"The ARA generally agrees with and supports the Department's proposal and the underlying goal of expanding coverage. We are concerned, however, that the proposed rule creates different standards for payroll deduction IRA Programs administered by a state and those administered by private sector providers outside of a state program. Furthermore, we believe the lack of a private sector alternative operating alongside the various state programs would be contrary to the overall objective of increasing access to workplace retirement savings programs. This would be to the detriment of improving retirement security for American workers."

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