To view an archive of Comment Letters, click HERE.
Using comment letters and testimony, ASPPA Government Affairs responds to new legislation, proposed changes to existing regulations, and proposed new regulations. Any action that would change existing pension policy or affect the work of pension professionals is the object of ASPPA comments from Government Affairs. In its role of closely monitoring legislative and regulatory actions, ASPPA Government Affairs directs its comments and testimony to appropriate agencies, clearly reflecting the stance of ASPPA and its members.
Most Recent Comments
On January 8, 2014, ASPPA submitted recommendations to the IRS on enhancements for the Filing Information Returns Electronically (FIRE) system. [Comment]
On December 20, 2013, ASPPA submitted comments to the IRS on the operation and administration of the TE/GE Compliance Questionnaire Program. [Comment]
On December 3, 2013, ASPPA submitted comments to DOL, recommending simplified guidance on same-gender spouses in ERISA-covered employee benefit plans. [Comment]
On October 23, 2013, ASPPA responded to a request for comments from the IRS on proposed rules regarding electronic filings. [Comment]
On October 21, 2013, ACOPA responded to an IRS request for comments, recommending the continued publication of combined static mortality tables. [Comment]
On October 17, 2013, ASPPA submitted comments to the IRS requesting guidance on amendments that may be adopted during the year without endangering a plan's safe harbor status. [Comment]
On October 4, 2013, ASPPA submitted comments to the IRS on further guidance regarding the implementation of new rules about same-gender spouses. [Comment]
On September 30, 2013, ACOPA submitted comments to the ASB on the exposure draft of a proposed ASOP on Modeling. [Comment]
On September 23, 2013, ASPPA and ACOPA filed comments with the PBGC on their proposed amendment to the premium filing regulations. [Comment]
On August 23, 2013, ASPPA and NTSAA submitted comments to the IRS regarding the Listing of Required Modifications (LRMs) for pre-approved 403(b) plans. [Comment]
On August 19, 2013, ASPPA and ACOPA submitted comments to the IRS requesting that the IRS issue guidance regarding the deduction-limit calculation for single-employer defined-benefit plans under IRC Section 404(o). [Comment]
On August 7, 2013, ASPPA submitted comments to the Department of Labor (DOL) regarding Advanced Notice of Proposed Rulemaking RIN 1210-AB20, the so-called “lifetime income illustrations rule.” ASPPA’s letter included several recommendations to enhance the proposed rule in order to make its implementation more helpful to participants and more cost-effective for service providers.[Comment]
On July 30, 2013, ASPPA filed comments with the Internal Revenue Service on Revenue Procedure 2013- 12 and the revisions made to the Employee Plans Compliance Resolution System (EPCRS). ASPPA’s comments included a number of suggested modifications to improve the program.[Comment]
On July 29, 2013, ASPPA filed a comment letter with the Department of Labor (DOL) requesting modification of Schedule C of Form 5500 to improve consistency in reporting data, particularly by eliminating the distinction between indirect compensation that is “eligible” for simplified reporting and indirect compensation that is not “eligible.” The comments additionally recommend that the DOL update its instructions for reporting the termination of a plan’s accountant or actuary. Along with the letter, ASPPA provided DOL with a revised Schedule C proposal. [Comment]