"[The proposed reg] provides that a good faith determination by the employer will be given deference... It would be helpful to also include a provision that a state or local law establishing a normal retirement age will also be given deference, assuming the law is reasonable under the facts and circumstances and is otherwise consistent with pre-ERISA vesting.... We believe it would be helpful if the preamble to the final regulations noted that these regulations do not affect the application of the 10% penalty rules contained in Code Section 72(t)."  MORE >>