"Thomas C. Nyhan, executive director and general counsel of the [Central States Pension Fund], challenged the [Treasury] department's conclusions that the multiemployer pension plan's proposal wasn't based on 'reasonable investment assumptions' and that its notices to participants weren't 'understandable to the average plan participant.'... The fund surveyed its participants and found that 73 percent of those responding said the information in the notices was 'clear and easy to understand,' he said. Nyhan said if 'Treasury had told us that they considered the notice to be unsatisfactory, we would have gladly mailed out a revised notice. It clearly didn't take Treasury 224 days to come to that conclusion.' "

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