U.S. Chamber of Commerce. November 1, 2007
|
|
- Osborn Hubert Ramsey
- 5 years ago
- Views:
Transcription
1 U.S. Chamber of Commerce November 1, 2007 The Honorable Charles Rangel Chairman House Committee on Ways and Means United States House of Representatives Washington, DC Dear Chairman Range!: On behalf of the U.S. Chamber of Commerce, I would like to thank you for the opportunity to comment on H.R. 3361, the Pension Protection Technical Corrections Act of 2007 (Corrections Act). Chamber members support the reforms to the private pension system made in the Pension Protection Act of 2006 (PPA) and want to ensure that those reforms are effectively and efficiently implemented. The U.S. Chamber of Commerce is the world s largest business federation, representing over three million businesses. More than 96 percent of the Chamber s members are small businesses with 100 or fewer employees, 70 percent of which have 10 or fewer employees. Yet, virtually all of the nation s largest companies are also active members. We are particularly cognizant of the problems of smaller businesses, as well as issues facing the business community at large. Besides representing a cross-section of the American business community in terms of number of employees, the Chamber represents a wide management spectrum by type of business and location. Each major classification of American business -- manufacturing, retailing, services, construction, wholesaling, and finance is represented. Also, the Chamber has substantial membership in all 50 states. Positions on national issues are developed by a cross-section of Chamber members serving on committees, subcommittees, and task forces. More than 1,000 business people participate in this process. The Primary Concern of the Chamber is that the Integrity of the PPA be Maintained. The PPA was the culmination of several years of discussions, negotiations, and delicately balanced compromises. Although the PPA contains provisions that we did not initially support, we understood the necessity of compromise. To undue any one of these compromises now would mean undoing them all. After the time and energy put into the bill including the considerable efforts of the Chairman it would be unfair to re-open the debate on substantive provisions. Therefore, we completely support the Chairman and his colleagues in limiting
2 changes to the PPA to technical corrections that are in keeping with the intent of the provisions as passed. We appreciate the significant effort that has been put into the Corrections Act. In particular, we have encouraged Congress to pass the following provisions and appreciate that they have been included in the Corrections Act. Combined Plan Limit. We appreciate the clarification of the combined plan limit. Without this clarification, contributions to the defined benefit plan would be limited to the greater of 25% of compensation or the minimum required contribution even if employer contributions to the defined contribution plan did not exceed 6%. Thank you for clarifying in the Corrections Act that if employer contributions to the defined contribution plan do not exceed 6% of compensation, the defined benefit plan is not subject to the combined plan limit. The Vesting Requirement for Cash Balance Plans. We applaud the inclusion of this provision. As you are aware, a vesting change usually requires one hour of service after the effective date of a change; however, this requirement was not included in the PPA. Thank you for recognizing that this result was not part of Congress s intent and it would have been an onerous and unjust burden on plan sponsors. Repeal of the Summary Annual Report for Defined Benefit Plans. Thank you for changing the reference in section 503(c)( 1) of the PPA. This change clarifies the intent to repeal the summary annual report requirement for defined benefit plans. Even with the magnitude of this effort, however, we believe that there are additional corrections needed to ensure that the intent of the statue is met. In no measure do we discount the work done thus far rather, we believe these changes will complement the work that has been done. As such, we recommend that the following corrections also be included. Congress Needs to Clarify that Asset Smoothing, Not Asset Averaging, Was Intended. One of the key policy discussions with respect to the PPA was the extent to which smoothing of interest rates and asset values would be permitted. Asset smoothing provides an employer with greater predictability with respect to the value of its pension assets and thus greater predictability with respect to its funding obligations. If an employer s funding obligations were subject to the constant fluctuations of the market, funding obligations would be so unpredictable that business planning would be exceedingly difficult. Since that unpredictability is a key reason for pension plan freezes and terminations, it is essential that asset smoothing be preserved. The PPA preserved a degree of predictability by preserving interest rate and asset smoothing, but the problem is that with respect to asset smoothing, the PPA used the term asset averaging, rather than asset smoothing. The legislative history of the PPA is extremely clear that the use of the term averaging was intended to refer to smoothing. In his floor statement on the PPA, Senator Enzi specifically states that smoothing for
3 both assets and liabilities may be only 24 months in duration. (emphasis added) Consequently, the language of the statute should be changed to reflect this Congressional intent. The Effective Date for the Whipsaw Provisions Should Apply to All Subsequent Distributions. The PPA states that the whipsaw provision applies to distributions made after the effective date of the PPA which is August 17, The Chamber urges Congress to clarify the plain meaning of the statutory language, namely, that the effective date is meant to apply to all distributions made after August 17, 2006, even if the corresponding benefits accrued before such effective date. Without this clarification, the provision will not offer the relief it was intended to and will create greater complications in the determination of benefits. The ERISA Preemption Provision Should Not be Contingent on Satisfying Investment or Notice Requirements. To clarify ERISA s preemptive effective on certain state wage garnishment laws, Section 902 of the PPA includes a preemption provision stating that ERISA will supersede the laws of any state that would directly or indirectly prohibit or restrict the inclusion in any plan of an automatic contribution arrangement. However, the preemption provision includes certain investment and notice requirements. Consequently, it is not clear if the old preemption under 