Excerpt: RIC's comments address many specific concerns with the regulations, among them: The IRS's inappropriate use of the determination letter and audit programs to make major interpretations of the law governing hybrid plans; An extremely limited interpretation of the market rate of return requirement that would prohibit plan sponsors from offering generous interest crediting rates to participants; An overly broad definition of interest credits that could disallow many required and permissible credits for imputed service or for periods of disability and maternity leave; A inappropriate application of the special vesting rules to benefits determined under non-hybrid plan formulas resulting in faster vesting; and The exclusion limited applicability of the PPA's indexing rule that would disallow cash balance and pension equity plans from complying with the age discrimination test by meeting its requirements.  MORE >>