ASPPA Comments by Date

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ASPPA communicates to a variety of government agencies, primarily, and other organizations about retirement plan issues via comment letters, position papers and testimonies. These communications are categorized below by date the communication was sent.

2005

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 [comments]

October 31 – ASPPA submitted comments to the DOL on their proposed regulation addressing the electronic filing of annual reports (Form 5500). [comments]

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. [comments]

August 17, 2005 – ASPPA President testifies before the IRS on the proposed Section 415 regulations [testimony]

August 11, 2005 – 2nd Comment letter to the IRS and Treasury on proposed Code Section 415 Regulations [comments]

August 9, 2005 -- ASPPA requested that the IRS provide additional guidance on the valuation of life insurance contracts [request]

July 25, 2005 - Comment letter on three major issues to the IRS and Treasury on proposed Code Section 415 Regulations [comments]

July 15, 2005 -- ASPPA submitted comments to the IRS on its current draft of its LRM on cross-testing [comments]

June 30, 2005 -- ASPPA testified before the Senate Finance committee certain tax reform proposals [testimony]

June 16, 2005 - ASPPA submitted a letter of support to the Lifetime Pension Annutiy for You Act of 2005 [letter]

June 6, 2005 - ASPPA Submitted Comments to the DOL on its revised Voluntary Fiduciary Correction Program (VFC Program) [comments]

June 2, 2005 - ASPPA submitted a letter of support for the Retirement Savings and Security Act of 2005 [letter]

May 27, 2005 - ASPPA submitted comments to the IRS and Treasury on Roth 401(k) contributions [comments]

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 [comments]

May 9, 2005 – ASPPA submits third set of comments to SEC on redemption fees [comments]

May 6, 2005 – ASPPA comments to PBGC on e-filing [comments]

April 20, 2005 – Comments on proposed regulations on liability pursuant to ERISA Section 4062(e) [comments]

April 20, 2005 - ASPPA, SBCA, SBLC and ECFC Endorse S 723, the SIMPLE Cafeteria Plan Act of 2005 [comments]

March 15, 2005 - Comments on proposed regulations for distributions from a pension plan under a phased retirement program [comments]

March 7, 2005 - ASPPA comments on temporary and proposed regulations to IRC §403(b) [comments]

February 14, 2005 – Comments to the DOL recommending full disclosure to plan fiduciaries of all costs payable out of plan assets [comments]

February 2, 2005 -- Comments on Distributions from a Pension Plan Under a Phased Retirement Program, definition of normal retirement age [comments]

January 20, 2005 – Supplemental comments to the IRS’s Section 412(i) proposed guidance [comments]

2004

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

December 22, 2004 - Comments to the IRS for the Staggered Remedial Amendment Period System [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 [comments]

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. [more]

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

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. [comments]

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. [comments]

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. [comments]

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. [comments]

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 letter]

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 letter]

In its February 6, 2004 comments, ASPPA stated its belief that exisiting 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. [complete comments]

On February 6, 2004, ASPPA commented that the society continues to believe that exisiting 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. [complete comments]

2003

On December 11, 2003, ASPPA submitted comments to the IRS regarding the ability of a qualified retirement plan to incorporate by reference certain provisions of the Internal Revenue Code and the regulations thereunder. [comment letter]

On November 26, 2003, ASPPA requested that the IRS issue guidance indicating that it concurs with the DOL Field Assistance Bulletin 2003-03 and asked that the IRS clarify its position that the plan's payment of administration expenses for participants who are active employees, but not for terminated vested participants, does not violate §411(a)(11). The Bulletin triggered a debate among plan sponsors and their advisors over the ability of employers to distinguish between active and terminated plan participants with respect to the payment of certain plan expenses. [full letter]

In response to alleged illegal conduct, the Securities and Exchange Commission (SEC) is considering a blanket rule requiring that all trades be received by the mutual fund company by 4:00 p.m. EST in order to get the closing price for the same day. On November 6, 2003, ASPPA representatives met with both Paul Roye of the SEC and Ann Combs of the DOL to present ASPPA's comments on the new rule. It is ASPPA's position that this rule would have a dramatic impact on the administration of retirement plans. According to Brian H. Graff, Esq., "The rule would prevent a substantial majority of 401(k) participants from being able to trade on the same day and get the closing price of that day. By treating these 401(k) plan participants as second-class investors, the rule could seriously threaten their retirement security." [comment letter]