514(a) still applies for automatic enrollment arrangements. A proposed rule on default investments has been issued, but no guidance has been provided for the new notice requirement. Since it is impossible to meet these new undefined requirements, it may be that section 5 14(e) is not yet available to plans. To eliminate this ambiguity, we recommend that this preemption not be contingent on satisfying any investment or notice requirements. This treatment is consistent with the preemption under 514(a) where no conditions are applied to the raising of ERISA preemption. Therefore, we urge Congress to delete subsections (2)(C) and (3)(A) of ERISA section 5 14(e) as passed in the PPA. The 30 Day s Advance Notice Requirement for Notice of Freedom to Divest Employer Securities Should be Amended. Section 507 of the PPA creates a new ERISA section 101(m) that requires that an individual be notified of their right to diversify company stock no later than 30 days before the first date they are eligible to do so for any type of contribution (i.e., elective deferrals and employer contributions). This requirement is impossible to satisfy in many situations particularly where the right to diversify employer securities is immediate in a daily trading environment. For example, this requirement cannot be met if an employment offer is made less than 30 days before an employment start date and the employer offers immediate eligibility to participate in a plan. Also, a plan that permits investment in employer securities or matches in employer securities cannot know with 30 days notice when any non-participating employee will choose to participate in the plan. Therefore, section 507 of the PPA should be amended to provide that in situations in which it is not possible to provide 30 days advance notice, because a plan provides that investments in employer securities may be diversified 1152 CONG REC S8749 (2006). 3
4 immediately, such notice must be provided within 30 days following the initial investment. The Mortality Table in Code Section 415 Should be Linked to the Mortality Table in Code section 417. The PPA changed the applicable interest rate and applicable mortality table required under Code section 4 17(e) beginning in Code section 4 17(e) currently refers to the applicable mortality table as the table based on the prevailing commissioners standard table. Code section 415(b)(2)(E)(v) references the same mortality table as in section 417(e)(3)(ii)(I) by using the exact same language; however, section 415 does not actually reference section 417(e). The mortality table language in section 415(b)(2)(E)(v) was not updated by the PPA. Thus, after the PPA is effective for purposes of Code section 417(e), the mortality table for 415 limit calculations will no longer be linked to the 417(e) mortality table, but will remain based on the commissioner s standard table. We believe this was unintentional and should be corrected. 2 The Effective Date for Single-Employer Funding Reforms Should be Delayed. We would like to reiterate the suggestion to delay the effective date of the funding changes for single-employer defined benefit plans. The effective date of the funding reforms is January 1, Although there is a transition period, the focus of the transition is to ease contribution requirements and financial burdens. Because the transition requires calculations to be made under the new rules, plans will have to undergo substantial modifications to their systems in order to be able to meet the transition requirements. At this time, however, plan sponsors do not have enough guidance because proposed regulations on funding are just being issued. With the required notice and comment period, the regulations will not be final until close to the end of the year at the earliest. Moreover, there are additional regulations needed that have not yet been issued even in proposed form. For example, guidance on the mortality table assumptions for calculating lump sum benefit payments is not expected until the middle of November. This is not enough time for plan sponsors to effectively and efficiently implement these rules. 3 We do not place any blame with the Administration on the contrary, it has done a tremendous job of providing much-needed guidance at an astonishing rate. However, with the many, many regulations that they are tasked with creating, it is impossible for them to all be completed at the same time. Taken out of context, it may seem that a year and a half is enough time for parties to prepare. However, in the context of a 900 page bill requiring hundreds of regulations in addition to other substantial regulatory projects (for example, the final regulations on nonqualified deferred compensation which are over 300 pages long), a year and a half just has not been long enough. We believe that this request fits under the technical corrections because the intent of the effective date in the PPA was to give all parties enough time to prepare for the changes 2 Code section 417(e)(3)(ii)(I). We advocate a delayed effective date for all provisions under section 102 of the PPA and the related changes in other sections that are necessary. 4
5 without being unduly burdened. In his floor statement on the bill, Senator Enzi explained that, The new rules we craft should not be so draconian that they become the cause of more bankruptcies and pension plan terminations. Without the appropriate guidance, plan sponsors cannot accurately determine their obligations for Due to the changes made in the funding rules, pension obligations could be significantly different from previous years. Moreover, if there is a significant increase and it is unexpected, it could cause an untenable burden on plan sponsors and drive some to terminate their plans. This result is a direct contradiction of the stated intent of the funding changes. Consequently, we ask that the effective date for the funding rules for single-employer defined benefit plans be extended for at least a year. Pursuant to this concern, we are fully supportive of legislation introduced by Representatives Pomeroy and Cantor, H.R. 3868, which delays the effective date of the funding rules for one year. 4 Again, we appreciate the work done by the Chairman and his colleagues in passing the PPA and appreciate the Chainnan s continued efforts to ensure that the provisions agreed to in the PPA are fully effectuated in the Corrections Act. We look forward to continuing to work the Chairman and other members of Congress on these important issues. Thank you for your consideration of our concerns. Sincerely, Randel K. Johnson Vice President Labor, Immigration & Employee Benefits OfUJO Aliya Wong Director of Pension Policy Labor, Immigration & Employee Benefits 152 CONG REC S8747 (2006).
