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 May 8, 2012, ASPPA submitted comments to the Internal Revenue Service regarding the use of forfeitures to fund safe harbor contributions. ASPPA requested that the IRS consider issuing additional guidance clarifying that forfeitures can be used to fund ADP safe harbor contributions and that forfeitures may be used to fund ADP safe harbor contributions that are qualified automatic contribution arrangements. [Comment]

On May 8, 2012, ASPPA submitted comments to the Internal Revenue Service with respect to proposed regulations relating to longevity annuity contracts under defined contribution plans. ASPPA recommended an increase in the limits, greater flexibility and clarifications regarding premiums paid under a contract that fails or ceases to be a QLAC. [Comment]

On May 2, 2012, ASPPA and ACOPA submitted comments on proposed modifications to IRC 417(e) regulations regarding partial annuity distribution options. Issues addressed included implications for past practice, multiple annuity starting dates and notice and election rules for bifurcated benefits. [Comments]

On April 30, 2012, ASPPA, CIKR and NAPA filed a comment letter with the Department of Labor requesting clarification that asset allocation strategies and model portfolios are not designated investment alternatives as defined in Regulation §2550.408b-2(c) as well as Regulation §2550.404a-5. Additionally, the letter recommended that the Department of Labor establish a 1-year transitional period during which good faith efforts to interpret and apply the new regulations will be acceptable. [Comment]