURTHER INFORMATION CONTACT:
Robert Walsh, (202) 622–6090 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information
contained in these final regulations has
been reviewed and approved by the
Office of Management and Budget in
accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under
the control number 1545–1471.
Responses to this collection of
information are mandatory.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless the collection of information
displays a valid control number.
The estimated burden per respondent
is .011 hours.
Comments concerning the accuracy of
this burden estimate and suggestions for
reducing this burden should be sent to
the Internal Revenue Service, Attn: IRS
Reports Clearance Officer, OP:FS:FP,
Washington, DC 20224, and to the
Office of Management and Budget, Attn:
Desk Officer for the Department of the
Treasury, Office of Information and
Regulatory Affairs, Washington, DC
20503.
Books or records relating to this
collection of information must be
retained as long as their contents may
become material in the administration
of any internal revenue law. Generally,
tax returns and tax return information
are confidential, as required by 26
U.S.C. 6103.
Background
This document contains amendments
to the Income Tax Regulations (26 CFR
part 1) under section 411(a)(11) and
section 417(e). These regulations
finalize proposed regulations that were
published as a notice of proposed
rulemaking (EE–24–93) (REG–209626–
93) in the Federal Register (60 FR
49236) on September 22, 1995. The
notice of proposed rulemaking states
that the text of the proposed regulations

70009

is the same as the text of temporary
regulations which were published in the
Federal Register (60 FR 49218) on the
same day. A public hearing was held on
the temporary regulations on April 24,
1996.
As indicated in Announcement 98–87
(1998–40 I.R.B. 11), the temporary
regulations automatically expired in
September, 1998, pursuant to section
7805(e). Announcement 98–87 provides,
however, that plan sponsors may rely
upon the identical proposed regulations
until they are amended or finalized.
Prior to the issuance of the proposed
regulations, § 1.411(a)–11(c) provided
that a participant’s consent to a
distribution under section 411(a)(11)
was not valid unless the participant
received a notice of his or her rights
under the plan no more than 90 and no
less than 30 days prior to the annuity
starting date. Section 1.417(e)–1 set
forth the same 90/30-day time period for
providing the notice explaining the
qualified joint and survivor annuity and
waiver rights required under section
417(a)(3) (QJSA explanation).
Temporary regulations providing
guidance on the amendment to section
402(f) made by the Unemployment
Compensation Amendments of 1992
(UCA), published in October 1992,
generally prescribed this 90/30-day time
period for purposes of the notice
requirement under that section. In the
preamble to the UCA temporary
regulations, the IRS and Treasury
requested comments on the
appropriateness of this time period for
section 411(a)(11), as well as for section
402(f).
In response to comments on the 90/
30-day time period, the proposed
regulations modified the 30-day time
period for purposes of sections
411(a)(11) and 417. Under the proposed
regulations, if, after having received the
notice of distribution rights described in
§ 1.411(a)–11, a participant affirmatively
elects a distribution, a plan will not fail
to satisfy the consent requirement of
section 411(a)(11) merely because the
distribution is made less than 30 days
after the notice was provided to the
participant.
The proposed regulations under
section 417 made the same change to
§ 1.417(e)–1 and also provided a more
limited modification to the 30-day time
period in § 1.417(e)–1. The reception to
this change to the 30-day period for
purposes of section 417 was generally
favorable.
Commentators expressed concern
about the restatement in the proposed
regulations of the statutory requirement
that the QJSA explanation be provided
before the annuity starting date because

70010

Federal Register / Vol. 63, No. 243 / Friday, December 18, 1998 / Rules and Regulations

