On December 30, 2011, ASPPA and ACOPA submitted comments to the Pension Benefit Guaranty Corporation (PBGC) providing comments on the proposed rule relating to benefit determinations and plan valuations for statutory hybrid plans. ASPPA and ACOPA recommended that: (1) proposed regulations regarding §4022 be temporary, effective only for plan terminations occurring before the effective date of final Treasury regulations regarding market rate of return; and (2) PBGC should re-propose these rules in a manner that is consistent with the final Treasury regulations after the final market rate of return regulations are issued. [Comment]
On December 20, 2011, ASPPA submitted comments to the Internal Revenue Service requesting clarification of the notice requirement with respect to separated participants who are listed on IRS Form 8955-SSA and its predecessor, Schedule SSA to Form 5500. [Comment]
On December 19, 2011, ASPPA and CIKR submitted comments to the Department of Labor recommending an extension of the applicability dates of the Department of Labor regulations issued under ERISA sections 404(a) and 408(b)(2). [Comment]
On November 21, 2011, ASPPA sent a letter to the IRS requesting the elimination of the signature requirement when IRS Form 5558, Application for Extension of Time to File Certain Employee Plan Returns, is filed to extend the due date for filing Form 8955-SSA. ASPPA requested that the exception granted under Treasury Regulation 1.6081-11 for Form 5500 series reports be applied or expanded to include Form 8955-SSA. [Letter]
On November 10, 2011, ASPPA and the ASPPA College of Pension Actuaries sent a letter to IRS requesting that the deadline for amendments required to comply with IRC section 436 be extended to be concurrent with the recently extended deadline for certain hybrid plan amendments. [Letter]
On September 30, 2011, ASPPA submitted comments to the Department of Labor proposing modifications to its Voluntary Fiduciary Correction Program as it applies to the late deposits of elective deferrals. [Comment]
On September 26, 2011, the ASPPA College of Pension Actuaries (ACOPA) joined five other organizations in requesting that PBGC expand relief for filing errors regarding election of the alternative premium funding target. [Letter]
On August 16, 2011, ASPPA, the National Institute of Pension Administrators (NIPA) and the American Institute of Retirement Education (AIRE) submitted comments to the Internal Revenue Service regarding the procedures and standards for approval of continuing education providers and programs under Circular 230. [Comment]
On July 25, 2011, ASPPA submitted comments to the Department of the Treasury regarding its Preliminary Plan for reducing regulatory burdens. ASPPA’s recommendations related to: (1) the initiative regarding lifetime income distributions; (2) relief for sponsors of safe harbor 401(k) plans who encounter financial difficulties; (3) mid-year changes to a safe harbor 401(k) plan; (4) a unified approach for electronic disclosures for retirement plans; (5) plan sponsor elections under the Pension Protection Act of 2006; (6) simplification of required employee communication items; and (7) that interim amendments only be required once every three years. [Comment]
On July 19, 2011, ACOPA submitted a letter to Treasury regarding the treatment of plan amendments under IRC section 412(d)(2). [Letter]
On July 15, 2011, ASPPA and NTSAA submitted comments to the Internal Revenue Service regarding the termination of a 403(b) plan which is funded, in whole or in part, by 403(b)(7) custodial accounts.[Comment]
On July 5, 2011, ASPPA submitted comments to the Department of Labor request extension of certain elements of good faith compliance provided in the DOL’s Frequently Asked Questions (FAQ) on Schedule C to the Form 5500. [Comment]
On July 1, 2011, ASPPA submitted comments to the Department of Labor regarding its Preliminary Plan for reducing regulatory burdens. ASPPA’s recommendation related to the use of electronic disclosure as the default option. [Comment]
On June 21, 2011, NAIRPA submitted comments to the Securities and Exchange Commission in response to its request for comments on existing private and public efforts to educate investors. [Comment]
On June 15, 2011, ASPPA and CIKR submitted comments to the Department of Labor regarding the applicability dates for the requirements for fee disclosure to plan fiduciaries and participants under ERISA sections 404(a) and 408(b)(2). [Comment]
On June 14, 2011, ASPPA submitted supplemental comments to the Department of Labor in response to its request for information regarding electronic disclosure by employee benefit plans to provide the Department with a White Paper by Professor Peter P. Swire and Kenesa Ahmad entitled, “Delivering ERISA Disclosure for Defined Contribution Plans: Why the Time has Come to Prefer Electronic Delivery.” ASPPA, the Investment Company Institute and other organizations had jointly supported the preparation of the White Paper. [Comment Letter] [White Paper]
On June 10, 2011, ASPPA submitted comments to the Internal Revenue Service in response to its request for comments regarding its 2011-2012 Guidance Priority List. [Comment]
