To satisfy IRS regulations, EMPOWER may need to substantiate select debit card transactions. When substantiation is required, EMPOWER will take the following steps:

1. EMPOWER will immediately email the Consumer a notice that they must provide an itemized receipt to substantiate the expense
   1. The Consumer may send receipt(s) to EMPOWER via fax, email, mail, or online.
2. EMPOWER will email a second notice to the Consumer after 30 days.
3. After an additional 30 days, EMPOWER will inactivate the Consumer’s debit card and send another notice to provide receipt(s). EMPOWER will reactivate the Debit Card when the expense is successfully substantiated.
4. After an additional 30 days, EMPOWER will send notice to the Consumer that the expense is not IRS-compliant along with instructions how to remit payment.