Comment Letters
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.
Read Most Recent Comments:
On March 4, 2010, ASPPA filed comments with the IRS providing recommendations on the how the procedures for determination letters, plan remedial amendments and other matters covered by Revenue Procedure 2007-44 could be improved. The letter was filed in anticipation of the issuance of an updated revenue procedure in this area. [Comment]
On February 18, 2010, ASPPA filed comments with the IRS suggesting ways in which the Employee Plans Compliance Resolution System (“EPCRS”) could be improved. The letter was in response to a request for comments found in Revenue Procedure 2008-50. [Comment]
On February 12, 2010, ASPPA filed comments with the DOL requesting that a self correction component for the late deposit of employee contributions be added to the Voluntary Fiduciary Correction Program. [Comment]
On February 3, 2010, ASPPA and NTSAA filed comments with the DOL requesting clarification of the application of the exemption from ERISA coverage for certain 403(b) arrangements using an “open architecture investment platform. [Comment]
On February 2, 2010, ASPPA filed a petition with the DOL regarding a potential problem with the sharing of signing credentials under the new EFAST2 Form 5500 filing system. Also included in the filing was a supplemental letter with a proposed solution to the problem. [Comment]
On January 22, 2010, ASPPA and ACOPA submitted comments to PBGC on the proposed rule relating to reportable events and other notice requirements. [Comment]
On November 20, 2009, ACOPA submitted comments on JBEA proposed amendments to the regulations relating to performance of actuarial services under ERISA. [Comment]
On October 14, 2009, ASPPA and ACOPA submitted comments to Treasury and IRS regarding possible DB(k) issues in need of guidance. [Comment]
On August 25, 2009, ASPPA President Stephen Dobrow responded to a New York Times editorial proposing changes to 401(k) plans. [Letter]
On August 17, 2009, ASPPA submitted comments to the IRS with regard to proposed regulations that would permit sponsors of 401(k) plans to suspend or reduce safe harbor nonelective contributions during a plan year. The proposal responds to ASPPA’s comment letter filed on February 20, 2009 asking for relief. [Comment]