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One Bad Apple Won't Spoil the Pie: New MEP Rules Proposed
Cohen & Buckmann, P.C. 
[Guidance Overview] July 8, 2019 "Hopefully, the final regulations will simplify the required procedures and clarify the extent to which ... the procedures may be applied to pre-existing qualification violations. There is also a question whether, in the absence of a statutory exception to the 'one bad apple' rule, regulations alone can override the general statutory requirement to treat the MEP as a unified plan, or whether a statutory amendment of the type that would be made by the SECURE Act is required." |
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