December 13, Request for Comments on Health Coverage Affordability Safe Harbor for Employers (Section 4980H)
December 13, 2011 Submitted Electronically: Notice.comments@irscounsel.treas.gov CC:PA:LPD:PR (Notice 2011-73) Room 5203 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC 20044
More informationStatement of the. U.S. Chamber of Commerce
Statement of the U.S. Chamber of Commerce ON: TO: The Reporting Requirements Necessary to Verify Income and Insurance Information under the Affordable Care Act The House Ways and Means Subcommittees on
More informationU.S. Chamber of Commerce
U.S. Chamber of Commerce www.uschamber.com 1615 H Street, NW Washington, DC 20062 January 3, 2006 Courier s Desk Internal Revenue Service 1111 Constitution Avenue, N.W. Washington, DC 20224 ATTN: C:PA:LPD:PR
More informationTestimony of Kyle Brown Retirement Counsel Watson Wyatt Worldwide on behalf of the American Benefits Council
Testimony of Kyle Brown Retirement Counsel Watson Wyatt Worldwide on behalf of the American Benefits Council Hearing on Participant Benefit Statements Working Group on Participant Benefit Statements ERISA
More informationPension Protection Act of 2006
Pension Protection Act of 2006 August 2006 Friends and Colleagues: On August 17, 2006, President Bush signed into law the Pension Protection Act of 2006 (the Act ). This client alert provides general highlights
More informationU.S. Chamber of Commerce
U.S. Chamber of Commerce Office of Regulations and Interpretations Employee Benefits Security Administration Room N-5655 U.S. Department of Labor 200 Constitution Avenue, NW Washington, DC 20210 June 6,
More informationNovember 8, Submitted Electronically Via Federal Rulemaking Portal:
November 8, 2013 Submitted Electronically Via Federal Rulemaking Portal: www.regulations.gov CC:PA:LPD:PR (REG-136630-12) Room 5205 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington,
More informationAugust 9, Submitted Electronically Via Federal Rulemaking Portal:
August 9, 2016 Submitted Electronically Via Federal Rulemaking Portal: www.regulations.gov Attention: CC:PA:LPDD:PR REG-135702-15 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington,
More informationMissing Participants in Individual Account Plans Request for Information
August 20, 2013 Office of the General Counsel Pension Benefit Guaranty Corporation 1200 K Street NW Washington, D.C. 20005 4026 RE: Missing Participants in Individual Account Plans Request for Information
More informationStabilizing Premiums and Helping Individuals in the Individual Insurance Market for 2018: Governors
ON: TO: FROM: Stabilizing Premiums and Helping Individuals in the Individual Insurance Market for 2018: Governors U.S. Senate Committee on Health, Education, Labor & Pensions Randel K. Johnson, Senior
More informationWe are writing you today regarding the implementation of a fundamental component of the Pension Protection Act of 2006 (the PPA ).
The Honorable Henry M. Paulson, Jr. Secretary of the Treasury Main Treasury Building, Room 3330 1500 Pennsylvania Avenue, NW Washington, DC 20220 Dear Secretary Paulson: We are writing you today regarding
More informationMarch 23, Internal Revenue Service CC:PA:LPD:RU (Notice ) Room 5203 PO Box 7604 Ben Franklin Station Washington, DC 20044
March 23, 2011 Internal Revenue Service CC:PA:LPD:RU (Notice 2011-02) Room 5203 PO Box 7604 Ben Franklin Station Washington, DC 20044 Re: Comments Regarding Notice 2011-02 Dear Sir or Madam: America s
More informationGROOM LAW GROUP, CHARTERED
GROOM LAW GROUP, CHARTERED 2007 Employee Benefits Seminar Potpourri of Plan Communication Issues Presenters: Mark Lofgren (Moderator) Kendall Daines Liz Dold Anna Driggs Topics: PPA-Required Notices Benefit
More informationPENSION RIGHTS CENTER
PENSION RIGHTS CENTER 1350 CONNECTICUT AVENUE, NW SUITE 206 WASHINGTON, DC 20036-1722 TEL: 202-296-3776 FAX: 202-833-2472 WWW.PENSIONRIGHTS.ORG The Honorable Henry M. Paulson, Jr. Secretary of the Treasury
More informationThe Honorable Orrin Hatch November 11, 2017 Page 2
The Honorable Orrin Hatch Chairman Senate Committee on Finance United States Senate 219 Dirksen Senate Office Building Washington, DC 20510 RE: Center On Executive Compensation Comments on Nonqualified
More informationRIN 1210-AB88, Definition of Employer Under Section 3(5) of ERISA- Association Retirement Plans and Other Multiple-Employer Plans
Filed electronically at www.regulations.gov Office of Regulations and Interpretations Employee Benefit Security Administration Room N-5655 U.S. Department of Labor 200 Constitution Avenue, NW Washington,
More informationAugust 26, Submitted Via Federal Rulemaking Portal:
August 26, 2010 Submitted Via Federal Rulemaking Portal: http://www.regulations.gov Office of Consumer Information and Insurance Oversight Department of Health and Human Services Room 445-G Hubert H. Humphrey
