Maybe if you post this in the International section you'd get answers. This part is for US OPs. Some, or even a lot of people using IOPs do not even come to this section. So you'd be better off posting this there.
At least I didn't when I was using IOPs. I'm glad I don't use them anymore. I was under the erroneous impression that it was legal to do. But, when I got that letter, I changed really fast to US Ops.