Regional Vice President of Sales The Retirement Plan Company
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Loan & Distribution Specialist AimPoint Pension
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Compass
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Bates & Company, Inc.
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AimPoint Pension
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ASPPA Comment Letter to IRS on Additional Alternatives for Satisfying Nondiscrimination Testing on a Benefits Basis for a DB/DC Plan (PDF)
American Society of Pension Professionals & Actuaries [ASPPA] [Opinion] Mar. 5, 2014
"In situations where the 'primarily DB' or 'broadly available' criteria of 1.401(a)(4)-9(b)(2)(v)(B) or (C) are not met, the current gateway structure of 1.401(a)(4)-9(b)(2)(v)(D) has allowed for flexibility in design, while providing meaningful benefits for non-highly compensated employees (NHCEs). The gateway regulations have served the purpose they were intended to serve, and the gateway structure should be preserved. However, permitting more flexibility in meeting the gateways could be helpful in improving plan design and retirement security for NHCEs through incenting employers to maintain defined benefit plans."
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