Compass
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Bates & Company, Inc.
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Loan & Distribution Specialist AimPoint Pension
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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AimPoint Pension
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Regional Vice President of Sales The Retirement Plan Company
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Text of Group Letter from 15 Associations to DOL Protesting Brokerage Window FAQ in FAB 2012-02 (PDF)
American Benefits Council and 15 Other Trade Associations [Opinion] June 25, 2012 7 pages. "[The authors] believe the positions set forth in Question and Answer 30 ... have potentially enormous costs and adverse effects on the retirement plan system -- costs and impacts that we believe need to be further developed and considered as part of a public notice and comment process.... [T]he Administrative Procedure Act, Executive Orders 12866 and 13610, as well as the guidance in OMB's Good Guidance Practices Bulletin, require that the Department withdraw the answer to Q&A-30. To the extent that the Department believes that the position set forth in Q&A-30 continues to deserve consideration, it should propose the guidance, in conjunction with a cost/benefit analysis, and invite public comment as is required for any 'supplement' to a regulation." |
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