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ASPPA Comments
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 Current Comments:
On April 29, 2008, ASPPA submitted a comment letter to the DOL on their proposed amendment of the plan asset regulation relating to participant contributions. [Comments]
On April 25, 2008, ASPPA submitted a comment letter to the IRS and Treasury discussing current methods available to plan sponsors through EPCRS to retroactively correct certain document errors, and providing additional examples to assist plan sponsor and practitioners. [Comments]
On April 15, 2008, ASPPA and CIKR submitted a Letter of Support to H.R. 3185, as amended, to House Education and Labor Chairman George Miller (D-CA). [H.R. 3185 Support Letter][News Release]
On April 2, 2008, ASPPA submitted comments to Treasury and the IRS on their proposed regulations on the diversification requirements for qualified defined contribution plans holding publicly traded employer securities. [Comments]
On March 31, 2008, ASPPA & CIKR testified before a DOL ERISA 408(b)(2) fee disclosure public hearing, addressing issues raised in the joint February 11, 2008 comment letter. [Oral Testimony]
On March 31, 2008 – ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed funding regulations, and requested revised proposed regulations be issued on both IRC 430 and 436. [Comments]
On March 27, 2008, ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed regulations regarding hybrid defined benefit plans. [Comments]
On March 11, 2008, ASPPA, CIKR and the Small Business Council of America (SBCA) submitted comments in opposition to Connecticut 401(k) plan legislation. [CT Written Comments]
On February 11, 2008, ASPPA & CIKR submitted comments to the DOL on ERISA Section 408(b)(2) proposed regulations. [Comments]
On February 6, 2008, ASPPA submitted comments to the IRS and Treasury on the Automatic Contribution Arrangements proposed regulations. [Comments]
On January 28, 2008, Judy A. Miller, ASPPA Chief of Actuarial Issues and Director of Retirement Policy, testified before the IRS and Treasury on proposed benefit restriction regulations for underfunded pension plans. [Testimony Outline]
On January 18, 2008, ASPPA submitted comments to the IRS and Treasury requesting clarification on partial plan termination guidance. [Comments]
On January 18, 2008, ASPPA submitted comments and a proposal to the IRS and Treasury requesting consideration of EPCRS to correct scrivener’s errors on a limited basis. [Comments] [Examples]
On November 28, 2007 – ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed regulations regarding benefit restrictions for underfunded pension plans. [Comments]
On November 16, 2007 – ASPPA submitted comments to the IRS on mid-year modifications of the provisions of a safe harbor plan, pursuant to Announcement 2007-59. [Comments]
On November 1, 2007 – ASPPA filed comments with the House Ways and Means Committee on PPA Technical Corrections legislation (H.R. 3361). [Comments]
On October 30, 2007 – Tommy Thomasson testified on behalf of ASPPA and CIKR before the House Ways and Means Committee on the appropriateness of retirement plan fees. [Testimony] [Fiduciary Disclosure] [Participant Disclosure] [Press Release] [House W&M Committee Website]
On October 24, 2007 – ASPPA President Sal L. Tripodi testified before the House Committee on Small Business Subcommittee on Finance and Tax on ways to increase small business pension coverage. [Testimony] [House Small Business Committee]
On October 24, 2007 – Michael Kiley testified on behalf of ASPPA and CIKR before the Senate Special Committee on Aging on the need for 401(k) fee transparency. [Testimony] [Fiduciary Disclosure] [Participant Disclosure] [Senate Aging Committee]
On October 4, 2007 – Tommy Thomasson testified on behalf of ASPPA and CIKR before the House Education and Labor Committee on the proposed fee disclosure rules in H.R. 3185. [Testimony] [Fiduciary Disclosure] [Participant Disclosure]
On September 20, 2007 – Samuel T. Brkich testified on behalf of CIKR before the ERISA Advisory Council’s Working Group on Fiduciary Responsibilities Update and Revenue Sharing. [Testimony]
On September 18, 2007 – Adam Pozek testified on behalf of ASPPA, CIKR and Sentinel before the ERISA Advisory Council’s Working Group on Automated Benefit Statements. [Testimony]
On September 10, 2007 – ASPPA filed comments with the IRS and SSA regarding the transition from the Schedule SSA to the new Form SSA. [Comments]
On July 20, 2007 – ASPPA and CIKR filed comments and an exemplary fee disclosure menu to DOL’s RFI on participant fee and expense information. [Comments] [Exemplary Fee Disclosure]
On July 18, 2007 – ASPPA, ABC, ERIC and The Coalition to Preserve the Defined Benefit System submitted a joint letter to Treasury on the anti-backloading rules under Code §411.
