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Comment Letter from SPARK and American Benefits Council on NTIS Proposed Regs for Certification Program for Access to the Death Master File (PDF)
American Benefits Council; The SPARK Institute [Opinion] Mar. 30, 2015
11 pages. "[The authors] remain very much concerned that the NPRM fails to address the critical need for a [death master file (DMF)] certification program that will allow parties to exchange recent death information in circumstances where there is no opportunity for abuse.... Our comments in this letter are intended to suggest clarifications and changes to the NPRM that would make the final rule more workable by providing for our members' continued use of Limited Access DMF for legitimate retirement plan administrative purposes without opening the door to the types of abuse that led to the ... implementation of a DMF certification program."
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