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Associations Representing State and Local Government Plans and Sponsors Comment Letter to IRS on Proposed Regs Defining 'Governmental Plan' (PDF)
National Conference on Public Employee Retirement Systems [NCPERS], with NAGDCA, NASRA, GFOA and NCTR 
[Opinion] June 19, 2012
"Given the vast and varying legal constructs of state and local governments and their agencies/instrumentalities throughout the country, the impact of the proposed definitions and requirements will differ from state to state, and entity to entity. However, 'safe harbors,' grandfathering treatment, and transition requirements will be paramount to ensuring the administrability [sic] of all governmental plans going forward."
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