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CHAPEL HILL — The University of North Carolina will vacate all 16 of its football victories from the 2008 and 2009 seasons and reduce scholarships as part of self-imposed penalties in response to an NCAA investigation into the athletics program.

The school also put the football program on two years of probation as a result of the probe into improper benefits and academic misconduct.

In Monday’s response to the NCAA’s notice of allegations outlining nine violations, the school said it will cut three football scholarships for each of the next three academic years. The school also will pay a $50,000 fine to the NCAA, but UNC did not impose a postseason ban.

The response calls the punishments “difficult but necessary steps.”

The school still must appear before the NCAA Committee on Infractions on Oct. 28 and await word on whether the university will face additional penalties from the NCAA.

Athletics Director Dick Baddour said the school reviewed similar cases from the past decade before deciding on the penalties.

“I can say that we were very serious in our approach and we didn’t look at it from the standpoint of trying to figure out what (the NCAA) might do,” Baddour said in a teleconference. “It was only about what we felt like we should do.”

Fourteen Tar Heels football players missed at least one game and seven were forced to sit out all last season, with four of those either dismissed from the team or ruled permanently ineligible by the NCAA.

The scandal that has hovered over the school for 14 months included an assistant coach receiving personal loans from an NFL agent, players receiving jewelry and other gifts from people outside the program and a tutor providing improper help to players on term papers.

“We have acknowledged our violations and we’ve responded in the way you would expect of this university,” Chancellor Holden Thorp said in a statement. “We think that the sanctions we have proposed accept responsibility and, at the same time, give our current and future student-athletes and coaches every opportunity for success.”

Thorp fired head coach Butch Davis a week before the start of practice, citing the cumulative damage to the university’s reputation by the probe. The Tar Heels went 8-5 under Davis in 2008 and in 2009, losing each time in the Meineke Bowl in Charlotte. Davis has never been tied directly to or cited for any violations in the probe.

John Blake resigned as associate head coach after last year’s season-opening loss to LSU, during which the Tar Heels played without 13 players because of the NCAA probe. Blake’s close friendship with late NFL agent Gary Wichard became a focus of the investigation, including more than $31,000 in money transferred from Wichard to Blake that Blake’s attorneys have characterized as loans from one friend to another during a time of financial difficulty.

The NCAA’s notice of allegations, sent to the school in June, reported seven players received more than $27,000 in improper benefits in 2009 and 2010. It also alleged unethical conduct by former tutor Jennifer Wiley for refusing to cooperate with the investigation and providing about $3,500 worth of extra benefits in travel, parking expenses and free tutoring to players.

In its response, the school largely agreed with the NCAA’s findings except for allegations that it failed to adequately monitor the social media activity of players. School officials noted that NCAA rules “are silent with respect to any alleged institutional obligation” for daily monitoring of players’ activity on sites such as Facebook or Twitter.

The school also defended itself against the allegation that it should have better monitored the activity of former player Chris Hawkins, regarded as a prospective agent by the NCAA.

It said there were “no red flags” about Hawkins’ presence on campus in recent years for workouts with friend and former Tar Heel Willie Parker, adding that former athletes are often welcomed back to campus.

The response also said school officials didn’t know Hawkins, who was arrested in September 2010 on drug charges, had “impermissibly socialized” with current players away from campus. School officials have since told Hawkins to stay away.

The school said it has updated policies for former players to use campus football facilities, including creating an attendance log.

It also will add a staff member to its compliance department and is revising its academic support program to better oversee tutors, among other changes.