UIPL_13-20_Change_3.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION Unemployment Insurance CORRESPONDENCE SYMBOL OUI DL DATE July 1 2021 RESCISSIONS None EXPIRATION DATE Continuing ADVISORY UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 13-20 Change 3 TO FROM SUBJECT STATE WORKFORCE AGENCIES SUZAN G. LEVINE Principal Assistance Deputy Secretary Families First Coronavirus Response Act Division D Emergency Unemployment Insurance Stabilization and Access Act of 2020 EUISAA Ending the Emergency Flexibilities Authorized under Section 4102 b 1.Purpose. The purpose of this Unemployment Insurance Program Letter UIPL is to advise states of the appropriate allowable period for states to exercise the emergency flexibilities authorized under Section 4102 b EUISAA to modify or suspend work search waiting week good cause or employer experience rating. 2.Action Requested. The Department of Labor s Department Employment and Training Administration ETA requests that State Workforce Administrators provide the information contained in this UIPL to appropriate program and other staff in the state s workforce system. 3.Summary and Background. a.Summary On March 10 2020I a nationwide public health emergency was declared due to the COVIaJ19 pandemic. Over the last 15 months the Unemployment Insurance UIF program has been a critical lifeline to millions of workers and to the economy during this pandemic. It has allowed 50 million unemployed workers to afford to buy food and pay utilities and rent and has injected more than 700 billion into the economy preventing an even greater economic crisis. EUISAA as part of the Families First Coronavirus Response Act Public Law Pub. L. 11SJ127 I was enacted on March 18 202M. Section 4102 b of EUISAA providedI among other thingsI authority for states to temporarily modify or suspend the following provisions on an emergency temporary basis as needed to respond to the spread of COVIaJ19 1F work search 2 waiting week 3 good cause and 4 employer experience rating. As discussed in this UIPL the statute only makes these flexibilities available for the period in which they are needed to respond to the spread of COVIaJ19. States are not permitted to use these flexibilities indefinitely or for purposes other than to respond to the spread of COVIDJ19. 2 The labor market is beginning to recover from the economic effects of COVID-19. In addition to providing unemployment benefits during spells of unemployment a core purpose of the UI program is getting workers back into suitable work. As we change the course of the pandemic and the country reopens the UI program and all who administer it have a critical role to play in shepherding that transition and helping workers find safe good-paying work. This UIPL discusses how states must consider the extent to which the emergency flexibilities authorized by Section 4102 b EUISAA with respect to work search waiting week good cause and employer experience rating remain necessary to respond to the spread of COVID-19. Because conditions related to COVID-19 vary widely from state to state and even within states this determination must be done by each state rather than as a nationwide determination. Additionally this UIPL discusses the current emergency state staffing flexibility and the requirement that an individual be able to work and available for work under permanent federal unemployment compensation UC law. b. Background Enactment of the Families First Coronavirus Response Act made emergency supplemental appropriations in response to the spread of COVID-19 and included EUISAA set out at Division D of the law. In addition to the emergency flexibilities authorized under Section 4102 b EUISAA provided 1 emergency administrative grants to states for administration of the UI program 2 a short-term waiver of Title XII 42 U.S.C. 1321 et al. interest payments due and interest accrual on title XII advances to states through December 31 2020 and 3 full federal funding under certain circumstances of Extended Benefits EB . See UIPL No. 13-20 published on March 22 2020 and 13-20 Change 1 published on May 4 2020. The Department published UIPL No. 13-20 Change 2 on June 3 2021 requesting that states provide information using the Form MA 8-7 by August 2 2021 pertaining to their compliance with the conditions of receiving the emergency administrative grants under EUISAA. On March 27 2020 the Coronavirus Aid Relief and Economic Security CARES Act Pub. L. 116-136 was enacted which included among other things the creation of three new temporary federal unemployment programs that states may administer through agreements with the Secretary of Labor Secretary Pandemic Unemployment Assistance PUA Federal Pandemic Unemployment Compensation FPUC and Pandemic Emergency Unemployment Compensation PEUC . The CARES Act also amended Section 4102 b EUISAA by providing states with emergency flexibility for the merit staffing requirement as needed in response to the spread of COVID-19 through December 31 2020. See UIPL No. 14-20 