On July 12, 2007 – ASPPA testified before the ERISA Advisory Council’s Working Group on Automated Benefit Statements.
On June 5, 2007 – ASPPA filed comments to the DOL recommending certain disclosure requirements with respect to forthcoming benefit statement guidance.
May 3, 2007 – ASPPA’s President-Elect Sal Tripodi testified before Congress on technical corrections to PPA. [Testimony] [Participant Disclosure Chart]
April 12, 2007 – ASPPA filed an updated 402(f) notice to the Treasury and the IRS reflecting legal changes made to the notice since 2002. This notice is only reflective of the law in effect at the time issued and not updated to reflect any new rules. [Cover Letter] [Notice]
March 16, 2007 – ASPPA filed comments on Notice2006-107, diversification requirements for qualified DC plans holding publicly traded employer securities.
March 12, 2007 – ASPPA submitted comments to the IRS on updating the EPCRS, proposing two modifications to the program.
March 5, 2007 – ASPPA Submits Comments for the Record on 401(k) Fee Disclosure
February 21, 2007 – ASPPA Comments on RFI on Investment Advice
February 15, 2007 – ASPPA, SBCA the U.S. Chamber and NFIB submitted a letter to DOL regarding its 45-day Requirement to Provide Benefit Statements
January 24, 2007 – ASPPA Submits Testimony on SIMPLE Cafeteria Plans [Testimony] [S. 723]
November 14, 2006 – ASPPA Comments on Default Investment Alternatives
September 26, 2006 – ASPPA comments on safe harbor notice requirements
September 19, 2006 – ASPPA commented on the proposed revisions to the Form 5500 Annual Return/Report
September 19, 2006 – ASPPA letter to the DOL on its VFC Program and online calculator
August 3, 2006 – ASPPA comments to the Senate Committee on Finance hearing, “Kick-Off for Tax Reform: Tackling the Tax Code”
August 3, 2006 – ASPPA summary of HR 4, Pension Protection Act of 2006
June 29, 2006 – ASPPA Comments to Senate Finance Subcommittee on Long-Term Growth and Debt Reduction
May 24, 2006 – ASPPA commented on the IRS’s 2006-2007 Guidance Priority List
May 10, 2006 – ASPPA urged pension reform conferees to enact a final bill
April 27, 2006 – ASPPA comments on Roth 402A
April 10, 2006 – On April 10, 2005, ASPPA commented to the SEC on Rule 22c-2.
March 14, 2006 – ASPPA commented to the DOL on IRS 403(b) proposed regulations
March 10, 2006 – ASPPA commented to the Senate Committee on Finance on HSAs impact on employer-provided health care coverage
March 1, 2006 – ASPPA Statement by Brian H. Graff
March 1, 2006 – ASPPA joins ACLI, AALU and NAIFA at the 2006 Saver Summit to release brochure on importance of lifetime financial protection. [PDF]
February 1, 2006 –ASPPA comments on IRC §415 proposed regulations on multiple annuity starting dates.
December 7, 2005 – ASPPA Asks for Vote on H.R. 2830 [Hastert letter] [Blunt letter]
November 30, 2005 – ASPPA submitted comments and a model form to the DOL on the disclosure of investment fee information to participants. [comments] [sample form]
November 10 – ASPPA filed comments on the IRS’s proposed IRC §411(d)(6) regulations
October 11, 2005 – ASPPA submitted supplement comments to IRC Section 415 proposed regulations to provide additional analysis on issues ASPPA raised in the prior two letters.
