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American Benefits Council Comment Letter to Oregon State Treasury on Oregon Retirement Savings Plan (PDF)
American Benefits Council
[Opinion] Feb. 23, 2017
22 pages. "[T]he revised proposed rules would cause the [Oregon Retirement Savings Plan (ORSP)] to significantly disrupt existing Qualified Plans and their participants by effectively dictating the design of retirement plans that already meet the numerous and stringent requirements imposed by federal law. Although it has since been communicated that this was not the intent of the new language, this situation only highlights the importance of the Board examining how the ORSP could affect our current retirement system and avoiding any adverse effects on employers who currently sponsor a retirement plan. The only way to ensure that correct result is for the ORSP to permanently exempt all current plan sponsors from the Plan's requirements in accordance with Oregon's authorizing legislation."
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