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American Academy of Actuaries Comment Letter to IRS on Notice 2014-5, Nondiscrimination Relief for Closed Defined Benefit Plans (PDF)
American Academy of Actuaries Link to more items from this source
Mar. 2, 2014
"The regulations related to nondiscrimination testing are already extremely complex. Any changes should be made with an eye toward simplification. In general, we believe it is better to remove the restrictions that are causing problems, rather than to add new rules, unless those rules come in the form of additional safe harbors. In addition, it is important that changes be available to all plan sponsors and not just those in a particular market segment or those whose plans fit a particular fact pattern."

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