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National Federation of Independent Businesses Comment Letter to DOL on Proposed Regs on Association Retirement Plans and MEPs (PDF)
National Federation of Independent Businesses [NFIB] Link to more items from this source
[Opinion]
Dec. 17, 2018
17 pages. "NFIB continues to object to the control and commonality-of-interests tests as a misconstruction of section 3(5) of ERISA. The Department should revise its proposed rule ... to allow an association to demonstrate in ways other than 'control' that the association acts in the interest of the employers in the association and should recognize small business size as itself a commonality of interest."

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