published on April 2 2020 and UIPL No. 14-20 Change 1 published on August 12 2020. On December 27 2020 the Continued Assistance for Unemployed Workers Act of 2020 Continued Assistance Act set forth in Division N Title II Subtitle A of the Consolidated Appropriations Act 2021 Pub. L. 116-260 was enacted. The Continued Assistance Act extended through March 14 2021 the short-term waiver of interest payments due and interest accrual on Title XII advances to states full federal funding 3 under certain circumstances of EB and the emergency flexibility for the merit staffing requirement. The Continued Assistance Act also created a new Mixed Earners Unemployment Compensation MEUC program that states may administer through agreements with the Secretary and extended authority for the PUA FPUC and PEUC programs through March 14 2021. See UIPL No. 09-21 published on December 30 2020. On March 11 2021 the American Rescue Plan Act of 2021 ARPA Pub. L. 117-2 was enacted. ARPA among other things further extended through September 6 2021 the short-term waiver of interest payments due and interest accrual on Title XII advances to states and full federal funding under certain circumstances of EB as well as the authority for states to administer the MEUC PUA FPUC and PEUC programs through agreements with the Secretary. Section 9015 ARPA provided authority for states to exercise emergency flexibility for the merit staffing requirement through September 6 2021. See UIPL No. 14-21 published on March 15 2021. 4. Guidance Regarding Emergency Flexibilities. Section 4102 b EUISAA provided authority for states to temporarily modify or suspend the following provisions on an emergency temporary basis as needed to respond to the spread of COVID-19 1 work search 2 waiting week 3 good cause and 4 employer experience rating. With respect to these four emergency flexibilities states may temporarily disregard the application of Section 303 of the Social Security Act SSA 42 U.S.C. 503 and Section 3304 of the Federal Unemployment Tax Act FUTA 26 U.S.C. 3304 . As state and local economies reopen states must consider the extent to which the emergency flexibilities authorized by Section 4102 b EUISAA remain necessary to respond to the spread of COVID-19. Because conditions related to COVID-19 vary widely from state to state and even within states such consideration must be done by each state rather than as a nationwide determination. With that in mind the Department provides the following guidelines for states to use in assessing when to eliminate the flexibilities authorized by EUISAA. States may have a different rationale for modifying or suspending each of the four emergency flexibilities and the Department does not expect that all four emergency flexibilities will have the same end date. For example some flexibilities are for benefit eligibility and others are for employer contributions which may have a lagging timeline dependent on state law. However states must consider the extent to which the flexibilities in their entirety are necessary in response to the spread of COVID-19. Additionally in assessing the extent to which the flexibilities are needed to respond to the spread of COVID-19 it is possible states may eliminate one or more of the flexibilities but later find the need to reinstate them if a new wave of infections occurs. a. Work Search. The re-employment of claimants into suitable work is a central goal of the UI program and work search is a critical component in meeting that goal. Section 303 a 12 SSA requires that an individual be actively seeking work as a condition of eligibility for any week. Section 4102 b EUISAA provided states with the ability to 4 temporarily modify or suspend the work search requirements on an emergency temporary basis as needed to respond to the spread of COVID-19. See Section 5.A. of UIPL No. 13-20. i. Evaluating a state s need for the ongoing modification or suspension of work search requirements. While EUISAA does not provide a specific date when such flexibilities must end it does limit the availability of such flexibilities they are available only for so long as they are needed to respond to the spread of COVID-19. It does not permit the use of these flexibilities indefinitely or for purposes other than in response to the spread of COVID-19. To comply with EUISAA s plain language state laws must 1 include or be tied to a declaration that the law being passed inclusive of Executive Orders issued and regulations promulgated is to address the COVID-19 pandemic and 2 be time-limited and operable only for the time needed to address the pandemic. In deciding to re-impose the work search requirement a state may consider health and safety conditions in the local area the unemployment rate at the state level the number of job openings in the state compared to the number of unemployed individuals the state s stage of reopening and the Governor s declaration of an emergency. These criteria may well overlap and none is dispositive on its own. A state may also limit its