On November 25, 2009,  ASPPA file comments with the Advisory Committee on Tax Exempt and Governmental entities suggesting ways in which the determination letter program and interim amendment procedures could be improved. [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 August 25, 2009, ASPPA President Stephen Dobrow responded to a New York Times editorial proposing changes to 401(k) plans. [Letter]

On June 15, 2009 ASPPA submitted comments to the Department of Labor requesting greater clarity on the exemption from ERISA for certain 403(b) arrangements in light of the final IRS regulations pertaining to 403(b) plans. [Comment]

On June 15, 2009, ASPPA submitted comments to the Department of Labor proposing a self-correction component be added to the Voluntary Fiduciary Correction Program for the late deposit of employee contributions. [Comment]

On June 15, 2009, ASPPA submitted comments to the IRS in regard to guidance priorities for the fiscal year that begins July 1, 2009. [Comment]

On June 1, 2009, ASPPA submitted comments to the IRS in response to Announcement 2009-34 with recommendations on how to structure a prototype program for 403(b) plans [Comment]

On April 24, 2009, ASPPA, CIKR and NAIRPA submitted a Letter of Support for H.R. 1984 to House Education and Labor Committee Chairman George Miller (D-CA). [HR 1984 Support Letter]

On April 8, ASPPA COPA submitted comments to the Treasury and IRS requesting guidance on matters related to end of year valuations and certain issues pertaining to application of benefit restrictions under IRC §436. [Comments]

On March 24, 2009, the ASPPA College of Pension Actuaries submitted comments to PBGC asking for reconsideration of the reporting requirements for small plans that fail to make required quarterly contributions. [Comments]

On March 6, 2009, ASPPA and CIKR submitted comments to the DOL on legal and policy questions relating to the final investment advice regulation, recommending that the DOL withdraw the class exemption portion of the final regulation. [Comments]

On February 20, 2009, ASPPA submitted comments to the IRS and Treasury requesting relief for certain sponsors of 401(k) safe harbor plans who will be unable to make 3 percent nonelective contributions under IRC §401(k)(12) for the entire year due to economic conditions. [comments][Listen to the Employee Benefit Advisor podcast of Bob Kaplan.]

On February 18, 2009, ASPPA and CIKR submitted comments requesting that the DOL extend the effective and applicability date of the final investment regulation by 60 days given the lack of certainty over the ultimate status of the regulation’s final outcome. [Comments]

On January 26, 2009, ASPPA submitted comments to the IRS on §201 of the Worker, Retiree and Employer Recovery Act of 2008, which suspends Required Minimum Distributions (RMDs) in 2009. [Comments]

On January 16, 2009, ASPPA recommended changes to the IRS’ Employee Plan’s Compliance Unit (EPCU) Compliance Check Program for pre-approved retirement plan documents. [EPCU Comments]

On January 7, 2009, ASPPA submitted comments to the IRS on the Proposed Regulation regarding the Notice to Participants of Consequences of Failing to Defer Receipt of Qualified Retirement Plan Distributions. [Comments]