More informationNovember 1, Background
Technical Director Financial Accounting Standards Board Norwalk, CT 06856-5116 November 1, 2010 Re: File Reference No. 1860-100 Proposed Accounting Standards Update, Compensation Retirement Benefits Multiemployer
More informationStatement of the U.S. Chamber of Commerce
Statement of the U.S. Chamber of Commerce ON: TO: S-CORPS: RECOMMENDED REFORMS THAT PROMOTE PARITY, GROWTH AND DEVELOPMENT FOR SMALL BUSINESSES" SUBCOMMITTEE ON FINANCE AND TAX OF THE HOUSE COMMITTEE ON
More informationStatement Of the U.S. Chamber Of Commerce
Statement Of the U.S. Chamber Of Commerce ON: TO: Hearing on Extension of Certain Expired and Expiring Tax Provisions Senate Finance Committee DATE: January 31, 2012 The Chamber s mission is to advance
More informationDecember 4, Dear Majority Leader Reid, Minority Leader McConnell, Speaker Pelosi and Minority Leader Boehner:
The Honorable Harry Reid Majority Leader, U.S. Senate The Honorable Nancy Pelosi Speaker, U.S. House of Representatives The Honorable Mitch McConnell Minority Leader U.S. Senate The Honorable John Boehner
More informationDOL ISSUES FINAL QDIA GUIDANCE October 26, 2007
THE PROFIT SHARING AND 401(k) ADVOCATE SHARING THE COMMITMENT SINCE 1947 500 Eighth Street, NW, Suite 210, Washington, DC 20004 202.863 7272 ferrigno@401k.org Edward Ferrigno Vice President, Washington
More informationStatement of the U.S. Chamber of Commerce
Statement of the U.S. Chamber of Commerce ON: TO: BY: Outsourcing Employee Benefit Plan Services The ERISA Advisory Council Aliya Wong DATE: August 19, 2014 The Chamber s mission is to advance human progress
More informationPENSION RIGHTS CENTER
PENSION RIGHTS CENTER 1350 CONNECTICUT AVENUE, NW SUITE 206 WASHINGTON, DC 20036 TEL: 202-296-3776 FAX: 202-833-2472 WWW.PENSIONRIGHTS.ORG STATEMENT OF KAREN D. FRIEDMAN ON BEHALF OF THE PENSION RIGHTS
More informationSUMMARY OF DEFINED CONTRIBUTION PLAN PROVISIONS OF THE PENSION PROTECTION ACT OF 2006
SUMMARY OF DEFINED CONTRIBUTION PLAN PROVISIONS OF THE PENSION PROTECTION ACT OF 2006 ISSUE PRIOR LAW PENSION PROTECTION ACT 1 PERMANENCE OF RETIREMENT SAVINGS INCENTIVES RETIREMENT PLANS The Economic
More informationThese FAQs state: HRA Prohibition May Have Broader Affects
May 20, 2013 Secretary Sebelius Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, S.W. Washington, DC 20201 Secretary Lew Department of the Treasury 1500 Pennsylvania
More informationStatement of the U.S. Chamber Of Commerce
Statement of the U.S. Chamber Of Commerce ON: TO: Hearing on Extension of Certain Expired and Expiring Tax Provisions Subcommittee on Select Revenue Measures of the Ways & Means Committee DATE: April 26,
More information1102 Longworth House Office Building 1139E Longworth House Office Building
The Honorable Paul Ryan The Honorable Nancy Pelosi Speaker Minority Leader United States House of Representatives United States House of Representatives H-232, U.S. Capitol H-204, U.S. Capitol Washington,
More informationVolcker Rule Conformance Period for Legacy Illiquid Funds. Dear Board of Governors of the Federal Reserve System:
March 1, 2016 20th Street and Constitution Avenue, N.W. Washington, D.C. 20551 Re: Volcker Rule Conformance Period for Legacy Illiquid Funds Dear : SIFMA 1 and the ABA 2 write to express their members
More informationSpecific Defined Benefit Plan Funding Proposals
May 20, 2009 Specific Defined Benefit Plan Funding Proposals First Relief Proposal: Amortization of 2008 Losses. In general. Under the Pension Protection Act of 2006 ( PPA ), 2008 asset losses must be
More informationPension Protection Act Series - Single Employer and Cash Balance Plans
Pension Protection Act Series - Single Employer and Cash Balance Plans Dial-in: 800.659.2090 Passcode: 10736696 Mark Boxer John Ferreira Mark Simons September 19 & 21, 2006 How To Print This Presentation
More informationWays & Means Committee Draft ( W&M Draft )
General The United States House of Representatives released on November 2, 2017. The House Committee on Ways & Means released its W&M on November 10, 2017 and the W&M was later approved by the House of
More informationStatement of the U.S. Chamber of Commerce
Statement of the U.S. Chamber of Commerce ON: TO: SMALL BUSINESS ECONOMIC STIMULUS HEARING THE HOUSE COMMITTEE ON SMALL BUSINESS DATE: JULY 24, 2008 The Chamber s mission is to advance human progress through
More informationOctober 1, CC:PA:LPD:PR (REG ) Room 5203 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC 20044
October 1, 2018 CC:PA:LPD:PR (REG-107892-18) Room 5203 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Attention: Regina Johnson RE: Comment on IRS Notice of Proposed Rulemaking
More informationMakes permanent the provisions of EGTRRA that relate to retirement plans and IRAs. Makes the Saver s Credit permanent.
