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The American Retirement Association: A New Name for an Expanding Mission

"For nearly half a century, the American Society of Pension Professionals and Actuaries (ASPPA) and its affiliated organizations have been working for America's retirement. As of today, it does so under a new name as broad and expansive as the members it represents: the American Retirement Association.... [T]he American Retirement Association is a nonprofit professional organization with two major goals: to educate all retirement plan and benefits professionals, and to create a framework of policy that gives every working American the ability to have a comfortable retirement.... The American Retirement Association is composed of four premier retirement industry associations: [1] the American Society of Pension Professionals & Actuaries (ASPPA); [2] the ASPPA College of Pension Actuaries (ACOPA) ; [3] the National Association of Plan Advisors (NAPA); and [4] the National Tax-deferred Savings Association (NTSA)"

American Retirement Association Comment Letter to EBSA on Proposed Revisions to Form 5500 (PDF)

"ARA recommends that the public comment period be extended by 105 days to January 17, 2017.... ARA recommends that additional time be provided to transition into the significant technology changes the Proposal will require and that the effective date should be deferred to allow for consideration of public comment as to ways information can be collected in a less costly and burdensome manner.... ARA recommends that the Agencies hold a public hearing on the Proposal."

American Retirement Association Comments to EBSA on Proposed Regs for Savings Arrangements Established by States for Non-Governmental Employees (PDF)

"The ARA generally agrees with and supports the Department's proposal and the underlying goal of expanding coverage. We are concerned, however, that the proposed rule creates different standards for payroll deduction IRA Programs administered by a state and those administered by private sector providers outside of a state program. Furthermore, we believe the lack of a private sector alternative operating alongside the various state programs would be contrary to the overall objective of increasing access to workplace retirement savings programs. This would be to the detriment of improving retirement security for American workers."

American Retirement Association Asks IRS for More Time on LTPTE Rule

"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."

American Retirement Association Comment Letter to EBSA on Proposed Amendment to the QPAM Exemption (PDF)

"[ARA recommends] that the Department: [1] Modify the exclusive authority condition of the proposed amendment to Section I(c) of the QPAM Exemption so as not to preclude routine business interactions. [2] Modify the conditions of the one-year winding down period of proposed new Section I(j) so as not to preclude new transactions in existing accounts which are required for a prudent winding down process. [3] Provide at least 18 months for QPAMs, plan sponsors, and other parties-in-interest to come into compliance with the conditions of an amended QPAM Exemption."

American Retirement Association Letter to IRS Recommending Changes to Pre-Approved Plan Programs (PDF)

"In an effort to further enhance the effectiveness of the current pre-approved plan programs, the ARA recommends: [1] The establishment of a single, streamlined revenue procedure that covers both 401(a) qualified plans and 403(b) plans ... eliminating distinctions (substantive, procedural and terminology) currently associated with 'M&P' and 'volume submitter' plans. [2] Specific enhancements to improve and expand the availability of pre-approved plans in light of the changes to the determination letter program for individually designed plans. [3] An initial restatement period of three years for employers adopting pre-approved 403(b) plans. [4] The addition of 457(b) plans to the pre-approved plan program."

American Retirement Association Letter to IRS Requesting Meeting on Revised 5500 Compliance Questions/Instructions (PDF)

American Retirement Association Comment Letter to IRS on Changes to Determination Letter Program (PDF)

12 pages. "ARA understands the resource concerns faced by the IRS and has been actively involved with the IRS in discussions to improve both the [determination letter (DL)] program and the pre-approved plan program. Our comments below are made with the expectation the IRS will continue to work with the practitioner community to improve both of these programs.... This comment letter primarily focuses on the changes made to the DL program for individually designed plans ... This letter first addresses the questions posed by the IRS. The answers to many of these questions are inherently tied to other issues under consideration by the IRS."

Comments of American Retirement Association to DOL on Guidance Issues Under the SECURE Act (PDF)

Topics include: [1] Multiple Employer Plans; Pooled Employer Plans; [2] Fiduciary safe harbor for selection of lifetime income provider; [3] Disclosure regarding lifetime income; [4] Combined annual report for Group of Plans; [5] Inclusion of long-term part-time employees.

American Retirement Association Comment Letter to IRS Requesting Meeting Relating to Section 401(k) Hardship Regs (PDF)

"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."