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ERIC Comment Letter to IRS on Notice 2014-5, Nondiscrimination Relief for Closed Defined Benefit Plans (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] Mar. 2, 2014
"The Agencies should issue guidance to provide plans with permanent relief as soon as possible. Additional relief should be provided with respect to benefits, rights and features. The Agencies should provide soft frozen defined benefit plans with additional options to satisfy the nondiscrimination requirements. Defined contribution plans that provide enhanced benefits to former defined benefit plan participants should be provided with additional options for satisfying the nondiscrimination requirements. Contributory plans that otherwise satisfy the nondiscrimination requirements should not be considered discriminatory merely because some highly compensated employees contribute more than some non-highly compensated employees."
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