Leading Proposals Affecting Defined Contribution and Other Retirement Arrangements (Other Than Pension Funding and Hybrid Plan Proposals) [Note: Includes discussion of H.R. 1000, which passed the House
More informationPENSION PROTECTION ACT OF 2006
AN OVERVIEW OF THE IMPACT OF THE PENSION PROTECTION ACT OF 2006 ON QUALIFIED RETIREMENT PLANS Indiana Benefits Conference January 16, 2007 Indianapolis, Indiana E. Van Olson Introduction The Pension Protection
More informationPENSION PROTECTION ACT. Single-Employer and Multiple-Employer Defined Benefit Plans
August 18, 2006 PENSION PROTECTION ACT President Bush signed the Pension Protection Act of 2006 ("PPA") on August 17, 2006. The PPA contains many changes for both defined contribution plans and defined
More informationJuly 31, Honorable Mike Enzi Chairman Committee on Health, Education, Labor and Pensions United States Senate Washington, DC 20510
CONGRESSIONAL BUDGET OFFICE U.S. Congress Washington, DC 20515 Honorable Mike Enzi Committee on Health, Education, Labor and Pensions United States Senate Washington, DC 20510 Dear Mr. : July 31, 2006
More informationSTATEMENT FOR THE RECORD SUBMITTED BY AMERICAN BENEFITS COUNCIL AND AMERICAN COUNCIL OF LIFE INSURERS AND INVESTMENT COMPANY INSTITUTE TO THE
STATEMENT FOR THE RECORD SUBMITTED BY AMERICAN BENEFITS COUNCIL AND AMERICAN COUNCIL OF LIFE INSURERS AND INVESTMENT COMPANY INSTITUTE TO THE U.S. HOUSE OF REPRESENTATIVES EDUCATION AND LABOR COMMITTEE
More informationBAUCUS-GRASSLEY BILL ADDRESSES PUBLICLY TRADED PARTNERSHIPS Senators seek to clarify tax treatment for partnerships acting as corporations
For Immediate Release Contact: Carol Guthrie (Baucus) June 14, 2007 Jill Gerber (Grassley) (202) 224-4515 BAUCUS-GRASSLEY BILL ADDRESSES PUBLICLY TRADED PARTNERSHIPS Senators seek to clarify tax treatment
More informationThe Long and Short of the Pension Protection Act of 2006
The Long and Short of the Pension Protection Act of 2006 Long-Term Implications and Short-Term Actions for Plan Sponsors 2006 United States watsonwyatt.com 2 Watson Wyatt Worldwide Table of Contents Single-Employer
More informationAugust 4, The Honorable Charles Rangel, Chairman Committee on Ways and Means United States House of Representatives Washington, D.C.
August 4, 2009 The Honorable Charles Rangel, Chairman Committee on Ways and Means United States House of Representatives Washington, D.C. 20515 The Honorable Henry A. Waxman, Chairman Committee on Energy
More information219 Dirksen Senate Office Building 219 Dirksen Senate Office Building Washington, DC Washington, DC 20510
The Honorable Orrin G. Hatch Chairman Ranking Member U.S. Senate Committee on Finance U.S. Senate Committee on Finance 219 Dirksen Senate Office Building 219 Dirksen Senate Office Building Washington,
More informationJuly 2, RE: Minimum Value of Eligible Employer-Sponsored Plans and Other Rules Regarding the Health Insurance Premium Tax Credit
July 2, 2013 Submitted Via Federal Rulemaking Portal: http://www.regulations.gov CC:PA:LPD:PR (REG-125398-12) Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044 RE: Minimum
More information1102 Longworth House Office Building 219 Dirksen Senate Office Building Washington, DC Washington, DC 20510
The Honorable Kevin Brady Chairman Chairman House Committee on Ways and Means United States Senate Committee on Finance 1102 Longworth House Office Building 219 Dirksen Senate Office Building Washington,
More informationIRS Issues Proposed Regulations on Hybrid Plans
IRS Issues Proposed Regulations on Hybrid Plans On December 27, 2007, the IRS issued proposed regulations on provisions in the Pension Protection Act of 2006 affecting primarily cash balance and other
More informationRelated Individuals. IRS Issues Cash Balance Plan Guidance. Ira G Bogner Partner t: Client Alert. November 19, 2010
Related Individuals Ira G Bogner t: 212.969.3947 Jacob I Friedman t: 212.969.3805 Paul M Hamburger t: 202.416.5850 Andrea S Rattner t: 212.969.3812 Michael S Sirkin t: 212.969.3840 Lisa A Berkowitz Herrnson
More informationSeptember 29, Filed electronically at
September 29, 2016 Filed electronically at http://www.regulations.gov Office of Regulations and Interpretations Employee Benefits Security Administration Room N 5655 U.S. Department of Labor 200 Constitution
More informationMay 3, Filed electronically via the Federal erulemaking Portal at
May 3, 2012 Filed electronically via the Federal erulemaking Portal at http://www.regulations.gov CC:PA:LPD:PR (REG-110980-10) Room 5203 Internal Revenue Service PO Box 7604 Ben Franklin Station Washington
More informationJune 3, Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street N.W. Washington, D.C.
