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U.S. Chamber of Commerce Comment Letter to IRS on Proposed Transitional Rules for Hybrid Retirement Plans (PDF)
U.S. Chamber of Commerce Link to more items from this source
[Opinion]
Dec. 19, 2014

"The proposed rule allows plan sponsors to fix only the piece of the interest credit that is not in compliance. However, changing just that single piece could change the overall impact or effect a plan sponsor may have been trying to reach.... Rather than requiring [Pension Equity Plans (PEPs)] to use administrative and financial resources to engage in a two-step process, we recommend that the transitional rules for PEPs not apply until further guidance specifically for these plans are issued.... The proposed rule is to take effect on the date that that a transition rule is published. Treasury and the IRS did not consider legally feasible alternative compliance schedules, such as 6, 12, 18 or 24 months after final rule publication."

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