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Comment Letter by NCTR, NASRA and NCPERS to IRS on Proposed Regs under Section 415 (PDF)
National Council on Teacher Retirement [NCTR], National Association of State Retirement Administrators [NASRA], National Conference of Public Employee Retirement System [NCPERS] 
July 27, 2005
7 pages. Excerpt: We would respectfully but strenuously urge consideration be given to extending the period for comments and delaying the public hearing on the proposed regulations until November or December so that affected plans can have sufficient time to review the proposals in depth, evaluate their impact on their particular circumstances, and prepare adequate responsive comments.
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