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."  MORE >>