On October 31, 2003, ASPPA filed comments to IRS issued proposed 401(k) regulations. ASPPA's government affairs committee commented on ten specific issues which highlight their findings that the comprehensive proposals close the gap where no guidance previously existed and, in some instances, go a long way toward providing practical solutions to certain common operational situations, and that other proposals, however, appear to increase the likelihood of compliance failures; therefore, clarification and further guidance is required for these aspects of the regulations. [comment letter ]

On October 7, 2003, ASPPA submitted comments on the Disclosure of the Relative Values of Optional Forms of Benefit proposed regulations. Enabling participants to make informed decisions requires providing them with an "apples to apples" comparison between available payment forms along with other understandable and meaningful information. It is important that final regulations ensure the delivery of such data. [comment letter]

In August 2001, the Internal Revenue Service issued a 36-page white paper, “The Future of the Employee Plans Determination Letter Program: Some Possible Options” ("first White Paper"), describing options for changing its current approach to issuance of determination letters on the qualification status of retirement plans and requesting comments from the private sector. On September 20, 2002, ASPPA submitted detailed comments on the first White Paper. Based on these comments, as well as others, the IRS issued a second set of White Papers, “The Future of the Employee Plans Determination Letter Program: Evaluation of Public Comments and Additional Explanation of Staggered Remedial Amendment Period Option” (“second White Paper”). ASPPA submitted its second White Paper comments on September 2, 2003.

On August 28, 2003, ASPPA submitted comments on the final and temporary regulations under Code Section 401(a)(9). ASPPA raised concerns about provisions that would eliminate the use of the "account balance method" for calculating Required Minimum Distributions under defined benefit plans. ASPPA's position is that RMD should be equal to the amount that would be paid if the participant elected a distribution in the form of a life annuity and that Code Section 401(a)(9) is intended to provide for certain minimum distributions prior to actual retirement and that it is not intended to require participants to receive mandatory lifetime annuity distributions or prohibit the later election of an optional payment form upon actual retirement. [letter]

On August 6, 2003, ASPPA requested guidance from the Service, in accordance with USERRA, on the following issues: year to which the make-up employee deferrals relate; required timing of employer contributions, whether they are discretionary profit sharing, QNEC, or matching; and testing implications of a brief military leave. [letter]

On July 15, 2003, ASPPA submitted a statement for the record in response to the Bush Administration's proposals to change some of the rules for single-employer defined benefit plans. According to Brian H. Graff, Esq., ASPPA Executive Director, "ASPPA welcomes the Administration's willingness to replace the 30-year Treasury bond rate with an interest rate based on a corporate bond rate. However, ASPPA strongly believes that a significant change to the funding rules, such as the yield curve proposal, should only be considered in the context of a complete review and possible additional revisions of the overall funding rules." [full statement]

On May 20, 2003, ASPPA and Small Business Council of America sent a joint letter to Chairman Thomas (R-22nd Calif.), chair of the House Committee on Ways & Means; and Chairman Grassley (R-Iowa), chair of the Senate Finance Committee; impressing upon them the importance of addressing small business retirement plans if annuities are added to the dividend exclusion proposal. [Letter]

On May 15, 2003, ASPPA submitted comments to the DOL on the Proposed Rule relating to fiduciary responsibility in relation to automatic rollovers. ASPPA stated that it is critical to ASPPA members and their plan sponsor clients that the automatic rollover rules are clear and easy to administer. ASPPA is concerned that rules that are too complex, or that impose too much potential liability on plan fiduciaries, will place an unreasonable burden on plan sponsors, particularly small business plan sponsors. [Comment letter]

On April 30, 2003, GAC submitted comments to the IRS requesting that restorative payments guidance be expressly extended to defined benefit plans. In Rev. Rul. 2002-45 the Service formalized the restorative payment guidelines. Because the facts in Rev. Rul. 2002-45 concern payments to DC plans, plan sponsors would benefit from assurance that the guidance in Rev. Rul. 2002-45 applies to DB plans. [Comment Letter]

