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American Retirement Association Asks IRS for More Time on LTPTE Rule
American Retirement Association [ARA] 
[Opinion] Nov. 30, 2023 "The ARA focused on three points in particular: [1] The interpretation of the vesting rule creates irreversible administrative complexities if the plan uses the LTPTE service rule; [2] Participants have entered the plan as LTPTEs in 2023, and therefore, the rule has retroactive consequences that cannot be reversed; and [3] Plan sponsors that would have LTPTEs entering for the first time in 2024 do not have sufficient time to respond by adjusting the plan design to avoid the irreversible administrative complexities introduced by the Proposed Regulation." |
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