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Comment Letters

Comment Letters Archive

2020

On October 1, 2020, the American Retirement Association wrote to the Department of Labor to comment on the proposed Registration Requirements for Pooled Plan Providers with the primary concern being that the proposal underestimates the time needed to comply with the registration requirements before January 1, 2021. [Letter]

On August 6, 2020, the American Retirement Association wrote to the Department of Labor to comment on the proposed class exemption for investment advice for workers and retirees.  In the letter, the American Retirement Association supports the application for an ERISA fiduciary standard for rollover advice, requests clarification of the application of the exemption for Pooled Employer Plans, and asks for a reexamination of the “regular basis” element of the five-part fiduciary test. [Letter]

On July 30, 2020, the American Retirement Association wrote to the Department of Labor to provide our views on their proposed rule concerning Financial Factors in Selecting Plan Investments.  Specifically, ARA does not believe DOL guidance should discourage ERISA fiduciaries from considering environmental, social, governance (ESG) factors as they evaluate plan investment options nor should these types of investments be prohibited from being used as a Qualified Default Investment Alternative (QDIA). [Letter]

On July 22, 2020, the American Retirement Association wrote to the Internal Revenue Service to provide input on the Retirement Benefit items to be included on the 2020-2021 Priority Guidance Plan.  [Letter]

On July 20, 2020, the American Retirement Association wrote to the Department of Labor to respond to the Request for Information regarding prohibited transactions involving Pooled Employer Plans under the SECURE Act. [Letter]

On June 24, 2020, the American Retirement Association wrote to the Department of Labor to respond to the Request for information regarding prohibited transactions involving Pooled Employer Plans under the SECURE Act. [letter]

On June 9, 2020, the American Retirement Association wrote to the Department of Labor to outline the relief needed from ERISA’s prohibited transaction rules for service providers to Pooled Employer Plans.  [letter]

On May 18, 2020, the American Retirement Association and Investment Company Institute wrote to the Department of Treasury regarding the in-kind distribution of custodial accounts upon termination of a 403(b) plan to request guidance that properly implements Section 110 of the SECURE Act.  [letter]

On May 11, 2020, the American Retirement Association wrote to the Internal Revenue Service to recommend improvements in the interim amendment process for pre-approved plan documents.  Specifically, the ARA requested that interim amendments for all pre-approved plans will not be required until the end of the second calendar year that begins after the issuance of the Required Amendments List with the updated qualification requirements. [letter]

On May 1, 2020, the American Retirement Association and 14 other organizations wrote to the Office of Management and Budget in support of the Department of Labor’s rule regarding Default Electronic Disclosure by Employee Pension Benefit Plans under the Employee Retirement Income Security Act (ERISA).  [letter]  

On March 30, 2020, the American Retirement Association requested that the Department of Labor extend certain ERISA notice and disclosure requirements in light of the COVID-19 pandemic.  ARA requested a general extension of 90 to 120 days, in accordance with the broad authority granted to the DOL under section 3607 of the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act. [letter]

On March 24, 2020, the American Retirement Association wrote to the Department of Treasury to follow up on the request for tax filing and other relief due to the impact of the COVID-19 pandemic and to highlight additional requests for relief.  [letter]

On March 16, 2020, the American Retirement Association wrote to the Departments of Labor and Treasury to request tax filing and other relief due to the impact of the COVID-19 pandemic, including extensions of Form 5500 deadlines, extensions of the defined benefit restatement deadline, and reasonable relief from participant notices. [letter]

On March 16, 2020, the American Retirement Association wrote to the Internal Revenue Service to ask for a one-year extension of the section 403(b) plan remedial amendment period and a reduced Voluntary Compliance Program (VCP) user fee for a 403(b) plan document failure. [letter]  

On February 27, 2020, the American Retirement Association wrote to the Internal Revenue Service to follow up on a request for an explanation of our testimony at the public hearing on the Notice of Proposed Rulemaking regarding updated life expectancy and distribution period tables used for purposes of determining required minimum distributions.  The letter further details the interaction between the proposed rule and the SECURE Act changes to the required minimum distribution rules. [letter]

On February 12, 2020, the American Retirement Association wrote to the Department of Treasury and the Internal Revenue Service to request guidance on certain issues related to the enactment of the Setting Every Community Up for Retirement Enhancement (SECURE) Act. [letter]

On February 12, 2020, the American Retirement Association wrote to the Department of Labor to request guidance on certain issues related to the enactment of the Setting Every Community Up for Retirement Enhancement (SECURE) Act. [letter]

On January 6, 2020, the American Retirement Association wrote to the Internal Revenue Service to comment on the Department of Treasury’s and Internal Revenue Service’s Notice of Proposed Rulemaking regarding updated life expectancy and distribution period tables used for purposes of determining required minimum distributions. In the letter the American Retirement Association recommends that IRS and Treasury first issue proposed regulations on the SECURE Act changes to the rules for required minimum distributions and that final regulations be published at least six (6) months prior to the beginning of the calendar year for which they are effective. [letter]