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 IRS requesting that 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]
On July 19, 2013, ASPPA submitted a brief letter to the Internal Revenue Service, the Department of the Treasury, and the Department of Labor in support of the statements and requests for guidance made by the American Benefits Council in its July 17, 2013 comment letter regarding the effects the Windsor (DOMA) case will have on retirement plans subject to the regulatory jurisdiction of these agencies[Comment]
On July 8, 2013, ASPPA filed a comment letter to the Internal Revenue Service regarding the use of forfeitures to fund ADP Test Safe Harbor Contributions and certain other contributions. The comment letter supplements a prior comment letter to (1) provide additional support for its position that forfeitures can be used to fund these contributions, and (2) request that, in the absence of a change in ruling policy, Internal Revenue Code §7805(b) be applied to provide transitional relief to plan sponsors who may have reasonably believed that, in the absence of an express prohibition, their plan’s language permitted forfeitures to be used in this way. [Comment]
On July 5, 2013, NAPA filed comments with the Securities and Exchange Commission recommending that the Commission not implement the Staff’s recommended “uniform fiduciary standard” for broker-dealers and investment advisers because such a standard would effectively result in a non-uniform “uniform fiduciary standard.” The Commission should instead require investment professionals to provide retail customers with clear and concise pre-engagement disclosures and that coordination with the ERISA disclosure requirements is critical. [Comment]
On June 18, 2013, ASPPA joined a number of other organizations in asking for an extension of the deadline to file lifetime income illustration comments [Comment]
On June 3, 2013, ASPPA and ACOPA submitted comments to PBGC on their proposed reportable events rules. [Comment]
On May 30, 2013, ACOPA submitted comments to the ASB on the second exposure draft of ASOP 4.[Comment]
On May 21, 2013, ASPPA submitted additional comments on the changes made with regard to in-plan Roth rollovers under the American Taxpayer Relief Act of 2012. ASPPA recommended that additional time be provided for remedial amendments, that transfers be limited to fully vested contribution sources, and that non-spouse beneficiaries and non-spouse alternate payees should be eligible for such treatment. [Comment]
On April 29, 2013, ASPPA and NTSAA submitted comments to the Internal Revenue Service (“IRS”) with suggested modifications to the recently announced 403(b) pre-approved plan program. In addition, the comment letter strongly recommended that the IRS permit cash balance plans to be included in the existing defined benefit pre-approved plan program. [Comment]
On April 22, 2013, ASPPA filed comments with the Department of Labor requesting a one-time transitional realignment period for providing the “second round” of participant notices required under ERISA Reg. §2550.404a-5. Additionally, ASPPA has requested clarification of the meaning of the regulatory term “annually thereafter” and suggested that it include the ability to give the annual updated participant notice anytime during a calendar year provided that notice is never given more than 18 months since the prior notice. [Comment]
On April 15, 2013, ASPPA GAC’s “Proposals for Enhancing Private Retirement Plans”, were included in a submission to the House Ways and Means Committee’s Pensions and Retirement Tax Reform Working Group. [Proposals]
On February 26, 2013, ASPPA submitted comments to the Internal Revenue Service requesting that it issue guidance confirming that the 5-year period of participation required for a tax-free distribution from a Roth account that is created by an internal Roth conversion begins on the first day of the calendar year that contains the date of the conversion, or if earlier, the date of the first designated Roth contribution to the plan. The American Taxpayer Relief Act of 2012 (H.R. 8, 112th Congress (2013)), expanded the availability of in-plan Roth conversions and increased the need for regulatory guidance. This letter is a supplement to ASPPA’s prior comment letter submitted on May 30, 2012. [Comment]
On January 28, 2013, ASPPA submitted comments to the Department of Labor and the Internal Revenue Service (IRS) requesting that they provide clarification and transitional relief with respect to the filing requirements for Form 5500, Annual Return/Report of Employee Benefit Plan, and Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, for plans that were reasonably believed to be multiple employer plans (MEPs) obligated to file as a single plan under Title I of ERISA and the Internal Revenue Code. [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 IRS requesting that 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]