temporary modification of the work search requirement to specific circumstances as appropriate to address the spread of COVID-19 while re-imposing the state s permanent work search requirements for all other individuals. For example a state may determine that individuals who are providing care for a family member who has been diagnosed with COVID-19 do not need to seek work. As the economy has begun to reopen at least 40 states that temporarily modified or suspended work search requirements in response to the spread of COVID-19 have since re-imposed these requirements indicating their assessment that such flexibility is no longer needed in response to the spread of COVID-19 for their states. Several states that have not rescinded their modification or suspension of the work search requirement have indefinite or undefined dates on when such a modification or suspension will be rescinded. An indefinite pause on work search requirements that is not connected to responding to the spread of COVID-19 is inconsistent with EUISAA. States are reminded that waivers must be rescinded once they are no longer needed to respond to the spread of COVID-19. 5 Individuals Collecting PEUC. For individuals collecting PEUC a state must at a minimum provide flexibility in meeting work search requirements in cases of individuals unable to search for work because of COVID-19 including because of illness quarantine or movement restrictions. See Section 2107 a 7 B of the CARES Act. This is only statutorily required for recipients of PEUC states need not apply such flexibility for recipients of other unemployment programs. ii. Providing for meaningful work search activities. Because Section 303 a 12 of the SSA does not specifically define actively seeking work states have some discretion to establish a reasonable definition. As stated in Section 4.a. of UIPL No. 05-13 States will exercise their discretion consistent with the strong expectation that unemployment compensation beneficiaries will be engaged in concerted and effective efforts calculated to find a suitable job in the shortest period of time that is practicable. Many states work search requirements rely solely on employer contacts or applications which while important do not fully reflect how hiring occurs in the modern labor market particularly as we continue to recover from the pandemic. The range of work search activities available to individuals should as a best practice include activities that support finding suitable employment. States may continue to allow an individual who is job-attached e.g. with a definite recall date to his or her employer to satisfy the requirement to seek work by taking reasonable steps to preserve their ability to return to that job. States are encouraged to have a fully integrated workforce system that focuses its collective efforts on assisting claimants getting back to work as quickly as possible in suitable jobs. One tool in achieving this aim is requiring work search activities that embrace a wide array of activities that support reemployment in today s labor market and include receiving services both remotely and in-person through the vast network of American Job Centers. The following tools are available for states in establishing meaningful work search requirements Training and Employment Notice TEN 17-19 published on February 10 2020 for model legislative language and a framework for updated work search requirements TEN 18-16 published on November 21 2016 for information about the My Reemployment Plan tool that can aid individuals who need more support in planning their work search and reemployment strategies. The electronic My Reemployment Plan is available for states to download and customize through the National Association of State Workforce Agencies NASWA Information Technology Support Center ITSC at http www.itsc.org Materials on the Reemployment Connections landing page on WorkforceGPS at https rc.workforcegps.org and 6 A listing of national internet -base d tools on the WorkforceGPS page at https www.workforcegps.org resources 2020 01 16 13 21 service - delivery -virtual -tools . b. Waiting W eek . As describe d in Section 4.e. of UIPL No. 10 -20 in most states an individual who is otherwise eligible for benefits must first serve a waiting period. This is not federally required although it is a longstanding practice in the UI program that may give states time to assess eligibility and deter fraud. Further existing federal EB law requires states to have a non -compensable waiting week in order for the state to receive federal cost sharing of the first week of EB. Section 4102 b EUISAA permits states that have a waiting week in their laws to waive the waiting week as necessary to respond to the spread of COVID -19. See Section 5.B. of UIPL No. 13 -20. Section 2105 of the CARES Act as amended provides 100 percent federal funding under the agreement to sta tes that waive the waiting week in state law. The last week of unemployment for which federal reimbursement of the first