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Judy Miller

On June 12, ACOPA representatives, along with other ARA representatives, met with about 15 folks from IRS and Treasury to discuss current issues of concern to our membership. (Another 8-12 IRS and Treasury people joined by phone.) Later that afternoon, ACOPA reps met with PBGC. We were represented... READ MORE
Back in January, President Trump issued his Executive Order on Reducing Regulation and Controlling Regulatory Costs (EO 13771). This is where he mandated that for every new regulation issued by a government agency, two old ones must be repealed. The net estimated fiscal impact on the economy of... READ MORE
With the April 15 deadline just passed, I figured this is a good time to update you on the prospects for tax reform. Back in January, I told you that this time, in this Congress, I put the prospects at over 90%. I said it’s not if, but when. Well, I would like to retract that, please. Tax reform is... READ MORE
We have a Treasury Secretary now. Someday soon, we probably will also have a Secretary of Labor. Until there are also some assistants in place – like those for tax policy at Treasury and for EBSA at DOL – those departments won’t be fully functional. Congress is shutting down DOL’s efforts to give... READ MORE
ACOPA GAC has been busy working on a comment letter on the proposed amendment to the 417(e) regulations that was published in November. It’s a relatively short proposal, but it has generated a lot of discussion and some serious concern. The key point that would be made by the amendment is that the... READ MORE
Nothing boring about 2017 in Washington. Many practitioners, and plan sponsors, are hoping Trump appointees will pare back, or throw out, regulations and other administrative actions initiated by the previous administration. Most of us will be surprised if there isn’t an executive order on day one... READ MORE
My guess is you are already counting up your hours to make sure you will have your CE in by the end of this year, but what if you won’t make it? Do you have enough ethics credits? “Formal” education? What qualifies for ethics credit, anyway? Most of us were first enrolled before Jan. 1, 2014, so... READ MORE
Twice in past few months I have had the pleasure of participating in discussions about recent activities of The Actuarial Foundation (TAF) and its plans for the future. Having spent about an hour with the ACOPA Leadership Council (LC) and TAF Executive Director Jason Leppin in August, one might... READ MORE
Since the last issue, we had a very successful ACOPA Symposium in early August. A big thank you to the committee. Sara DeFillipo (chair), Ray Berry and Drew Forgrave put together a great event. Discussion was very lively, and time went by quickly. If you haven't attended an ACOPA Symposium, plan on... READ MORE
Karen, Kurt and I wrapped up an American Retirement Association Government Affairs Committee (GAC) meeting June 14 with visits with staff of the committees of jurisdiction on Capitol Hill. Presidents and Presidents-Elect of ARA and other membership divisions were also in the Hill contingent. (For... READ MORE
A few weeks ago, when Treasury withdrew the “reasonable classification” proposal, and the final fiduciary rule came out with modifications that addressed all but one item in our comment letter, I felt a tremendous sense of relief, and went off to the North American Actuarial Council (NAAC) meeting... READ MORE
By now you know that the “reasonable classification” proposal was stripped from the closed plans proposed regulation on April 14.  A huge “Thank You” to all of you who helped us get to this point. As of this writing, we had more than 1,000 practitioners and nearly 900 plan sponsors who had written... READ MORE
When did we first realize that the IRS read IRC §412(d)(2) to mean something other than what it appears to mean? Concern arose with the §430 and §436 regulations published in October 2009, but it really came to the fore in 2011, when the Gray Book question on the subject was asked, and answered.The... READ MORE
Buried in a recent Treasury Department regulation is a provision that will make it harder for small businesses to form new retirement plans or maintain their current ones.The regulation, in proposed form, imposes a new “reasonable classification” requirement on cross-tested plans. To be considered... READ MORE
Last month I promised an update on the proposed IRS regulation on “Nondiscrimination Relief for Closed Defined Benefit Plans and Additional Changes to the Retirement Plan Nondiscrimination Requirements.” In a nutshell, a rate group would not have access to the average benefits/nondiscriminatory... READ MORE
By now you have heard that the proposed IRS regulation on “Nondiscrimination Relief for Closed Defined Benefit Plans and Additional Changes to the Retirement Plan Nondiscrimination Requirements” is more about the “Additional Changes” than “Closed Defined Benefit Plans.” The IRS had made it clear in... READ MORE
The Senate Finance Committee held a hearing Jan. 28 on “Helping Americans Prepare for Retirement: Increasing Access, Participation and Coverage in Retirement Savings Plans.” Chairman Orrin Hatch (R-Utah) noted in his opening remarks that the hearing would allow the full committee to hear more... READ MORE
Over the past several years, we have heard from our members that the IRS had taken issue with “412(d)(2)” plan amendments in the determination letter application review process — but an internal memorandum from the IRS contains some good news.Some plan sponsors were being told that the amendments... READ MORE
Another year in the rear view mirror. My mother always told me that time goes by more quickly as you get older, and she was definitely right about that. Before looking ahead, I’d like to thank the dozens of ACOPA members who made last year a very productive one for us. We are all very busy people,... READ MORE
Those who have been concerned about the Labor Department’s recent extension of authority to state governments to run so-called “open” MEPs may now have an opportunity to compete more effectively with that alternative.In November, the Department of Labor (DOL) issued Interpretive Bulletin (IB) 2015-... READ MORE

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