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American Retirement Association Comment Letter to IRS Requesting Meeting Relating to Section 401(k) Hardship Regs (PDF)
American Retirement Association [ARA]
[Opinion] Oct. 10, 2019 "Sponsors of individually designed plans have two years from the publication of the Required Amendments List to adopt a conforming amendment. Imposing a substantially shorter deadline for adopters of pre-approved plans may undercut IRS' goal of fostering compliance within the retirement industry.... This is extremely problematic for plan document providers who must implement the underlying systems, delivery, and communications of the amendments. This interim amendment cannot simply be adopted by the volume submitter practitioner or prototype sponsoring organization because adopting employers have many options available to them." MORE >> |
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