compensable week is available for states without a waiting week is week ending September 4 2021 September 5 2021 in states where th e week of unemployment ends on a Sunday . See Section 4.c.iv. of UIPL No. 14 -21. Additionally Section 9014 ARPA provides full federal reimbursement for the first week of EB in states without a waiting week through September 6 2021. The last week o f unemployment for which federal reimbursement is available for the first week of EB is week ending September 11 2021 September 5 2021 in states where the week of unemployment ends on a Sunday . See Section 4.a.ii. of UIPL No. 14 -21. There is not a fe deral requirement for states to have a waiting week and states may choose to suspend the waiting week provision under state law indefinitely beyond that which is needed to respond to the spread of COVID -19 . In doing so states should be aware of the impl ications on federal cost sharing under the EB program. c. Good Cause . As described in Section 4.C. of UIPL No. 13 -20 state laws provide for instances where good cause is considered in making a determination of eligibility. This often applies in job sepa rations where the individual voluntarily quits as well as where individuals refus e suitable work or do not meet reporting requirements. Section 4102 b EUISAA permits states to modify their good cause provisions as necessary to respond to the spread of COVID -19. However states have discretion in how they define good cause under existing federal law. States may choose to continue with an expanded definition of good cause beyond that which is needed to respond to the spread of COVID -19. Good cause to refuse an offer of work under PUA . The Department approved additional COVID -19 related reasons for an individual to self -certify for PUA eligibility in UIPL No. 16 -20 Change 5 published on February 25 2021 . Among them is a provision on good cause to r efuse an offer of work as follows 7 The individual has been denied continued unemployment benefits because the individual refused to return to work or accept an offer of work at a worksite that in either instance is not in compliance with local state or national health and safety standards directly related to COVID -19. This includes but is not limited to those related to facial mask wearing physical distancing measures or the provision of personal protective equipment consistent with public heal th guidelines . Any amendment to a state s definition of good cause to refuse an offer of work may impact an individual s ability to self -certify to this COVID -19 related reason for purposes of PUA eligibility. For example if a state determines that an expanded definition of good cause is no longer necessary in response to the spread of COVID -19 and chooses to restrict the definition this may result in more individuals being disqualified for regular UI benefits and thus eligible for PUA if such work was refused for the specified COVID -19 related reason. d. Employer Experience Rating . Experience rating is the system states use to determine the state unemployment tax rate that each employer must pay. Under these experience rating laws states determi ne individual employer tax rates based upon the employer s history of employee unempl oyment as measured by payroll or other measurement of exposure to the insured risk charging benefits paid out to employees to the employer s account . See UIPL No. 29 -83. The state system must meet the federal requirements for employer experience rating laid out in Section 3303 FUTA to receive the additional credit under that section of FUTA. On its face Section 4102 b EUISAA permits states to modify their laws governing employer experience rating. Although Section 3303 FUTA is not enumerated in the emergency flexibility provision of Section 4102 b EUISAA the Department interprets the provisions of Section 3303 FUTA that provides the requirements for emp loyer experience rating laws to be included as part of the emergency flexibility provided under EUISAA. As discussed above t o comply with EUISAA s plain language state laws must 1 include or be tied to a declaration that the law being passed incl usive of Executive Orders issued and regulations promulgated is to address the COVID -19 pandemic and 2 be time -limited and operable only for the time needed to address the pandemic. Many states have exercised these emergency flexibilities by non -charg ing some or all benefit charges to an employer s experience rating account during certain time period s of the pandemic or for claims which are directly related to the economic effects of COVID -19. States have also exercised these emergency flexibilities by altering the experience rating formula to disregard the most recent year s when computing employer rates. Similar to the modification or suspension of the work search requirement discussed in Section 4.a.i. of this UIPL w hile EUISAA does not provide a specific date when such emergency flexibilities must end it does require the modifications or suspensions to be temporary