On Thursday, March 13, 2003, ASPPA's Government Affairs Committee filed comments regarding the IRS proposed regulations on Reductions of Accruals and Allocations Because of the Attainment of Any Age: Application of Nondiscrimination Cross-Testing Rules to Cash Balance Plans. The Committee stated that any legislative or regulatory policy must keep in mind the vital role defined benefit plans play in providing working Americans with a more secure retirement. Until now, a large and difficult impediment to the growth of account-based defined benefit plans has been the uncertainty over how age discrimination rules apply to them. By publishing proposed guidance, IRS and Treasury have taken an important first step towards removing this roadblock. [Comment Letter]

2002

On December 23, 2002, ASPPA commended the Service for issuing the much-needed and detailed Code Section 457 guidance. Although in 1982 the Service issued comprehensive Code Section 457 final regulations, those regulations did not address many of the practical and compliance issues encountered by employers who maintain 457 plans and by practitioners who work with such plans. Also, the significant statutory amendments made to Section 457 since 1982 have made updated and expanded Section 457 guidance essential. [Full comment letter]

In November, 2002, the North Carolina State Bar sent letters to two firms with ASPPA members asserting that many of the retirement plan services provided by the firms constitute the unauthorized practice of law. The firms implicated were a large financial institution as well as a smaller plan administration firm. Specifically, the letters request that the firms "refrain from any future unauthorized practice of law in North Carolina, including:

(1) advising, counseling, or recommending to any entity that a particular profit-sharing, deferred compensation, pension, or other retirement plan is appropriate to that entity's particular circumstances or that it should adopt and implement such a plan; or (2) preparing, drawing, drafting, amending, restating, or aiding in such processes of any documents necessary to implement such a plan."

The breadth of this restriction would practically necessitate the involvement of a lawyer whenever a business is considering the adoption of a retirement plan, no matter how straightforward the plan. In many cases, this would likely add thousands of dollars in unnecessary administrative costs potentially discouraging, in particular, the adoption of small business retirement plans. ASPPA members both residing in and outside the State of North Carolina and the firms they work for help thousands of businesses in North Carolina provide retirement benefits for their employees. The longstanding business practices of all of these members and their firms would be dramatically affected if the Committee's current position is upheld. Given the significance of these issues to ASPPA's membership and the retirement industry overall, we have filed an amicus Memorandum of Law setting forth our strongly held views that the Committee's current position should be withdrawn.

On October 21, 2002, ASPPA submitted comments to the IRS on the final and temporary regulations under Internal Revenue Code section 401(a)(9), issued on April 17, 2002. After careful review of the temporary rules for defined benefit plans and annuity contracts, ASPPA believes that there are a number of important issues that Treasury and the Service should reconsider before January 1, 2003, the current proposed effective date for the Regulations.

On November 20, 2002, ASPPA released a seven-page response to the Department of Labor (DOL) final regulations relating to notice of blackout periods required by the Sarbanes-Oxley Act. In its response, ASPPA recommended changes and/or clarification of the content and timing of blackout notices in order to assist employers in complying with the Sarbanes-Oxley Act. ASPPA also recommended that the DOL amend the definition of one-participant plans, clarify the definition of a blackout period by distinguishing between permanent and temporary changes in options, loans, or distributions, and add some exceptions to the blackout definition. [Access the full comment letter]

On September 23, 2002, ASPPA issued a 29 page response to the Internal Revenue Service White Paper entitled The Future of the Employee Plans Determination Letter Program Some Possible Options. In its response ASPPA stated that "[it] applauds the efforts of the Service to improve the efficiency of its determination letter program. ASPPA believes and hopes that these efforts will produce significant improvements." (Note: this file is in pdf format, and require Acrobat Reader® to open. Don't have it? Get the free plugin here!)

On September 20, 2002, ASPPA issued a 29 page response to the Internal Revenue Service White Paper entitled The Future of the Employee Plans Determination Letter Program Some Possible Options. In its response ASPPA stated that "[it] applauds the efforts of the Service to improve the efficiency of its determination letter program. ASPPA believes and hopes that these efforts will produce significant improvements." Read the letter. (Note: this file is in pdf format, and require Acrobat Reader® to open. Don't have it? Get the free plugin here!)

