2012 | AMERICAN SOCIETY OF PENSION PROFESSIONALS & ACTUARIES

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On November 28, 2012, ASPPA submitted comments to the Internal Revenue Service (IRS) requesting that it issue guidance clarifying the application of the eligibility provisions of the Internal Revenue Code when a former employee is rehired following a one-year break in service. [Comment]

On October 31, 2012, ASPPA submitted comments to the Office of Management and Budget (OMB) and Internal Revenue Service (IRS) to recommend that the IRS solicit and maintain information on the active status of a trust associated with a qualified retirement plan to avoid inadvertent deactivation of the trust’s EIN. [Comment]

On September 19, 2012, ASPPA and CIKR submitted comments to the Treasury Department and Internal Revenue Service (IRS) to suggest improvements to the Employee Plans Compliance Resolution System (EPCRS) with respect to the correction of automatic enrollment failures. [Comment]

On August 21, 2012, ASPPA joined with 12 other organizations in recommending that the SEC not move forward with proposals for new regulatory requirements regarding money market funds because of administrative difficulties they would cause for retirement plan administrators and fiduciaries.[letter to SEC]

On July 25, 2012, ASPPA and NTSAA submitted comments to the Treasury Department and IRS relating to the determination of whether a plan is a governmental plan within the meaning of Internal Revenue Code section 414(d). ASPPA and NTSAA recommended that the Treasury Department and IRS: (a) establish an exemption specific to charter schools that are created and maintained pursuant to state statutes; and (b) create an express category in the description of agency to include charter schools. [Comment]

On June 25, 2012, ASPPA joined with other organizations in submitting comments to the Department of Labor requesting that the guidance on brokerage windows and similar arrangements contained in question 30 of FAB 2012-02 be withdrawn. It was recommended that if the Department of Labor wanted to continue to pursue the position espoused in question 30, it should do so through the formal rulemaking process where it would be subject to public comment and economic analysis. [Comment]

On June 1, 2012, ASPPA and ACOPA sent a letter to IRS asking for guidance providing automatic approval for certain changes in funding method similar to the guidance provided in Revenue Procedure 2000-40 before the funding rule changes enacted in the Pension Protection Act of 2006 (PPA) made that procedure obsolete. [Letter]

On June 1, 2012, ASPPA submitted comments to the Internal Revenue Service (IRS) and Treasury Department to provide input on the Retirement Benefit items (and relative priority of such items) to be included on the 2012-2013 Guidance Priority List. [Comment]

On June 1, 2012, ASPPA submitted comments to the Internal Revenue Service (IRS) requesting additional guidance on mid-year modifications to safe harbor plans under Internal Revenue Code sections 401(k) and 401(m). ASPPA recommended that the IRS: (1) provide a list of plan modifications that may be made after the start of a plan year without affecting a plan’s safe harbor status; (2) create exceptions for certain safe harbor plan amendments that are made early in the plan year; and (3) clarify whether and when plan sponsors must provide a supplemental notice to participants to advise them of mid-year plan changes. [Comment]

On May 30, 2012, ASPPA submitted comments to the Internal Revenue Service (IRS) with respect to the 5-year rule relating to Roth conversions within qualified retirement plans under Internal Revenue Code section 402A. ASPPA recommended that the IRS issue additional guidance confirming that the 5-year period of participation for tax-free distributions from a Roth account that was created by an internal Roth conversion inside a 401(k) plan begins on the date of the conversion. [Letter]

On May 23, 2012, ASPPA and ACOPA sent a letter to Surface Transportation Act conferees urging them to modify the funding rules to moderate the impact of artificially low interest rates. [Letter]

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]

On April 16, 2012, ASPPA joined 28 other organizations in urging House Ways and Means Committee members to support tax incentives for retirement savings. The statement was provided in advance of the committee’s April 17 hearing on the retirement savings incentives. [letter]

On January 23, 2012, NTSAA and ASPPA submitted comments to the Internal Revenue Service in support of the inclusion of 403(b) plans in the prototype program for pre-approved plan documents. IRS officials have recently indicated that budget concerns may result in a reexamination of whether to include 403(b) plan documents in the pre-approved plan program. NTSAA and ASPPA believe that a prototype program for 403(b) plans is essential for the proper administration of the tax laws and that it would be a mistake to abandon this integral component of 403(b) compliance. [Comment]

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