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ASPPA and ACOPA Comment Letter to IRS on Cash Balance Volume Submitter Provisions (PDF)
American Society of Pension Professionals & Actuaries [ASPPA]; ASPPA College of Pension Actuaries [ACOPA] 
[Opinion] June 23, 2014
"ASPPA and ACOPA recommend that the flexibility contained in traditional defined benefit volume submitter plans should also be available in cash balance volume submitter documents. This flexibility pertains to definitions of classes, formulas based on percentage of compensation or flat dollar credit per year of service and the lesser of these or net self-employment income."
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