this requirement precluded retroactive
annuity payments for any period before
the explanation was provided.
Subsequently, section 1451 of the Small
Business Job Protection Act of 1996,
Public Law 104–188, 110 Stat. 1755
(SBJPA) added section 417(a)(7) to the
Internal Revenue Code effective for plan
years beginning on or after January 1,
1997. Section 417(a)(7) permits the plan
to provide the QJSA explanation after
the annuity starting date.
After consideration of the comments,
these final regulations generally adopt
the provisions of the proposed
regulations. However, the final
regulations under section 417 have been
modified to provide that, for plan years
beginning after December 31, 1996, the
requirement that the QJSA explanation
be provided before the annuity starting
date does not apply to the extent
provided under section 417(a)(7).
Explanation of Provisions
1. Overview of Statutory Provisions
Section 411(a)(11) provides that, if the
value of a participant’s accrued benefit
exceeds $5,000, a qualified plan
generally may not distribute the benefit
to the participant without the
participant’s consent.
Section 401(a)(11) requires that
certain distributions be made in the
form of a qualified joint and survivor
annuity (QJSA) unless, in accordance
with section 417, the participant waives
the QJSA and elects a different form of
benefit. Profit-sharing plans and stock
bonus plans that meet the requirements
of sections 401(a)(11)(B)(iii)(I) through
(III) are not subject to the survivor
annuity requirements of sections
401(a)(11) and 417.
Section 417 sets forth the
requirements applicable to a waiver of
the QJSA. Section 417(a) requires the
participant to obtain the consent of the
participant’s spouse, if any, to any
waiver of the QJSA and election of a
form of benefit other than a QJSA. Any
election made by the participant must
be revocable during the 90-day period
ending on the annuity starting date.
Section 417(a)(3) requires that, within a
reasonable period of time before the
participant’s annuity starting date, a
plan provide the participant with a
notice explaining the participant’s right
to the QJSA and the participant’s right
to waive the QJSA (QJSA explanation).
Section 417(a)(7)(B), added by SBJPA,
codified the provision in the proposed
regulations which provides that a plan
may permit a participant to elect (with
applicable spousal consent) a
distribution with an annuity starting
date after the QJSA explanation was

provided but before 30 days have
elapsed, as long as the distribution
commences more than seven days after
the explanation was provided. As
discussed above, section 417(a)(7)(A)
further provides that a plan is permitted
to provide the QJSA explanation after
the annuity starting date if the
distribution commences at least 30 days
after such explanation was provided,
subject to the same waiver of the 30-day
minimum waiting period. This is
intended to allow retroactive payments
of benefits which are attributable to the
period before the explanation.
2. Waiver of 30-day Period for QJSA
Explanation
The proposed regulations permit a
plan administrator (where not
inconsistent with the terms of the plan)
to commence distributions before the
end of the 30-day time period after the
QJSA explanation is provided, if certain
requirements are met. Specifically, after
an affirmative distribution election,
with any applicable spousal consent,
the plan may permit the distribution to
commence at any time more than seven
days after the QJSA explanation was
provided to the participant. Any
distribution election must remain
revocable until the later of the annuity
starting date or the expiration of the
seven-day period that begins the day
after the QJSA explanation is provided.
For example, if a married participant
receives the explanation of the QJSA on
November 28 and elects (with spousal
consent) on December 2 to waive the
QJSA and receive an immediate single
life annuity, the annuity starting date is
permitted to be December 1, provided
that the first payment is made no earlier
than December 6 and the participant
does not revoke the election before that
date.
Most commentators expressed
approval of this change to the 30-day
waiting period. However, one
commentator indicated that this change
would create an incentive for
participants to pressure their spouses to
consent to any waiver of the QJSA as
quickly as possible. Because it has been
codified by section 417(a)(7)(B), the
final regulations retain this waiver
provision.
3. Provision of QJSA Explanation After
Annuity Starting Date
The proposed regulations provide that
the annuity starting date must be a date
after the explanation of the QJSA is
provided to the participant, but may
precede the date the participant
affirmatively elects a distribution or the
date the distribution commences.
Commentators indicated that this rule

disadvantaged participants because it
does not allow a retroactive annuity
starting date to a date before the QJSA
explanation was provided. However,
prior to its amendment by SBJPA, the
plain language of section 417 required
the QJSA explanation to be provided
before the annuity starting date.
As discussed above, section 1451 of
the SBJPA added section 417(a)(7)(A) to
the Code. That section provides that a
plan may provide the QJSA explanation
after the annuity starting date and that
the applicable election period shall not
end before the 30th day after the date on
which the explanation is provided.
Thus, section 417(a)(7)(A) allows
retroactive payments of benefits which
are attributable to the period before the
QJSA explanation is provided.
Accordingly, the final regulations
provide that, for plan years beginning
after December 31, 1996, the
requirement that the QJSA explanation
be provided before the annuity starting
date does not apply to the extent
provided under section 417(a)(7).
Section 417(a)(7)(A) provides that the
Secretary may by regulations limit its
application except that such regulations
may not limit the period of time by
which the annuity starting date
precedes the provision of the written
explanation other than by providing that
the annuity starting date may not be
earlier than termination of employment.
4. Use of Electronic Media for Notices
and Consent
Comments on the proposed
regulations requested that the IRS and
Treasury clarify the extent to which
plans may use new technologies,
including electronic media, for
providing notices under sections 402(f),
411(a)(11) and 417, and for receiving
participant and beneficiary consents
and elections under sections 411(a)(11)
and 417. Subsequently, section 1510 of
the Taxpayer Relief Act of 1997 (TRA
’97) provided generally for the Secretary
of the Treasury to issue guidance
concerning the use of new technologies
in the administration of retirement
plans. Announcement 98–62 (1998–29
I.R.B. 13) requested comments on the
guidance described in section 1510.
After consideration of the comments
on the proposed regulations and
Announcement 98–62, the IRS and
Treasury have decided to propose
regulations regarding the use of
electronic media to provide notices
under sections 402(f), 411(a)(11), and
section 3405(e)(10) and for receiving
participant consent under section
411(a)(11). Those proposed regulations
are set forth in a notice of proposed

