the Secretary of the Treasury and the Chairman of the Securities and Exchange Commission to address needed changes due to the creation of automatic IRAs. (f) Failure To provide qualifying automatic IRA arrangements Chapter 43 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 4980J. Requirements for covered employers to provide qualifying automatic IRA arrangements (a) General rule There is hereby imposed a tax on any failure by a covered employer (as defined in section 408B) to maintain a qualifying IRA arrangement (as defined in such section), and to meet the requirements under such arrangement, for a calendar year. (b) Amount (1) In general The amount of the tax imposed by subsection (a) on any failure for any calendar year shall be $100 with respect to each employee to whom such failure relates. (2) Tax not to apply where failure not discovered and reasonable diligence exercised No tax shall be imposed by subsection (a) on any failure during any period for which it is established to the satisfaction of the Secretary that the employer subject to liability for the tax did not know that the failure existed and exercised reasonable diligence to maintain a qualifying IRA arrangement and to meet the requirements under such arrangement. (3) Tax not to apply to failures corrected within 90 days No tax shall be imposed by subsection (a) on any failure if— (A) the employer subject to liability for the tax under subsection (a) exercised reasonable diligence to maintain a qualifying IRA arrangement and to meet the requirements under such arrangement, and (B) the employer provides a qualifying automatic IRA arrangement described in section 408B to each qualifying employee (as defined in section 408B) by the end of the 90-day period beginning on the first date the employer knew, or exercising reasonable diligence would have known, that such failure existed. (4) Waiver by Secretary In the case of a failure which is due to reasonable cause and not to willful neglect, the