Greenline Wealth Management
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Senior Specialist 401k Recordkeeping T Bank N.A.
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Great Lakes Pension Associates, Inc.
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Pollard & Associates
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TPA Retirement Plan Consultant EPIC RPS (TPA/DPS)
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New York City District Council of Carpenters Benefit Funds
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Defined Contributions Compliance Consultant Loren D. Stark Company (LDSCO)
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Retirement Solutions Specialists
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Fringe Benefit Group
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Defined Contribution Account Manager Nova 401(k) Associates
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Retirement Planners and Administrators (RPA)
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American Benefits Council Comment Letter to Treasury and IRS Requesting Guidance under Pension Funding Interest Rate Stabilization, Including Addressing Lump Sum Distributions (PDF)
American Benefits Council [Opinion] July 30, 2012
9 pages. "[O]ne issue dwarfs all others. It is critical that guidance from Treasury and the Service not undo substantially all the effects of funding stabilization for a very large number of plans by modifying the current-law regulatory rules for valuing lump sum distributions for funding purposes. In this regard, we ask for no guidance, since current law works very well. Any different guidance would have a devastating effect on companies across the country, as explained further below, and be directly inconsistent with [1] Congressional intent, [2] the principles underlying the Pension Protection Act of 2006 ... and [3] the principles underlying the final regulations."
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