Federal Register / Vol. 63, No. 243 / Friday, December 18, 1998 / Rules and Regulations
rulemaking published elsewhere in this
issue of the Federal Register.

Adoption of Amendments to the
Regulations

5. 90-day Time Period

Accordingly, 26 CFR parts 1 and 602
are amended as follows:

Comments on the proposed
regulations requested an expansion of
the 90-day time period, and the IRS and
the Treasury have decided to propose
changes to the 90/30-day period for
providing notices under sections 402(f)
and 411(a)(11). These changes are
included in the proposed regulations on
the use of new technologies, which are
set forth in a notice of proposed
rulemaking published elsewhere in this
issue of the Federal Register.
6. Effective Dates
The regulations apply to distributions
on or after September 22, 1995.
However, plan sponsors and plan
administrators may rely on the
regulations under section 411(a)(11) as
though they were included in the final
regulations under section 411(a)(11)
published in 1988–2 C.B. 48.
Special Analyses
It has been determined that this
Treasury decision is not a significant
regulatory action as defined in EO
12866. Therefore, a regulatory
assessment is not required. It also has
been determined that section 553(b) of
the Administrative Procedure Act (5
U.S.C. chapter 5) does not apply to these
regulations, and because the notice of
proposed rulemaking was issued prior
to March 29, 1996, the Regulatory
Flexibility Act (5 U.S.C. chapter 6) does
not apply. Pursuant to section 7805(f) of
the Internal Revenue Code, the notice of
proposed rulemaking preceding these
regulations was submitted to the Chief
Counsel for Advocacy of the Small
Business Administration for comment
on their impact on small business.
Drafting Information
The principal author of these
regulations is Robert Walsh, Office of
the Associate Chief Counsel (Employee
Benefits and Exempt Organizations),
IRS. However, other personnel from the
IRS and Treasury Department
participated in their development.
List of Subjects
26 CFR Part 1
Income taxes, Reporting and
recordkeeping requirements.
26 CFR Part 602
Reporting and recordkeeping
requirements.

PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read, in part, as
follows:
Authority: 26 U.S.C. 7805 * * *

Par. 2. Section 1.411(a)–11 is
amended as follows:
1. Paragraph (c)(2)(ii) is revised.
2. Paragraphs (c)(2)(iii), (c)(2)(iv),
(c)(2)(v) and (c)(8) are added.
The revision and additions read as
follows:
§ 1.411(a)–11 Restriction and valuation of
distributions.

*

*
*
*
*
(c) * * *
(2) * * *
(ii) Written consent of the participant
to the distribution must not be made
before the participant receives the
notice of his or her rights specified in
this paragraph (c)(2) and must not be
made more than 90 days before the date
the distribution commences.
(iii) A plan must provide participants
with notice of their rights specified in
this paragraph (c)(2) no less than 30
days and no more than 90 days before
the date the distribution commences.
However, if the participant, after having
received this notice, affirmatively elects
a distribution, a plan will not fail to
satisfy the consent requirement of
section 411(a)(11) merely because the
distribution commences less than 30
days after the notice was provided to the
participant, provided that the following
requirement is met. The plan
administrator must provide information
to the participant clearly indicating that
(in accordance with the first sentence of
this paragraph (c)(2)(iii)) the participant
has a right to at least 30 days to consider
whether to consent to the distribution.
(iv) For purposes of satisfying the
requirements of this paragraph (c)(2),
the plan administrator may substitute
the annuity starting date, within the
meaning of § 1.401(a)–20, Q&A–10, for
the date the distribution commences.
(v) See § 1.401(a)–20, Q&A–24 for a
special rule applicable to consents to
plan loans.
*
*
*
*
*
(8) Delegation to Commissioner. The
Commissioner, in revenue rulings,
notices, and other guidance published
in the Internal Revenue Bulletin, may
modify, or provide additional guidance
with respect to, the notice and consent

