PPA Diversification

[Randy Watson]

Under the new diversification rules (ignore the transition rules please) an employer can limit the times when divestment and reinvestment in employer securities occur, as long as reasonable opportunities occur at least quarterly. The catch is that employers can’t impose restrictions on employer securities that are not imposed on other investments “unless circumstances require different treatment.”

What kind of circumstances do you suppose they're talking about? I don't think we'll know for sure until additional guidance is issued, but I'd like to here comments. Thanks.

[Guest mjb]

restriction on purchase or sales by certain employees under the securities laws?

[Randy Watson]

I should clarify that I got that quote ("unless circumstances require a different approach") from the Technical Explanation for PPA prepared by the Joint Committee on Taxation. I read that to mean something other than securities law compliance (which is an exception). Think I'm reading into things too much?