Robert R. Davis Executive Vice President Mortgage Markets, Financial Management & Public Policy (202) 663-5588 RDavis@aba.com Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection
More informationGRIST Report: House passes broad pension bill; Senate outlook uncertain
GRIST Report: House passes broad pension bill; Senate outlook uncertain By Geoff Manville, Heidi Rackley, Valerie Grace, Paul Strella, and Amy Bergner of the Washington Resource Group, and Paul Graf of
More informationMay 15, Submitted Electronically via
May 15, 2015 Submitted Electronically via Email: Notice.comments@irscounsel.treas.gov CC:PA:LPD:PR (Notice 2015-16) Room 5203 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC
More informationOverview of the New Pension Protection Act of 2006
Overview of the New Pension Protection Act of 2006 August 28, 2006 To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including
More informationPension Protection Act of 2006: What to do in 2007
DECEMBER 1, 2006 VOLUME 2, NUMBER 12 Pension Protection Act of 2006: What to do in 2007 This newsletter looks to 2007 and highlights effective by (913) 685-0749 PPA changes some of which are already effective,
More informationJune 10, RIN 1210 AB08 (Proposed Amendment Relating to Reasonable Contract or Arrangement Under Section 408(b)(2) Fee Disclosure)
The ERISA Industry Committee June 10, 2014 Attention: RIN 1210 AB08; 408(b)(2) Guide Office of Regulations and Interpretations Employee Benefits Security Administration Room N 5655 U.S. Department of Labor
More informationREG Proposed Amendment to Regulations Relating to Hardship Distributions
The ERISA Industry Committee Driven By and For Large Employers 7 0 1 8 t h S t r e e t N W, S u i t e 6 1 0, W a s h i n g t o n, D C 2 0 0 0 1 ( 2 0 2 ) 7 8 9-1400 w w w. e r i c. o r g January 14, 2019
More informationIRS Provides Guidance for Hybrid Plans
Important Information Plan Design February 2007 IRS Provides Guidance for Hybrid Plans WHO'S AFFECTED These developments affect sponsors of and participants in hybrid plans, such as cash balance plans
More informationPension Protection Act of 2006: Next steps and considerations for plan sponsors of single-employer defined benefit plans *
Pension Protection Act of 2006: Next steps and considerations for plan sponsors of single-employer defined benefit plans * Effective immediately or retroactively Provision Summary of Provision Next Steps
More informationpay, but they able to
Universal Coverage: USA Retirement Funds would provide every working person in America with access to a retirement plan throughh an automatic payroll deduction. Employers with more than 10 employees would
More informationFeedback for REG ( Transition Tax) as of 10/3/2018 SECTION TITLE ISSUE RECOMMENDATION ADDITIONAL EXPLANATION /QUERIES
Feedback for REG-104226-18 ( 965 1 Transition Tax) as of 10/3/2018 PROPOSED REGS Preamble Pages 63-64 Double counting for November 2017 distributions to the United States from 11/30 year end deferred foreign
More informationDefined Contribution Plan Issues In Pension Reform Legislation
Defined Contribution Plan Issues In Pension Reform Legislation The pending pension reform legislation contains critical reforms of the rules relating to defined benefit plan funding, hybrid plans, and
More information317 Russell Senate Office Building 322 Hart Senate Office Building
The Honorable Mitch McConnell Majority Leader Minority Leader United States Senate United States Senate 317 Russell Senate Office Building 322 Hart Senate Office Building Washington, DC 20510 Washington,
More informationMay 6, Annie Donovan Director, CDFI Fund Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220
May 6, 2016 Annie Donovan Director, CDFI Fund Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 RE: Regulatory Information Number 1559-AA00 Dear Director Donovan, The Local Initiatives
More informationCommissioner, Iowa Insurance Division Commissioner, D.C. Department of Insurance,
Insured Retirement Institute 1100 Vermont Avenue, NW 10 th Floor Washington, DC 20005 t 202.469.3000 f 202.469.3030 February 15, 2019 www.irionline.org www.myirionline.org Submitted Electronically to jmatthews@naic.org
More informationTESTIMONY OF LEW MINSKY ON BEHALF OF
TESTIMONY OF LEW MINSKY ON BEHALF OF THE ERISA INDUSTRY COMMITTEE PROFIT SHARING/401K COUNCIL OF AMERICA NATIONAL ASSOCIATION OF MANUFACTURERS AND U.S. CHAMBER OF COMMERCE BEFORE THE U.S. HOUSE OF REPRESENTATIVES
More informationNew Deferred Compensation Legislation Summary and Action Steps
October 29, 2004 New Deferred Compensation Legislation Summary and Action Steps The House and Senate recently approved far-reaching changes in the federal tax laws that apply to nonqualified deferred compensation
More informationMEMORANDUM TO CLIENTS. Key Provisions of The "Worker, Retiree, and Employer Recovery Act of 2008" A Bit More Than PPA Technical Corrections
MEMORANDUM TO CLIENTS December 19, 2008 RE: Key Provisions of The "Worker, Retiree, and Employer Recovery Act of 2008" A Bit More Than PPA Technical Corrections The Worker, Retiree, and Employer Recovery
More informationApril 30, Dear Colleague,
Loral R. Blinde Vice President People & Employee Services April 30, 2015 Dear Colleague, I am pleased to share the enclosed Annual Funding Notice, which details information about your pension plan, the
More informationQDIA PRACTICES CHECKLIST
QDIA PRACTICES CHECKLIST PLAN SPONSOR: PLAN NAME(S): RECORDKEEPER: ADVISOR: ADVISOR GUIDELINES FOR RECOMMENDING QDIAS OVERVIEW: A common question asked by plan sponsors is: How do I select a qualified
More informationThe de minimis exception to designation as a Swap Dealer should be available to regional banks and dealers that intermediate regional Swap markets.