70011

requirements of this section. See
§ 601.601(d)(2)(ii)(b) of this chapter.
*
*
*
*
*
§ 1.411(a)–11T

[Removed]

Par. 3. Section 1.411(a)–11T is
removed.
Par. 4. Section 1.417(e)–1 is amended
as follows:
1. Paragraph (b)(3) is revised.
2. Paragraph (b)(4) is added.
The revision and addition read as
follows:
§ 1.417(e)–1 Restrictions and valuations of
distributions from plans subject to sections
401(a)(11) and 417.

*

*
*
*
*
(b) * * *
(3) Time of consent. (i) Written
consent of the participant and the
participant’s spouse to the distribution
must be made not more than 90 days
before the annuity starting date.
(ii) A plan must provide participants
with the written explanation of the
QJSA required by section 417(a)(3) no
less than 30 days and no more than 90
days before the annuity starting date
(except as otherwise provided by
section 417(a)(7) for plan years
beginning after December 31, 1996).
However, if the participant, after having
received the written explanation of the
QJSA, affirmatively elects a form of
distribution and the spouse consents to
that form of distribution (if necessary),
a plan will not fail to satisfy the
requirements of section 417(a) merely
because the annuity starting date is less
than 30 days after the written
explanation was provided to the
participant, provided that the following
requirements are met:
(A) The plan administrator provides
information to the participant clearly
indicating that (in accordance with the
first sentence of this paragraph (b)(3)(ii))
the participant has a right to at least 30
days to consider whether to waive the
QJSA and consent to a form of
distribution other than a QJSA.
(B) The participant is permitted to
revoke an affirmative distribution
election at least until the annuity
starting date, or, if later, at any time
prior to the expiration of the 7-day
period that begins the day after the
explanation of the QJSA is provided to
the participant.
(C) The annuity starting date is after
the date that the explanation of the
QJSA is provided to the participant
(except as otherwise provided by
section 417(a)(7) for plan years
beginning after December 31, 1996).
However, the plan may permit the
annuity starting date to be before the
date that any affirmative distribution

70012

Federal Register / Vol. 63, No. 243 / Friday, December 18, 1998 / Rules and Regulations

election is made by the participant and
before the date that the distribution is
permitted to commence under
paragraph (b)(3)(ii)(D) of this section.
(D) Distribution in accordance with
the affirmative election does not
commence before the expiration of the
7-day period that begins the day after
the explanation of the QJSA is provided
to the participant.
(iii) The following example illustrates
the provisions of this paragraph (b)(3):
Example. Employee E, a married
participant in a defined benefit plan who has
terminated employment, is provided with the
explanation of the QJSA on November 28.
Employee E elects (with spousal consent)
on December 2 to waive the QJSA and
receive an immediate distribution in the form
of a single life annuity. The plan may permit
Employee E to receive payments with an
annuity starting date of December 1,
provided that the first payment is made no
earlier than December 6 and the participant
does not revoke the election before that date.
The plan can make the remaining monthly
payments on the first day of each month
thereafter in accordance with its regular
payment schedule.

(iv) The additional rules of this
paragraph (b)(3) concerning the notice
and consent requirements of section 417
apply to distributions on or after
September 22, 1995. For distributions
before September 22, 1995, the
additional rules concerning the notice
and consent requirements of section 417
in § 1.417(e)–1(b)(3) in effect prior to
September 22, 1995 (see § 1.417(e)–1
(b)(3) in 26 CFR Part 1 revised as of
April 1, 1995) apply.
(4) Delegation to Commissioner. The
Commissioner, in revenue rulings,
notices, and other guidance published
in the Internal Revenue Bulletin, may
modify, or provide additional guidance
with respect to, the notice and consent
requirements of this section. See
§ 601.601(d)(2)(ii)(b) of this chapter.
*
*
*
*
*
§ 1.417(e)–1T

[Amended]

Par. 5. In § 1.417(e)–1T, paragraphs
(b)(3) and (4) are removed.
PART 602—OMB CONTROL NUMBERS
UNDER THE PAPERWORK
REDUCTION ACT
Par. 6. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.