On July 19, 2013, ASPPA submitted a brief letter to the Internal Revenue Service, the Department of the Treasury, and the Department of Labor in support of the statements and requests for guidance made by the American Benefits Council in its July 17, 2013 comment letter regarding the effects the Windsor (DOMA) case will have on retirement plans subject to the regulatory jurisdiction of these agencies[Comment]
On July 8, 2013, ASPPA filed a comment letter to the Internal Revenue Service regarding the use of forfeitures to fund ADP Test Safe Harbor Contributions and certain other contributions. The comment letter supplements a prior comment letter to (1) provide additional support for its position that forfeitures can be used to fund these contributions, and (2) request that, in the absence of a change in ruling policy, Internal Revenue Code §7805(b) be applied to provide transitional relief to plan sponsors who may have reasonably believed that, in the absence of an express prohibition, their plan’s language permitted forfeitures to be used in this way. [Comment]
On July 5, 2013, NAPA filed comments with the Securities and Exchange Commission recommending that the Commission not implement the Staff’s recommended “uniform fiduciary standard” for broker-dealers and investment advisers because such a standard would effectively result in a non-uniform “uniform fiduciary standard.” The Commission should instead require investment professionals to provide retail customers with clear and concise pre-engagement disclosures and that coordination with the ERISA disclosure requirements is critical. [Comment]
On June 18, 2013, ASPPA joined a number of other organizations in asking for an extension of the deadline to file lifetime income illustration comments [Comment]
On June 3, 2013, ASPPA and ACOPA submitted comments to PBGC on their proposed reportable events rules. [Comment]
On May 30, 2013, ACOPA submitted comments to the ASB on the second exposure draft of ASOP 4.[Comment]
On May 21, 2013, ASPPA submitted additional comments on the changes made with regard to in-plan Roth rollovers under the American Taxpayer Relief Act of 2012. ASPPA recommended that additional time be provided for remedial amendments, that transfers be limited to fully vested contribution sources, and that non-spouse beneficiaries and non-spouse alternate payees should be eligible for such treatment. [Comment]
On April 29, 2013, ASPPA and NTSAA submitted comments to the Internal Revenue Service (“IRS”) with suggested modifications to the recently announced 403(b) pre-approved plan program. In addition, the comment letter strongly recommended that the IRS permit cash balance plans to be included in the existing defined benefit pre-approved plan program. [Comment]
On April 22, 2013, ASPPA filed comments with the Department of Labor requesting a one-time transitional realignment period for providing the “second round” of participant notices required under ERISA Reg. §2550.404a-5. Additionally, ASPPA has requested clarification of the meaning of the regulatory term “annually thereafter” and suggested that it include the ability to give the annual updated participant notice anytime during a calendar year provided that notice is never given more than 18 months since the prior notice. [Comment]
On April 15, 2013, ASPPA GAC’s “Proposals for Enhancing Private Retirement Plans”, were included in a submission to the House Ways and Means Committee’s Pensions and Retirement Tax Reform Working Group. [Proposals]
On February 26, 2013, ASPPA submitted comments to the Internal Revenue Service requesting that it issue guidance confirming that the 5-year period of participation required for a tax-free distribution from a Roth account that is created by an internal Roth conversion begins on the first day of the calendar year that contains the date of the conversion, or if earlier, the date of the first designated Roth contribution to the plan. The American Taxpayer Relief Act of 2012 (H.R. 8, 112th Congress (2013)), expanded the availability of in-plan Roth conversions and increased the need for regulatory guidance. This letter is a supplement to ASPPA’s prior comment letter submitted on May 30, 2012. [Comment]
On January 28, 2013, ASPPA submitted comments to the Department of Labor and the Internal Revenue Service (IRS) requesting that they provide clarification and transitional relief with respect to the filing requirements for Form 5500, Annual Return/Report of Employee Benefit Plan, and Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, for plans that were reasonably believed to be multiple employer plans (MEPs) obligated to file as a single plan under Title I of ERISA and the Internal Revenue Code. [Comment]