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American Academy of Actuaries Comment Letter to IRS on Proposed Form Relating to the Annual Certification for Multiemployer DB Plans (PDF)
American Academy of Actuaries 
[Opinion] Aug. 25, 2020 "We agree with the agency's estimate of the burden of 45 minutes per plan to complete the form.... We do not believe the proposed form would enhance quality given the very limited information collected. However, the utility and clarity may be enhanced given the ease of use with the electronic submission, which should reduce the possibility of data entry error." |
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