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American Retirement Association Comment Letter to IRS on Changes to Determination Letter Program (PDF)
American Retirement Association [ARA] 
[Opinion] Oct. 2, 2015
12 pages. "ARA understands the resource concerns faced by the IRS and has been actively involved with the IRS in discussions to improve both the [determination letter (DL)] program and the pre-approved plan program. Our comments below are made with the expectation the IRS will continue to work with the practitioner community to improve both of these programs.... This comment letter primarily focuses on the changes made to the DL program for individually designed plans ... This letter first addresses the questions posed by the IRS. The answers to many of these questions are inherently tied to other issues under consideration by the IRS."
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