August 17, 2005 – ASPPA President testifies before the IRS on the proposed Section 415 regulations
August 11, 2005 – 2nd Comment letter to the IRS and Treasury on proposed Code Section 415 Regulations
August 9, 2005 – ASPPA requested that the IRS provide additional guidance on the valuation of life insurance contracts
July 25, 2005 – Comment letter on three major issues to the IRS and Treasury on proposed Code Section 415 Regulations
July 15, 2005 – ASPPA submitted comments to the IRS on its current draft of its LRM on cross-testing
June 30, 2005 – ASPPA testified before the Senate Finance committee certain tax reform proposals
June 16, 2005 - ASPPA submitted a letter of support to the Lifetime Pension Annutiy for You Act of 2005
June 6, 2005 - ASPPA Submitted Comments to the DOL on its revised Voluntary Fiduciary Correction Program (VFC Program)
June 2, 2005 - ASPPA submitted a letter of support for the Retirement Savings and Security Act of 2005
May 27, 2005 - ASPPA submitted comments to the IRS and Treasury on Roth 401(k) contributions
May 17, 2005 – ASPPA submitted its new report on the how tax reform could undermine long-term retirement savings to the President's Advisory Panel on Federal Tax Reform.
May 9, 2005 – ASPPA comments to DOL on orphan plans
May 9, 2005 – ASPPA submits third set of comments to SEC on redemption fees
May 6, 2005 – ASPPA comments to PBGC on e-filing
April 20, 2005 - ASPPA, SBCA, SBLC and ECFC Endorse S 723, the SIMPLE Cafeteria Plan Act of 2005
April 20, 2005 – Comments on proposed regulations on liability pursuant to ERISA Section 4062(e)
March 15, 2005 - Comments on proposed regulations for distributions from a pension plan under a phased retirement program
March 7, 2005 - ASPPA comments on temporary and proposed regulations to IRC §403(b)
March 1, 2005 -- ASPPA Submits Comments to Congressional Record on Defined Benefit Reform
February 14, 2005 – Comments to the DOL recommending full disclosure to plan fiduciaries of all costs payable out of plan assets [comments] [Fee Disclosure Form]
February 2, 2005 -- Comments on Distributions from a Pension Plan Under a Phased Retirement Program, definition of normal retirement age
January 20, 2005 – Supplemental comments to the IRS’s Section 412(i) proposed guidance
December 22, 2004 - Clarification Request to IRS on Short Service Employee Memorandum
December 22, 2004 - Comments to the IRS for the Staggered Remedial Amendment Period System
December
10, 2004 - Comments to the IRS and Treasury on Code Section 411(d)(6)
December 9, 2004 - Comments to the IRS on the Draft Revenue Procedure for Pre-Approved Plans (Announcement 2004-33)
December 7, 2004 - Comments to the DOL on Proposed USERRA Regulations Addressing Problems With Contribution Deadlines and After-Tax Contributions Upon Termination of Employment
October 8, 2004 – Comments to the SEC Reiterating Concerns With Non-Uniform Redemption Fee Requirements Imposed by Different Mutual Fund Families
September 27, 2004 – Comments on Regulations Governing Performance of Actuarial Services
September 21, 2004 - ASPPA's Testimony before the ERISA Advisory Council on Disclosure of Participant Fees and Expenses
May 17, 2004 – Comments on Problems with Proposed IRC Guidance on Value of Life Insurance Contracts Distributed from Qualified Retirement Plan
April 21, 2004 – Comments on Mandatory Redemption Fees for Redeemable Fund Securities in Letter to Securities and Exchange Commission
February 20, 2004 – ASPPA Recommends IRS Delay Proposed Changes on Mortality Tables Due to Questionable Positive Impact
February 9, 2004 – ASPPA Comments on Problems with IRS-Supervised Correction Under Employee Plans Compliance Resolution System. Plan Sponsors Cite High Cost, Time-Consuming Process
February 6, 2004 – Comment on Practical Approach to Prevent Late-Day Trading in Retirement Plans Under Proposed Amendments to Rules Governing Pricing of Mutual Fund Shares
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© ASPPA 1999-2006. All rights reserved. ASPPA is a non-profit professional society.The materials contained herein are intended for instruction only and are not a substitute for professional advice.