On June 24, 2002, GAC submitted a comment letter to the DOL regarding the disposition of account balances for missing participants in defined contribution plans. Read the letter.

On June 24, 2002, GAC submitted a comment letter to the DOL regarding the disposition of account balances for missing participants in defined contribution plans. Read the letter.

On June 24, 2002, GAC submitted a Suspension of Benefits comment letter to the IRS stating that ASPPA members appreciate the Service's efforts to quickly issue EGTRRA guidance. One area in particular, however, raises concerns for our membership, that is, the identification of a suspension of benefits conflict where the §415 limits restrict a current accrual due to the "plateau" of the dollar limit between age 62 and age 65 for plans with a normal retirement date prior to age 65. Read the letter.

On June 24, 2002, GAC submitted a comment letter to the IRS on the application of the regulations under Internal Revenue Code ("Code") Section 401(m) to 403(b) plans and other issues relating to matching contributions under 403(b) plans. Read the letter.

On February 7, 2002, ASPPA released a white paper addressing the issue of whether federal pension law should contain rules that restrict either the number or length of "lockdowns" of qualified pension plans. It includes a summary of our recent survey of plan administration firms on their typical experiences with lockdowns. Read the paper.

On January 30, 2002, GAC submitted comments on the proposed regulations under §414(v) regarding Catch-Up Contributions for Individuals Age 50 or Over [REG-142499-01] ASPPA stated that clarification and further guidance is required with regard to certain aspects of the proposed rules. [Learn more. (Note: this file is in pdf format, and requires Acrobat Reader® to open. Don't have it? Get the free plugin here!).

On January 2, 2002, in a comment letter, ASPPA commended the IRS on the issuance of Revenue Procedure 2001-17 (Rev. Proc.), which further updates and clarifies the guidance under the Employee Plans Compliance Resolution System (EPCRS). The letter addresses 19 issues. Read the letter.

On December 7, 2001, ASPPA provided comments to the IRS regarding the disposition of account balances for missing participants in defined contribution plans. ASPPA stated that it believes that guidance from the Service concerning the proper disposition of account balances for missing participants, particularly in the context of terminating defined contribution plans, is urgently needed. Learn more.

On November 20, 2001, ASPPA issued comments regarding the appropriateness of further transitional relief with respect to the deadline for using the newly revised 5300 Forms is appropriate. In light of the delayed release of the new forms, the cut-off date for using the old forms, as indicated in Announcement 2001-109, should be extended, at a minimum, an additional three months. [more]

On November 15, 2001, GAC sent a letter to the IRS to emphasize the importance of IRC Section 414(k) accounts in promoting pension portability and to request that the Service reconsider the guidance. Read the letter.

On October 1, 2001, ASPPA requested comments regarding the Form 5500 and Schedules. We appreciate the several improvements already made in the organization of the general instructions for the 2000 Form 5500 Series, including among other changes, better organization of the instructions related to direct filing entities (DFEs). Although, reporting on DFEs is still an area of some confusion. We also appreciate the reinstatement of the prior rule that allows filing for a short plan year on the currently available form. We have two ongoing concerns regarding the Form 5500 Series, including some questions and suggestions which we would like you to consider. Read the actual letter.

On August 13, 2001, ASPPA issued comments supplementing ASPPA's April 17, 2001, comments regarding the Proposed Regulations under section 401(a)(9) of the IRC. This new letter addresses: (1) the partially retroactive application of the final regulations; (2) the handling of TEFRA elections; and (3) the use of term certain annuities. Read the supplemental comments.

On August 8, 2001, ASPPA issued comments regarding the issuance of Revenue Procedure 2000-41, which updates the requirements to obtain approval of a change in funding method. We believe that the guidance represents a positive step in dealing with this complex issue. One particularly problematic issue remains, however: that the change of a calendar year valuation date due to a change in plan year is a change in funding method which requires IRS approval under Rev. Proc. 2000-41. We submit that this should not be the case. Read the comments.

