ARA Comment Letter on Amending Safe Harbor Plans

[austin3515]

I don't understand this letter so I hope someone can tell me what I am missing. The new rules regarding amendmending safe harbors expressly allow you to amend for ANYTHING except the 4 expressly prohibited amendments.  Why are they asking the IRS to approve certain other amendments when there is nothing prohibiting those amendments?

 

http://www.asppa.org/Portals/2/PDFs/GAC/Comment Letter/final170606_Safe_Harbor_Mid_Year_CL.pdf

[Kevin C]

You are not missing anything.  I agree with one of my co-workers who pointed out that controversy fills conference seats.

[RatherBeGolfing]

The devil is in the details.  At least one of the points in the letter was discussed at the ASPPA Annual IRS Q&A last year where the ASPPA panel felt the change did not fall under the 4 prohibited amendments and the IRS disagreed.  Asking for clarity and / or different wording is important.  

As for controversy, I think they have all they need with the Fiduciary rule and MEPs