"The proposed DOL regulation, if finalized in its current form, will undermine California's current statute which uses formula-based, cash balance-style accounts for the Golden State's private sector retirement savings program. The DOL's proposed regulation requires that participants in state-sponsored retirement savings programs possess the same unrestricted right to withdraw their retirement savings as IRA participants possess. This unrestricted right of withdrawal will create the possibility of a 'run on the bank' if the assets in the proposed California state retirement plan are insufficient to pay larger formula-based claims established by the California statute."

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