"[ICI suggests] eliminating the requirement to attach or otherwise include the financial institution's procedures for withdrawal and transfer on the form and summary description. Instead, guidance could state that the financial institution must identify on the form where procedures for withdrawal and transfer can be located.... [T]he IRS should reconsider the requirement for each financial institution to provide the employer with the summary description ... [ICI requests] guidance clarifying the circumstances under which a financial institution could stop sending annual summary descriptions."