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ASPPA and ACOPA Comment Letter to IRS on Determination Letter Rulings for Plan Amendments Under Code Section 412(d)(2) (PDF)
American Society of Pension Professionals & Actuaries [ASPPA]; ASPPA College of Pension Actuaries [ACOPA] 
[Opinion] June 10, 2014
"IRS ruling policy and, to the extent necessary, guidance (sub-regulatory or otherwise) should affirm the clear statutory language of IRC Section 412(d)(2) and Congressional authority to permit defined benefit plan sponsors to adopt retroactive 'discretionary' amendments.... The IRS should rebuild trust with the employee benefits plan community by engaging in dialogue, rather than using the threat of disqualification, as the vehicle to communicate a change in the Service's ruling policy."
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