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Page 4 of 11 of the exclusionary period, will only be allowed a variance exclusion for the time remaining. State agencies that implement after the exclusionary period end date do not get a variance exclusion. Early implementation rules at 7 CFR 275.12(d)(2)(vii)(A) do not apply since the enactment date for Section 10108 of OBBB was July 4, 2025. A 120-day variance exclusion is permitted for the misapplication of changes in Section 10108 of the OBBB to new and ongoing SNAP households until the exclusionary period end date on November 1, 2025. FNS stands ready to work with State agencies and provide additional technical assistance as OBBB implementation continues. State agencies with questions on Section 10108 of the OBBB should contact their respective FNS Regional Office. These questions will help inform additional guidance in future memos. Sincerely, SASHA GERSTEN- PAAL Digitally signed by SASHA GERSTEN-PAAL Date: 2025.10.31 10:20:47 -04'00' for Ronald Ward Acting Associate Administrator Supplemental Nutrition Assistance Program Food and Nutrition Service Attachments