November 10, 2010 Mr. David A. Stawick Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington DC 20581 Ms. Elizabeth M. Murphy Secretary Securities and
More informationCommissioner, Iowa Insurance Division Commissioner, D.C. Department of Insurance,
February 15, 2019 Submitted Electronically to jmatthews@naic.org The Honorable Doug Ommen The Honorable Stephen C. Taylor Commissioner, Iowa Insurance Division Commissioner, D.C. Department of Insurance,
More informationMarch 5, Re: Definition of Employer Small Business Health Plans RIN 1210-AB85. Dear Secretary Acosta:
The Honorable R. Alexander Acosta Secretary of Labor U.S. Department of Labor Employee Benefits Security Administration 200 Constitution Avenue NW, Room N-5655 Washington, DC 20210 Re: Definition of Employer
More informationIBEW FACT SHEET JOINT SELECT COMMITTEE ON SOLVENCY OF MULTIEMPLOYER PENSION PLANS
November 2018 IBEW FACT SHEET JOINT SELECT COMMITTEE ON SOLVENCY OF MULTIEMPLOYER PENSION PLANS The IBEW opposes solutions that would apply burdensome funding requirements and excessive fees on multiemployer
More informationJanuary 3, Re: Comments Regarding CFTC s Proposed Rule Pertaining to the Process for Review of Swaps for Mandatory Clearing
Mr. David A. Stawick Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 Submitted via Agency Website January 3, 2011 Re: Comments Regarding
More informationCOMPENSATION & BENEFITS
COMPENSATION & BENEFITS JUNE 2001 A lert Summary of Retirement-Related Provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001 The Economic Growth and Tax Relief Reconciliation Act
More informationApril 24, The Honorable Phyllis Borzi Office of Regulations and Interpretations, Employee Benefits Security Attn: Conflict of Interest Rule,
The Honorable Phyllis Borzi, Assistant Secretary Employee Benefits Security Administration, Employee Benefits Security Attn: Conflict of Interest Rule, Administration Room N-5655, Attn: Conflict of Interest
More informationOctober 12, The Council recognizes the difficult mission of the Pension Benefit Guaranty Corporation (the PBGC ). The PBGC is charged with:
October 12, 2010 Legislative and Regulatory Department Pension Benefit Guaranty Corporation 1200 K Street, NW Washington, DC 20005-4026 RE: RIN 1212-AB20 Dear Sir or Madam: I am writing today on behalf
More informationRE: Proposed Rule Expatriate Health Plans and other issues
1 The ERISA Industry Committee July 29, 2016 Internal Revenue Service Attention: CC:PA:LPD:PR (REG 135702 15) P.O. Box 7604 Washington, DC 20044 RE: Proposed Rule Expatriate Health Plans and other issues
More informationIRS Publishes Rules for Single-Employer Pension Plan Funding Relief
IRS Publishes Rules for Single-Employer Pension Plan Funding Relief IRS Notice 2011-3 provides guidance as to how a sponsor of a single-employer defined benefit pension plan may elect one of the two alternative
More informationFile Number S ; Custody of Funds or Securities of Clients by Investment Advisers
Via Electronic Mail: rule-comments@sec.gov Elizabeth M. Murphy Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Re: File Number S7-09-09; Custody of Funds or
More informationSenate passes Pension Protection Act, Bill goes to President
LEGISLATION Senate passes Pension Protection Act, Bill goes to President Seeking to avert a meltdown and taxpayer bailout of traditional private pension plans, Congress has passed a comprehensive pension
More informationSUMMARY OF PROVISIONS OF THE PENSION PROTECTION ACT OF 2006 AFFECTING DEFINED BENEFIT PLAN FUNDING AND HYBRID PLANS
SUMMARY OF PROVISIONS OF THE PENSION PROTECTION ACT OF 2006 AFFECTING DEFINED BENEFIT PLAN FUNDING AND HYBRID PLANS ISSUE PRIOR LAW PENSION PROTECTION ACT 1 COMMENTS SINGLE-EMPLOYER PENSION FUNDING IN
More informationstabilize the Medicare Advantage Program
March 4, 2016 The Honorable Sylvia Burwell Secretary, U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, D.C. 20201 Dear Secretary Burwell: The U.S. Chamber of Commerce
More informationAugust 7, The Honorable Steven Mnuchin Secretary of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220
August 7, 2017 The Honorable Steven Mnuchin Secretary of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 RE: SIFMA Response to Notice 2017-38 Dear Secretary Mnuchin: The Securities Industry
More informationApril 6, Dirksen Senate Office Building 713 Hart Senate Office Building Washington, DC Washington, DC, 20515
April 6, 2015 Honorable Mike Crapo Honorable Sherrod Brown 239 Dirksen Senate Office Building 713 Hart Senate Office Building Washington, DC 20515 Washington, DC, 20515 Dear Senator Crapo and Senator Brown:
More informationUNIFIED GROCERS, INC.
UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of Report (Date of the earliest
More information219 Dirksen Senate Office Building 219 Dirksen Senate Office Building Washington, DC Washington, DC 20510
The Honorable Michael Crapo Senate Committee on Finance Senate Committee on Finance Tax Reform Working Group on Tax Reform Working Group on Savings and Investment Savings and Investment 219 Dirksen Senate
More informationDecember 21, Dear Chairman McWilliams, Comptroller Otting, Vice Chairman Quarles, Chairman McWatters, and Chairman Tonsager:
December 21, 2018 The Honorable Jelena McWilliams The Honorable J. Mark McWatters Chairman Chairman Federal Deposit Insurance Corporation National Credit Union Administration 550 17 th Street, NW 1775
More informationOctober 9, Re: REG Relating to the Proposed Regulations under Section 965
October 9, 2018 William M. Paul, Esq. Acting Chief Counsel Internal Revenue Service 1111 Constitution Avenue, N.W. Washington DC 20224 CC:PA:LPD:PR (REG 104226 18) Room 5203 Internal Revenue Service P.O.
More information1102 Longworth House Office Building 1106 Longworth House Office Building Washington, DC Washington, DC 20515
February 23, 2017 The Honorable Kevin Brady The Honorable Richard Neal Chairman Ranking Member Committee on Ways and Means Committee on Ways and Means U.S. House of Representatives U.S. House of Representatives
More informationThe Honorable Max Baucus, Chairman The Honorable Dave Camp, Chairman
The Honorable Max Baucus, Chairman, Chairman Senate Committee on Finance House Committee on Ways & Means 219 Dirksen Senate Office Building 1102 Longworth House Office Building Washington, DC 20510 Washington,
More informationJune 22, RE: Comments on Mental Health Parity and Addiction Equity Act Draft Model Disclosure Request Form
June 22, 2018 Filed electronically via OIRA_submission@omb.eop.gov Office of Information and Regulatory Affairs, Attn: OMB Desk Officer for DOL-EBSA Office of Management and Budget Room 10235 725 17 th
More informationPENSION PROTECTION ACT OF 2006-An Overview of Selected Provisions. Yolanda D. Montgomery Nicole Eichberger Proskauer Rose LLP
PENSION PROTECTION ACT OF 2006-An Overview of Selected Provisions Peter J. Marathas, Jr. Yolanda D. Montgomery Nicole Eichberger Proskauer Rose LLP 0 Reasons For Pension Reform Many factors are responsible
More informationAmerican Payroll Association
American Payroll Association Government Relations Washington, DC June 2, 2015 Statement for the Record Submitted to the House Judiciary Subcommittee on Regulatory Reform, Commercial and Antitrust Law In
More information1500 Pennsylvania Avenue, NW 1111 Constitution Avenue, NW Washington, D.C Washington, D.C
VIA ELECTRONIC MAIL The Honorable David Kautter The Honorable William Paul Assistant Secretary of the Treasury Acting Chief Counsel U.S. Department of the Treasury Internal Revenue Service 1500 Pennsylvania
More informationConference Agreement on the "Tax Cuts and Jobs Act" includes significant executive compensation and employee benefits provisions
December 20, 2017 Conference Agreement on the "Tax Cuts and Jobs Act" includes significant executive compensation and employee benefits provisions This Alert highlights the changes in tax law related to
More informationFee Disclosure in Defined Contribution Retirement Plans: Background and Legislation
Fee Disclosure in Defined Contribution Retirement Plans: Background and Legislation John J. Topoleski Analyst in Income Security January 29, 2010 Congressional Research Service CRS Report for Congress
More informationComments Regarding the Application of Section 470 to Partnerships Solely as a Result of Section 168(h)(6)
July 26, 2006 The Honorable Charles E. Grassley Chairman Senate Finance Committee 219 Senate Dirksen Office Building Washington, D.C. 20515 The Honorable Max Baucus Ranking Minority Member Senate Finance
More informationSubcommittee on Employer-Employee Relations Committee on Economic and Educational Opportunities U.S. House of Representatives
Subcommittee on Employer-Employee Relations Committee on Economic and Educational Opportunities U.S. House of Representatives Hearing on Issues on Pension Reform Written Testimony Submitted by Ronald Gebhardtsbauer
More informationBANK HOLDING COMPANY LEGISLATION
BANK HOLDING COMPANY LEGISLATION At the outset I should like to emphasize that the Board of Governors believes that bank holding company legislation is desirable. The Board's general views on this subject
More information