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Chicago Bar Association Comments on Second IRS White Paper on Future of Determ. Letter Program (PDF)
Chicago Bar Association, Employee Benefits Committee
Oct. 8, 2003
10 pages. Excerpt: The Subcommittee believes that an annual update procedure would benefit plan sponsors.... Combining an annual update with a five-year filing cycle would help ensure regular, systematic review of all qualified plans and would put plan sponsors into the habit of keeping their plans in compliance.... [T]he cumulative burden on plan sponsors, such as that at the end of a remedial amendment period under the current system, would be greatly reduced.
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