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2004
Manage | s y s c o m : g m

December 22, 2004, Clarification Request to IRS on Short Service Employee Memorandum  [Comments]

December 10, 2004, Comments to the IRS and Treasury on Code Section 411(d)(6)  [Comments]

December 9, 2004, Comments to the IRS on the Draft Revenue Procedure for Pre-Approved Plans (Announcement 2004-33).  [Comments]

December 7, 2004 , Comments to the DOL on Proposed USERRA Regulations Addressing Problems With Contribution Deadlines and After-Tax Contributions Upon Termination of Employment [Comment]

November 10, 2004, ASPPA's Position Paper on Tax Exclusion for Nonqualified Lifetime Annuity Payouts Recommending Equal Treatment for Qualified Plans and Annuities.  [Comments]

On October 8, 2004, ASPPA filed comments with the SEC reiterating concerns that non-uniform redemption fee requirements imposed by different mutual fund families will result in significant confusion and additional costs for working Americans participating in 401(k) and similar defined contribution retirement plans.  [Comments]

On September 27, 2004, ASPPA filed comments with the Joint Board of Enrolled Actuaries (JBEA) in response to a review of its current regulations. In the comments, ASPPA encourages the JBEA to reconstitute its actuarial oversight and discipline, review its testing procedures to better ensure that only qualified actuaries are obtaining enrollment status, and recommends that modifications be made to the continuing education rules. [Comments}

On September 21, 2004, Bruce L. Ashton, ASPPA's President, offered testimony before the ERISA Advisory Council on disclosure of participant fees and expenses. [Comment]

On June 2, 2004, ASPPA submitted comments on EFAST to the DOL, IRS, PBGC and SSA. ASPPA commended the agencies for encouraging the use of electronic filing and supported their efforts to improve the process. However, ASPPA strongly objected to any proposal to accelerate filing deadlines, a system which would have filings rejected if all edit tests and data validation tests are not satisfied, and mandatory electronic filing. [Comment]

On May 17, 2004, ASPPA submitted its 412(i) comments to the IRS stating its support of the Service's goal of clarifying statutory law by promulgating rules that both preserve traditional fully-insured pension plans and eliminate the use of the fully-insured funding method to circumvent the benefit limitations under the law. [Comment]

On April 21, 2004, ASPPA filed extensive comments with the SEC on proposed rules imposing mandatory fees on redemptions of mutual fund investments. Unless modified, these rules will impose substantial administrative burdens and costs on 401(k) plans that will ultimately be borne by plan participants. [Comment]

On April 2, 2004, GAC filed comments to the DOL/EBSA proposed automatic rollovers regulations. ASPPA commented and made recommendations to the: amount of mandatory distributions eligible for safe harbor fiduciary treatment; required disclosures to participants and beneficiaries; permissible fees and expenses charged by IRAs; ability of companies and individuals in the securities and banking industry to provide these accounts in light of regulation relating to those industries; and proposed effective date for the changes.  [Comment]

On February 20, 2004, ASPPA offered comments regarding the mortality table used to determine various current liabilities in response to Notice 2003-62. Because of the questionable positive impact of the proposed changes in the mortality table rules for calculating current liability, as well as the outstanding concerns about other factors in the current liability calculation, ASPPA recommended that the proposed changes be delayed until final regulations regarding the current liability calculation are issued. [Comment]

On February 9, 2004, ASPPA submitted comments to the IRS regarding the EPCRS, as described in Rev. Proc. 2003-44. ASPPA recommended that TE/GE adopt a notice filing program for reporting and correcting failures in qualified plans; modify the SCP to extend the significant defect correction period from two to three years; expand its procedures to provide for voluntary correction of prohibited transactions and coordination with the VFC Program; and adopt procedures to address restorative payments. [Comment]

On February 6, 2004, ASPPA commented that the society continues to believe that existing technology solutions, as provided in the House-passed mutual fund reform bill (H.R. 2420), are the most sensible and practical approach to prevent late-day trading in retirement plans. However, if the SEC takes the clearinghouse approach instead, ASPPA makes several important suggestions to improve the fairness and workability of the clearinghouse alternative. [Comments]