On June 8, 2011, ASPPA submitted comments to the Internal Revenue Service to provide suggestions for improving the pre-approved plans and the determination letter program with respect to defined contribution plans. [Comment]
On June 6, 2011, ASPPA submitted comments to the Department of Labor in response to its request for information regarding electronic disclosure by employee benefit plans. [Comment]
On May 31, 2011, ASPPA submitted comments to the Internal Revenue Service requesting a revision of the due date for filing 2009 and 2010 Form 8955-SSA. [Comment]
On April 29, 2011, ASPPA submitted comments to the Department of Treasury in response to its request for recommendations on how it can improve its regulations. ASPPA’s recommendations relate to: (1) safe harbor 401(k) plans; (2) electronic communications; (3) plan sponsor elections under PPA; (4) participant communications; and (5) interim amendments. [Comment]
On April 20, 2011, ASPPA and ACOPA submitted comments to PBGC in response to its request for recommendations on how it can improve its regulations. ASPPA and ACOPA’s recommendations relate to: (1) reporting exemptions; (2) the premium filing deadline; (3) My PAA website functionality; and (4) PBGC’s customer service. [Comment]
On April 14, 2011, ASPPA and NTSAA submitted comments to the U.S. Securities and Exchange Commission regarding the registration of municipal advisors. [Comment]
On March 31, 2011, ASPPA submitted comments to the U.S. Department of Labor in response to its request for comments on how it can improve its regulations. ASPPA’s recommendations relate to: (1) the exclusion of 403(b) contracts prior to 2009; (2) electronic disclosure as the default option; and (3) a self-correction program for VFCP. [Comment]
On February 17, 2011, ASPPA and NTSAA submitted supplemental comments to the U.S. Department of Labor requesting additional transitional relief with respect to the Form 5500 audit requirements for 403(b) plans. [Comment]
On January 27, 2011, ASPPA, CIKR and NAIRPA submitted comments to the U.S. Department of Labor on the proposed regulation regarding the definition of the term “fiduciary”. [Comment]
On January 18, 2011, ASPPA and ACOPA submitted comments to EBSA on proposed rules regarding the Annual Funding Notice for Defined Benefit Plans. [Comment]
On January 14, 2011, ASPPA filed comments with Department of Labor with respect to its proposed amendments to the qualified default investment alternative (QDIA) and the participant-level disclosure regulations for target date funds. The comments applaud the Department for its efforts, request clarifications regarding the proposed regulation’s requirements, and provide recommendations of additional information to be given to assist participants. [Comment]
On January 12, 2011, ASPPA and ACOPA submitted comments to IRS and Treasury on proposed additional rules regarding hybrid retirement plans. [Comment]
On December 20, 2011, ASPPA submitted comments to the Internal Revenue Service requesting clarification of the notice requirement with respect to separated participants who are listed on IRS Form 8955-SSA and its predecessor, Schedule SSA to Form 5500. [Comment]
On December 19, 2011, ASPPA and CIKR submitted comments to the Department of Labor recommending an extension of the applicability dates of the Department of Labor regulations issued under ERISA sections 404(a) and 408(b)(2). [Comment]
On November 21, 2011, ASPPA sent a letter to the IRS requesting the elimination of the signature requirement when IRS Form 5558, Application for Extension of Time to File Certain Employee Plan Returns, is filed to extend the due date for filing Form 8955-SSA. ASPPA requested that the exception granted under Treasury Regulation 1.6081-11 for Form 5500 series reports be applied or expanded to include Form 8955-SSA. [Letter]
On November 10, 2011, ASPPA and the ASPPA College of Pension Actuaries sent a letter to IRS requesting that the deadline for amendments required to comply with IRC section 436 be extended to be concurrent with the recently extended deadline for certain hybrid plan amendments. [Letter]
On September 30, 2011, ASPPA submitted comments to the Department of Labor proposing modifications to its Voluntary Fiduciary Correction Program as it applies to the late deposits of elective deferrals. [Comment]
On September 26, 2011, the ASPPA College of Pension Actuaries (ACOPA) joined five other organizations in requesting that PBGC expand relief for filing errors regarding election of the alternative premium funding target. [Letter]
On August 16, 2011, ASPPA, the National Institute of Pension Administrators (NIPA) and the American Institute of Retirement Education (AIRE) submitted comments to the Internal Revenue Service regarding the procedures and standards for approval of continuing education providers and programs under Circular 230. [Comment]
