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American Benefits Council Comment Letter to IRS on Proposed Regs for Use of Forfeitures in Qualified Retirement Plans
American Benefits Council Link to more items from this source
[Opinion]
June 1, 2023

"[M]ost defined contribution plan sponsors will use forfeitures to pay for administrative expenses or offset employer contributions. But if the forfeitures in any year are more than is required for administrative expenses or existing required employer contributions, the proposal is effectively requiring additional benefits. While that may be a noble public policy goal, and many employers will be comfortable providing additional benefits, there is nothing in the Code that imposes such a requirement. "

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