Nicholas Pension Consultants
Plumbers Local Union No. 1 Benefit Funds
Retirement Plan Consultants
Farmer & Betts, Inc.
EPIC Retirement Plan Services
Loren D. Stark Company
Pension Rights Center
Pension Plan Specialists
RTD Financial Advisors
Kentucky Trust Company
Retirement Industry Trust Association (RITA)
Hochheiser Deutsch & Co, Inc.
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|Groom Law Group Comment Letter to IRS on Curtailment of the Determination Letter Program (PDF)|
Groom Law Group
Oct. 6, 2015
11 pages. "The elimination of the existing DL Program for individually designed retirement plans undermines the current retirement system by negatively impacting plan participants and unduly burdening employers and plan administrators. Since DLs were first issued some 70 years ago, an entire framework has been established that relies on the IRS determination letter as prima facie evidence of a plan's qualified status. Many thousands of transactions that effectively rely on a plan's determination letter occur every single day ... Undermining this system by eliminating the periodic determination letters for individually designed plans will harm participants, whose rollover contributions can no longer be processed as efficiently (or perhaps participant bankruptcies and other efforts to reach benefits protected by the anti- assignment rule."
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