EXHIBIT 5.2
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
DISTRICT DIRECTOR
31 HOPKINS PLAZA
BALTIMORE, MD 21201-0000
Date: June 21, 1995
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<S> <C>
PNC BANK CORP. Employer Identification Number: 25-1435979
C/O MICHAEL E. LLOYD, ESQ. File Folder Number: 521022825
ECKERT SEAMANS CHERIN & MELIOT Person to Contact: THOMAS J. SCHUTZMAN
600 GRANT STREET 42ND FLOOR Contact Telephone Number: (412) 644-5707
PITTSBURGH, PA 15219 Plan Name: PNC BANK CORP INCENTIVE SAVINGS PLAN
Plan Number: 001
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Dear Applicant:
We have made a favorable determination on your plan, identified
above, based on the information supplied. Please keep this letter in your
permanent records.
Continued qualification of the plan under its present form will
depend on its effect in operation. (See section 1.401-1(b) (3) of the
Income Tax Regulations.) We will review the status of the plan in operation
periodically.
The enclosed document explains the significance of this favorable
determination letter, points out some features that may affect the
qualified status of your employee retirement plan, and provides information
on the reporting requirements for your plan. It also describes some events
that automatically nullify it. It is very important that you read the
publication.
This letter relates only to the status of your plan under the
Internal Revenue Code. It is not a determination regarding the effect of
other federal or local statutes.
This determination is subject to your adoption of the proposed
amendments submitted in your letter dated May 5, 1995. The proposed
amendments should be adopted on or before the date prescribed by the
regulations under Code section 401(b).
This determination is also subject to your adoption of the
proposed amendments submitted in your letter(s) dated May 16, 1995. These
proposed amendments should also be adopted on or before the date prescribed
by the regulations under Code Section 401(b).
This plan has been mandatorily disaggregated, permissively
aggregated, or restructured to satisfy the nondiscrimination requirements.
This plan satisfies the nondiscrimination in amount requirement of
section 1.401(a) (4)-1(b) (2) of the regulations on the basis of a
design-based safe harbor described in the regulations.
This letter is issued under Rev. Proc. 93-39 and considers the
amendments required by the Tax Reform Act of 1986 except as otherwise
specified in this letter.
This plan satisfies the nondiscriminatory current availability
requirements of section 1.401(a) (4)-4(b) of the regulations with respect
to those benefits, rights, and features that are currently available to all
employees in the plan's coverage group. For this purpose, the plan's
coverage group consists of those employees treated as currently benefiting
for purposes of demonstrating that the plan satisfies the minimum coverage
requirements of section 410(b) of the Code.
This letter may not be relied upon with respect to whether the
plan satisfies the qualification requirements as amended by the Uruguay
Round Agreements Act, Pub. L. 103-465.
We have sent a copy of this letter to your representative as
indicated in the power of attorney.
If you have questions concerning this matter, please contact the
person whose name and telephone number are shown above.
Sincerely yours,
/s/ Paul M. Harrington
District Director
Enclosures:
Publication 794
Reporting & Disclosure Guide
for Employee Benefit Plans
