3 pages. Excerpt: With regard to the proposed regulations, we are concerned that they could affect a wide variety of common practices that our members use to provide and protect on a nondiscriminatory basis the qualified retirement plan income of disabled employees. These practices include: the provision of continued employer-funded defined benefit pension accruals for employees on long-term disability, the provision of continued defined contribution plan accruals for employees on long-term disability - with funding from employer contributions, the purchase of a special long-term disability policy designed for DC plans, or from a companion welfare benefit trust.

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