in nature and limit s the availability of such flexibilities only for so long as they 8 are needed to respond to the spread of COVID -19. It does not permit the use of these flexibilities indefinitely or for purposes other than in response to the spread of COVID - 19. In determining when to end the employer experience rating emergency flexibilities a state may consider health and safety conditions in the local area the unemployment rate at the state level the number of job openings in the state compared to the number of unemployed individuals the state s stage of reopening and the Governor s declaration of an emergency. These criter ia may well overlap and none is dispositive. The type of experience rating system in a state s UC law must also be taken into consideration when d etermining the appropriate period of time for the employer experience rating emergency flexibilities to be i n place. During the COVID -19 pandemic employers experienced payroll reduction s due to circumstance beyond their control. All state experience rating formula s take into consideration an employer s payroll when calculating employer contribution rates as a mean s of measuring the employer s exposure to insured risk . If a year is determined to be impact ed by the spread of COVID -19 based on the factor s in the above paragraph it is permissible with respect to the temporary flexibilities for that year s payrol l to not be used when calculating an employer s contribution rate. For example if when determining employer contribution rates for calendar year 2022 a state s experience rating formula uses the last three years of payroll and the state finds that calen dar years 2020 and 2021 were COVID -19 impacted it would be permissible for the state to instead use calendar years 2017 2018 and 2019 disregarding calendar years 2020 and 2021 . 5. Emergency State Staffing Flexibil ity . Section 303 a 1 SSA requires that states have s uch methods of administration including . . . methods relating to the establishment and maintenance of personnel standards on a merit basis . . . as are found by the Secretary to be reasonably calculated to insure full payment of u nemployment compensation when due. As set forth in Section 9015 ARPA the emergency flexibility with respect to the merit staffing requirement expires on September 6 2021. See Section 4.b. of UIPL No. 14 -21. For direction on the application of meri t staffing principles after September 6 2021 refer to UIPL No. 12 -01 Change 2 published on January 8 2021 regarding a state s ability to exercise flexibility in its staffing models under permanent federal law. 6. Requirement that an individual be able to work and available for work . Section 303 a 12 SSA requires that an individual be able to work and available for work . This requirement cannot be categorically waived or exempted. The same requirement applies to all unemployment benefit programs including the temporary federal programs provided under the CARES Act except as described for PUA below. States able and available requirements must meet the standards established in 20 C.F.R. part 604. However s tates have some discretion under perma nent federal law in establishing how an individual demonstrates that they meet the able and available requirements and in determining the types of work that are suitable for an individual. See Section 4.b. and 4.c. of UIPL No. 10 -20 published on March 12 2020. To be eligible for continued benefits an 9 individual must not limit their ability or availability in such a way that the individual has withdrawn from the labor market. See 20 C.F.R. 604. 4 a and 60 4.5 a 1 . Federal law provides for some author ized exceptions or substitutions to these requirements such as individuals in state -approved training Section 3304 a 8 FUTA or participation in the Short -Time Compensation program Section 3306 v 5 FUTA . Exceptions to the able and available requ irement are limited to those included in statute and regulations and there is no express statutory exception for individuals whose ability to work or availability for work is affected by the COVID -19 pandemic. Individuals Collecting PUA. The PUA program provides benefits to certain individuals who do not qualify for regular UI benefits such as individuals who are self -employed. An individual collecting PUA must be able to work and available for work within the meaning of state law except if they are u nable to work or unavailable for work pursuant to specific COVID -19 related reasons identified in the CARES Act and through Departmental guidance. See Section 2102 of the CARES Act and UIPL No. 16 -20 and its changes. For this reason an individual must certify every week under penalty of perjury that a qualifying COVID -19 related reason or reasons remains present. See Section s C.1. and C.7. of Attachment I to UIPL No. 16 -20 Change 4. 7. Inquiries . Please direct inquiries to covid -19 dol.gov with a copy to the appropriate Regional Office. 