On July 25, 2011, ASPPA submitted comments to the Department of the Treasury regarding its Preliminary Plan for reducing regulatory burdens. ASPPA’s recommendations related to: (1) the initiative regarding lifetime income distributions; (2) relief for sponsors of safe harbor 401(k) plans who encounter financial difficulties; (3) mid-year changes to a safe harbor 401(k) plan; (4) a unified approach for electronic disclosures for retirement plans; (5) plan sponsor elections under the Pension Protection Act of 2006; (6) simplification of required employee communication items; and (7) that interim amendments only be required once every three years. [Comment]
On July 19, 2011, ACOPA submitted a letter to Treasury regarding the treatment of plan amendments under IRC section 412(d)(2). [Letter]
On July 15, 2011, ASPPA and NTSAA submitted comments to the Internal Revenue Service regarding the termination of a 403(b) plan which is funded, in whole or in part, by 403(b)(7) custodial accounts.[Comment]
On July 5, 2011, ASPPA submitted comments to the Department of Labor request extension of certain elements of good faith compliance provided in the DOL’s Frequently Asked Questions (FAQ) on Schedule C to the Form 5500. [Comment]
On July 1, 2011, ASPPA submitted comments to the Department of Labor regarding its Preliminary Plan for reducing regulatory burdens. ASPPA’s recommendation related to the use of electronic disclosure as the default option. [Comment]
On June 21, 2011, NAIRPA submitted comments to the Securities and Exchange Commission in response to its request for comments on existing private and public efforts to educate investors. [Comment]
On June 15, 2011, ASPPA and CIKR submitted comments to the Department of Labor regarding the applicability dates for the requirements for fee disclosure to plan fiduciaries and participants under ERISA sections 404(a) and 408(b)(2). [Comment]
On June 14, 2011, ASPPA submitted supplemental comments to the Department of Labor in response to its request for information regarding electronic disclosure by employee benefit plans to provide the Department with a White Paper by Professor Peter P. Swire and Kenesa Ahmad entitled, “Delivering ERISA Disclosure for Defined Contribution Plans: Why the Time has Come to Prefer Electronic Delivery.” ASPPA, the Investment Company Institute and other organizations had jointly supported the preparation of the White Paper. [Comment Letter] [White Paper]
On June 10, 2011, ASPPA submitted comments to the Internal Revenue Service in response to its request for comments regarding its 2011-2012 Guidance Priority List. [Comment]
On June 8, 2011, ASPPA submitted comments to the Internal Revenue Service to provide suggestions for improving the pre-approved plans and the determination letter program with respect to defined contribution plans. [Comment]
On June 6, 2011, ASPPA submitted comments to the Department of Labor in response to its request for information regarding electronic disclosure by employee benefit plans. [Comment]
On May 31, 2011, ASPPA submitted comments to the Internal Revenue Service requesting a revision of the due date for filing 2009 and 2010 Form 8955-SSA. [Comment]
On April 29, 2011, ASPPA submitted comments to the Department of Treasury in response to its request for recommendations on how it can improve its regulations. ASPPA’s recommendations relate to: (1) safe harbor 401(k) plans; (2) electronic communications; (3) plan sponsor elections under PPA; (4) participant communications; and (5) interim amendments. [Comment]
On April 20, 2011, ASPPA and ACOPA submitted comments to PBGC in response to its request for recommendations on how it can improve its regulations. ASPPA and ACOPA’s recommendations relate to: (1) reporting exemptions; (2) the premium filing deadline; (3) My PAA website functionality; and (4) PBGC’s customer service. [Comment]
On April 14, 2011, ASPPA and NTSAA submitted comments to the U.S. Securities and Exchange Commission regarding the registration of municipal advisors. [Comment]
On March 31, 2011, ASPPA submitted comments to the U.S. Department of Labor in response to its request for comments on how it can improve its regulations. ASPPA’s recommendations relate to: (1) the exclusion of 403(b) contracts prior to 2009; (2) electronic disclosure as the default option; and (3) a self-correction program for VFCP. [Comment]
On February 17, 2011, ASPPA and NTSAA submitted supplemental comments to the U.S. Department of Labor requesting additional transitional relief with respect to the Form 5500 audit requirements for 403(b) plans. [Comment]
On January 27, 2011, ASPPA, CIKR and NAIRPA submitted comments to the U.S. Department of Labor on the proposed regulation regarding the definition of the term “fiduciary”. [Comment]
On January 18, 2011, ASPPA and ACOPA submitted comments to EBSA on proposed rules regarding the Annual Funding Notice for Defined Benefit Plans. [Comment]
On January 14, 2011, ASPPA filed comments with Department of Labor with respect to its proposed amendments to the qualified default investment alternative (QDIA) and the participant-level disclosure regulations for target date funds. The comments applaud the Department for its efforts, request clarifications regarding the proposed regulation’s requirements, and provide recommendations of additional information to be given to assist participants. [Comment]
On January 12, 2011, ASPPA and ACOPA submitted comments to IRS and Treasury on proposed additional rules regarding hybrid retirement plans. [Comment]