Par. 7. In § 602.101, the table in
paragraph (c) is amended by removing
the entry for 1.411(a)–11T and adding
the following entries in numerical order
to read as follows:
§ 602.101

*

*

OMB Control numbers.

*

*

*

(c) * * *
Current
OMB control No.

CFR part or section where
identified and described

*
*
*
*
*
1.411(a)–11 ...............................
1545–1471
*
*
*
*
*
1.417(e)–1 .................................
1545–1471
*

*

*

*

*

John M. Dalrymple,
Acting Deputy Commissioner of Internal
Revenue.
Approved: December 2, 1998.
Donald C. Lubick,
Assistant Secretary of the Treasury.
[FR Doc. 98–32938 Filed 12–17–98; 8:45 am]
BILLING CODE 4830–01–U

DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
[TD 8789]
RIN 1545–AV32

Abatement of Interest
Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulation.
AGENCY:

This document contains final
regulations relating to the abatement of
interest attributable to unreasonable
errors or delays by an officer or
employee of the IRS in performing a
ministerial or managerial act. The final
regulations reflect changes to the law
made by the Tax Reform Act of 1986
and the Taxpayer Bill of Rights 2. The
final regulations affect both taxpayers
requesting abatement of certain interest
and IRS personnel responsible for
administering the abatement provisions.
DATES: Effective Date: These regulations
are effective December 18, 1998.
Applicability Date: For dates of
applicability, see § 301.6404–2(d).
FOR FURTHER INFORMATION CONTACT:
Michael L. Gompertz, (202) 622–4910
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
SUMMARY:

Background
This document contains amendments
to the Procedure and Administration
Regulations (26 CFR Part 301) relating to
the abatement of interest attributable to
unreasonable errors or delays by an
officer or employee of the IRS under
section 6404(e)(1) of the Internal

Revenue Code. Section 6404(e)(1) was
enacted by section 1563(a) of the Tax
Reform Act of 1986 (1986 Act) (Public
Law 99–514 (100 Stat. 2762) (1986)) and
amended by section 301 of the Taxpayer
Bill of Rights 2 (TBOR2) (Public Law
104–168 (110 Stat. 1452) (1996)).
Section 6404(e)(1) applies only to
interest on taxes of a type for which a
notice of deficiency is required by
section 6212, that is, income tax, estate
tax, gift tax, generation-skipping transfer
tax, and certain excise taxes. Requests
for abatement of interest should be
made on Form 843, ‘‘Claim for Refund
and Request for Abatement.’’ For more
information, see Publication 556,
‘‘Examination of Returns, Appeal
Rights, and Claims for Refund.’’
As enacted by the 1986 Act, section
6404(e)(1) provided that the IRS may
abate interest attributable to any error or
delay by an officer or employee of the
IRS (acting in an official capacity) in
performing a ministerial act. The
legislative history accompanying the
Act provided:
The committee intends that the term
‘ministerial act’ be limited to
nondiscretionary acts where all of the
preliminary prerequisites, such as
conferencing and review by supervisors, have
taken place. Thus, a ministerial act is a
procedural action, not a decision in a
substantive area of tax law.

H.R. Rep. No. 426, 99th Cong., 1st
Sess. 845 (1985); S. Rep. No. 313, 99th
Cong., 2d Sess. 209 (1986).
Further, Congress did not intend that
the abatement of interest provision ‘‘be
used routinely to avoid payment of
interest.’’ H.R. Rep. No. 426, 99th Cong.,
1st Sess. 844 (1985); S. Rep. No. 313,
99th Cong., 2d Sess. 208 (1986). Rather,
Congress intended abatement of interest
to be used in instances ‘‘where failure
to abate interest would be widely
perceived as grossly unfair.’’ Id.
In TBOR2, Congress amended section
6404(e)(1) to permit the IRS to abate
interest attributable to any unreasonable
error or delay by an officer or employee
of the IRS (acting in an official capacity)
in performing a managerial act as well
as a ministerial act.
Pursuant to the legislative history
accompanying TBOR2, a managerial act
includes a loss of records or a personnel
management decision such as the
decision to approve a personnel
transfer, extended leave, or extended
training. See H.R. Rep. No. 506, 104th
Cong., 2d Sess. 27 (1996). The
legislative history of TBOR2
distinguished a managerial act from a
general administrative decision and
provided that interest would not be
abated for delays resulting from general
administrative decisions. For example,