On August 7, 2001, ASPPA's Actuarial/PBGC subcommittee reviewed the new Form 1-EZ and the new Schedule A and viewed the changes as positive and helpful. Read the comment letter.

On August 6, 2001, ASPPA issued a letter strongly supporting the effort by the Department of Labor, and particularly the PWBA, to permit plan sponsors and administrators to take advantage of new information technologies in distributing certain required documents to plan participants. Read the comment letter.

On May 29, 2001, ASPPA requested that the Department of Labor provide a blanket extension of time to file the 2000 Form 5500 Series, similar to the transition-year extension granted on March 22, 2000 for the 1999 annual return/report forms. Read the letter.

On April 17, 2001, ASPPA commented on IRS Proposed Regulations under section 401(a)(9) of the Internal Revenue Code (Code). ASPPA submitted comments regarding: (1) effective dates and use of the model amendment; (2) establishment of separate accounts; (3) the identification of beneficiaries and the ability to split trusts after the participant's death; and (4) application of the proposed rules to 403(b) plans. Read the comments.

On March 7, 2001, ASPPA responded to the PBGC's request for comment on how to make benefit determinations for cash balance and hybrid plans at plan termination. Read the comments.

On February 23, 2001, ASPPA responded to DOL's request for information regarding disclosure of obligations of fiduciaries of employee benefit plans subject to Title I of ERISA.  The input was requested with respect to both pension plans (including both defined contribution and defined benefit plans) and welfare plans (particularly health and disability plans).  Read the response.

The DOL requested comments regarding the agenda for the 2001 SAVER Summit, from organizations that have a mission to educate American workers about the importance of saving for retirement and ways to achieve retirement security.  ASPPA offered the following comments and recommendations regarding the agenda - read them.

ASPPA wrote the IRS to offer suggestions on the priorities for guidance under the 2001 guidance priority list issued jointly by Treasury and IRS (Notice 2000-63, Comments on Items for Year 2001 Published Guidance Priority List). Read the suggestions.

On January 5, 2001, ASPPA filed with the Internal Revenue Service detailed comments on proposed regulations governing new comparability plans. In these comments ASPPA argues that the proposed rules applicable to combination defined contribution/defined benefit plans will likely result in excessive contribution requirements leading small businesses to abandon their defined contribution plans to the detriment of younger workers. The comments also address a number of technical issues raised by the proposed regulations. Read the comments.

On December 11, 2000, ASPPA provided the Internal Revenue Service with additional comments on IRS Notice 99-44, Section 415 Limitations on Benefit and Contributions Under Qualified Plans. Read the comments.

On October 31, 2000, ASPPA wrote a letter to the Department of Labor requesting a reduction in the penalties associated with their DFVC program. Read the letter.

On October 29, 2000, ASPPA wrote the Internal Revenue Service commending them on the publication of the Proposed and Final Regulations under 72(p) of the Internal Revenue Code and providing suggestions for further improvements. Read the letter.

On October 27, 2000, ASPPA wrote a letter to the Department of Labor suggesting the Pension and Welfare Benefits Adminstration publicize the availability of ERISA Procedure 76-1 for issues which affect tax-sheltered annuity arrangements described in Section 403(b) of the Internal Revenue Code. Read the letter.

On September 11, 2000, ASPPA wrote to the Internal Revenue Service commending the Service on its recent issuance of guidance concerning the Employee Plans Compliance Resolution System, and providing suggestions on further improvements. Read the letter.

On May 18, 2000, ASPPA wrote Ms. Carol R. Gold, IRS, a letter commenting on Notice 2000-3. [Read the letter. Note: this file is in pdf format, and requires Acrobat Reader® to open. Don't have it? Get the free plugin here!

On May 18, 2000, ASPPA wote Virginia C. Smith, Director of Enforcement, VFC Program, offering comments in regard to the Department of Labor's Notice of a Voluntary Fiduciary Correction Program (VFC Program). Read the letter.

On May 18, 2000, ASPPA wrote Ms. Carol R. Gold, IRS, regarding the issuance of Revenue Procedure 99-45 and concerns that our earlier comments on Revenue Procedures 95-51 and 98-10 may not have been adequately considered. ASPPA is also concerned with how IRS field actuaries seem to have been interpreting Section 4.02 of Revenue Procedure 95-51 as required changes rather than optional changes. Read the letter.

