4 pages. Excerpt: [W]e respectfully request that the period to bring plan documents into compliance with Section 409A be extended until December 31, 2008. We further request that all transition relief currently scheduled to expire on December 31, 2007 (including the 'reasonable good faith compliance' standard for plan operation) be extended until December 31, 2008 and that the date of the applicability of the final regulations be changed to January 1, 2009.... [W]e urge you to solicit practitioner input on ways for employers to comply on a simplified and bulk basis ... and to develop a voluntary correction program for inadvertent Section 409A violations.

MORE >>