8. References . American Rescue Plan Act of 2021 ARPA including Title IX Subtitle A Crisis Support for Unemployed Workers Pub. L. 117 -2 Consolidated Appropriations Act 2 021 including Division N Title II Subtitle A the Continued Assistance for Unemployed Workers Act of 2020 Continued Assistance Act Pub. L. 116 -260 Coronavirus Aid Relief and Economic Security CARES Act including Title II Subtitle A Relief f or Workers Affected by Coronavirus Act Pub. L. 116 -136 Families First Coronavirus Response Act including Division D Emergency Unemployment Insurance Stabilization and Access Act of 2020 EUISAA Pub. L. 116 -127 Section s 3303 and 3304 Federal Unemp loyment Tax Act FUTA 26 U.S.C. 3303 3304 Section s 303 and 1201 Social Security Act SSA 42 U.S.C. 503 1321 20 C.F.R. Part 604 UIPL No. 14 -21 American Rescue Plan Act of 2021 ARPA Key Unemployment Insurance UI Provisions issued Mar ch 15 2021 https wdr.doleta.gov directives corr doc.cfm DOCN 5669 UIPL No. 09 -21 Continued Assistance for Unemployed Workers Act of 2020 Continued Assistance Act - Summary of Key Unemployment Insurance UI Provisions issued December 30 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 3831 10 UIPL No. 16 -20 Change 5 Expanded Eligibility Provi sions for the Pandemic Unemployment Assistance PUA Program issued February 25 2021 https wdr.doleta.gov directives corr doc.cfm DOCN 3202 UIPL No. 16 -20 Change 4 Continued Assistance to Unemployed Workers Act of 2020 -Pandemic Unemployment Assistance PUA Program Updated Operating Instructions and Reporting Changes issued January 8 2021 https wdr. doleta.gov directives corr doc.cfm DOCN 6973 UIPL No. 16 -20 Change 2 Coronavirus Aid Relief and Economic Security CARES Act of 2020 Pandemic Unemployment Assistance PUA Additional Questions and Answers issued July 21 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 5479 UIPL No. 16 -20 Change 1 Coronavirus Aid Relief and Economic Security CARES Act of 2020 Pandemic Unemployment Assistance PUA Program Reporting Instructions and Questions and Answers issued April 27 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 5899 UIPL No. 16 -20 Coronavirus Aid Relief and Econ omic Security CARES Act of 2020 Pandemic Unemployment Assistance PUA Program Operating Financial and Reporting Instructions issued April 05 2020 https wdr.doleta.gov direc tives corr doc.cfm DOCN 4628 UIPL No. 14 -20 Change 1 Coronavirus Aid Relief and Economic Security CARES Act of 2020 Questions and Answers issued August 12 2020 https w dr.doleta.gov directives corr doc.cfm DOCN 3791 UIPL No. 14 -20 Coronavirus Aid Relief and Economic Security CARES Act of 2020 Summary of Key Unemployment Insurance UI Provisions and Guidance Regarding Temporary Emergency State Staffing Flexibi lity issued April 2 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 3390 UIPL No. 13 -20 Change 2 Families First Coronavirus Response Act Division D Emergency Unemplo yment Insurance Stabilization and Access Act of 2020 EUISAA Review of State Compliance for Receipt of Emergency Administrative Grants and Clarification on Benefit Offset Requirements issued June 3 2021 https wdr.doleta.gov directives corr doc.cfm docn 8645 UIPL No. 13 -20 Change 1 Families First Coronavirus Response Act Division D Emergency Unemployment Insurance Stabilization and Access Act of 2020 EUISAA Reporting In structions Modification to Emergency Administrative Grants Application Requirement and Questions and Answers issued May 4 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 5374 UIPL No. 13 -20 Families First Coronavirus Response Act Division D Emergency Unemployment Insurance Stabilization and Access Act of 2020 issued March 22 2020 https wdr.dol eta.gov directives corr doc.cfm DOCN 8634 UIPL No. 10 -20 Unemployment Compensation UC for Individuals Affected by the Coronavirus Disease 2019 COVID -19 issued March 12 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 8893 UIPL No. 05 -13 Work Search and Overpayment Offset Provisions Added to Permanent Federal Unemployment Compensation Law by Title II Subtitle A of the Middle Class Tax Relief and Job Creation Act o f 2012 issued January 10 2013 https wdr.doleta.gov directives corr doc.cfm DOCN 3698 11 UIPL No. 12 -01 Change 2 States Ability to Exercise Flexibility in Staffing Models for the Performance of Certain Unemployment Compensation UC Administrative Activities issued January 8 2021 https wdr.doleta.gov directives corr doc.cfm DOCN 8998 UIPL No. 29 -83 Ge neral Principles of Experience Rating Under Section 3303 a 1 FUTA issued June 23 1983 https oui.doleta.gov dmstree uipl uipl83 uipl 2983.htm 1 TEN No. 17 -19 Model Unemployme nt Insurance State Work Search Legislation issue February 10 2020 https wdr.doleta.gov directives corr doc.cfm DOCN 4227 and TEN No. 18 -16 Pathways to Reemployment Tools and R esources issued November 21 2016 https wdr.doleta.gov directives corr doc.cfm DOCN 6266 . 9. Attachment s . None. 1 We note that the link to this docume nt shows an expiration dat e of July 30 1985 . However per TEN No. 15 -20 issued January 14 2021 this remains an active UIPL.