On May 2, 2000, ASPPA wrote The Honorable Orrin Hatch, Chairman of the Senate Committee on the Judiciary, expressing our strong opposition to adding any provision to the Bankruptcy Reform Act of 2000 (H.R. 833) that would cap the amount of retirement plan assets entitled to protection from creditors in bankruptcy. Read the letter.

On April 15th, ASPPA wrote Mr. John J. Canary, Chief, Division of Coverage, Reporting and Disclosure, DOL, regarding the need for an additional extension for filing Form 5500 series forms, and on guidance needed for filing Short Plan Year Return/Reports (5500). Read the letter.

On March 28, 2000, ASPPA wrote to the Internal Revenue Service regarding the issuance of guidance on the section 457(e)(11) exception for bona fide severance pay plans. Read the comment letter.

On February 2, 2000, ASPPA wrote to the Department of Labor regarding the proposed rule that would amend the regulations governing the circumstances under which small pension plans are exempt from the requirements to engage an independent qualified public accountant. Read the comment letter.

On December 3, 1999, ASPPA sent a letter to the IRS in support of its initiation of an outreach program for 403(b) tax-sheltered annuity arrangements. Read the letter.

On December 3, 1999, ASPPA sent a comment letter to the IRS asking for clarification on the catch-up provision elections A-B-C. Read the letter.

On November 15, 1999, ASPPA sent a comment letter to the IRS regarding the amortization of foregone contributions under the alternative full funding limit as modified by the Taxpayer Relief Act of 1997. Read the letter.

On October 25, 1999, ASPPA delivered a letter to the Internal Revenue Service during the 1999 ASPPA Annual Conference regarding the repeal of IRC Section 415(e). Read the letter.

On September 3, 1999, ASPPA sent a comment letter to the Treasury regarding the procedures for permitting restorative payments to qualified retirement plans. Read the letter.

On September 3, 1999, ASPPA sent a letter in support of Carol Gold's application for the position of Director of Employee Plans. Read the letter.

On August 5th, 1999, ASPPA sent a comment letter to the IRS regarding Revenue Procedure 99-13. The letter focuses on improvement of the EPCRS as it applies to 403(b) Plans, and obtaining clarification of some of the features of the Revenue Procedure. Read the comment letter.

On August 5th, 1999, ASPPA sent a comment letter to the U.S. Department of Labor on the computer scannable versions of the New Form 5500. Read the comment letter.

On August 5th, 1999, ASPPA sent a comment letter to the Pension Benefit Guaranty Corporation regarding the proposed rule on payment of premiums, the Alternative Calculation Method. Read the letter.

On May 14, 1999, ASPPA sent a letter to the IRS regarding the redesign of the prototype program. Read the letter.

On May 6, 1999, ASPPA sent comments to the U.S. Department of Labor expressing support of the Department's effort to use new information technologies. The comment letter also proposes some improvements to the proposed regulations. Read the letter.

On May 6, 1999, ASPPA wrote to the Internal Revenue Service to urge reconsideration of their position on the deductability of compliance correction fees under the Walk-In CAP Program. Read the letter.

On March 15, 1999, ASPPA wrote to the Department of the Treasury to urge that plan documents for 401(k) plans not be required to include specific nondiscrimination testing criteria. Read the letter.

On February 23, 1999, ASPPA expressed concern with a number of the requirements contained in Notice 98-52 in a letter to the Internal Revenue Service. Read the letter.

On December 8, 1998 ASPPA wrote to the DOL expressing concerns about potential regulations regarding small plan reporting requirements. Read the letter. (In March 1999 the DOL responded to these concerns. Read the DOL letter.) Senior members of Congress also expressed concerns about potential DOL Small Plan reporting regulations. Read the letter.

On October 28, 1998, ASPPA wrote to the Pension and Welfare Benefits Administration at the Department of Labor regarding the proposal by ASPPA for a DOL Voluntary Fiduciary Correction Program. Read the letter.

On October 26, 1998, ASPPA wrote to the IRS regarding Extension of GUST Remedial Amendment Period. Read the letter.

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