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ERIC Comment Letter to New York City Council on Proposal for Mandatory Employer-Sponsored Retirement Program (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] Aug. 2, 2018
"[1] Defining employee with an age requirement of 18 years old is in direct contradiction of federal laws and regulations that allow an employer to wait until age 21 to allow an employee to enroll in the employer retirement plan. [2] Employers should be able to limit participation in an employer retirement plan to employees who do not exceed 1,000 hours in a year, in accordance with ERISA ... [3] The program should automatically exempt employers that provide a retirement plan to employees in accordance with ERISA."
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