11 pages. "Thank you for arranging the meeting with you and your staff and representatives of the [IRS] to discuss issues that have arisen regarding how to apply the anti-backloading rules of section 411 of the Internal Revenue Code, particularly to cash balance plans. We are writing in response to your request for concrete proposals to address the application of the anti-backloading rules to 'greater of' formulas used in cash balance conversions."  MORE >>