ARA Submits Letter on Guidance on Alternative Investments
On September 4, 2025, the American Retirement Association submitted a letter to the DOL regarding guidance on Alternative Investments. (more…)
ARA Submits Letter on the Executive Order, “Modernizing Payments To and From America’s Bank Account”
On June 30, 2025, the American Retirement Association submitted a letter in response to the U.S. Department of the Treasury’s Request for Information related to Executive Order 14247, “Modernizing Payments To and From America’s Bank Account. (more…)
ARA Submits Letter on Notice 2025-19, Recommendations on Items to be Included on the 2025-2026 Priority Guidance Plan
On May 30, 2025, the American Retirement Association submitted a letter in response to Internal Revenue Service Notice 2025-19 (the “Notice”) to provide input on the Retirement Benefits items (and the relative priority of such items) to be included on the 2025-2026 Priority Guidance Plan. (more…)
ARA Submits Letter in Support of H.R. 1013, the Retirement Fairness for Charities and Educational Institutions Act of 2025
On March 31, the American Retirement Association submitted a letter in support of the Retirement Fairness for Charities and Educational Institutions Act. This bill would amend federal securities laws to allow 403(b) plans to include Collective Investment Trusts (CITs) in their suite of investment options. This change would ensure that 403(b) participants have access to...
ARA Submits Comments on Automatic Enrollment Requirements
On March 17, the American Retirement Association submitted a letter to the Internal Revenue Service (IRS) recommending the Service provide additional guidance. Specifically, the ARA encouraged the IRS to amend the Proposed Rule to: (1) extend the deadline for post-transaction plan mergers beyond the end of the special transition period under IRC §410(b)(6)(C)(ii) for purposes...
ARA Submits Comments on Catch-Up Contributions
On March 14, the American Retirement Association submitted a letter to the Internal Revenue Service supporting the issuance of guidance on catch-up contributions. Specifically, the ARA supports guidance that would permit an employer that is part of a controlled group or affiliated service group to aggregate compensation across multiple entities for purposes of determining whether...
ARA Submits Comments on Notice 2024-73
On December 20, 2024, the American Retirement Association submitted a letter regarding Internal Revenue Service Notice 2024-73 (the “Notice”), which provides additional guidance with respect to long-term, part-time employee (LTPTE) rules, including guidance regarding the application of IRC § 403(b)(12) to LTPTEs under section 403(b) plans.in support of the Retirement Fairness for Charities and Educational...
ARA Submits Letter on Internal Revenue Service Notice 2024-77, with Respect to Inadvertent Benefit Overpayments
On December 16, 2024, the American Retirement Association submitted a comment letter on Internal Revenue Service Notice 2024-77 (the “Notice”), which provides guidance with respect to inadvertent benefit overpayments. (more…)
ARA Submits Comments on IRS Notice 2024-63
On October 18, the ARA submitted comments to the Internal Revenue Service (IRS) recommending the Service issue guidance on qualified student loan payments (QSLPs). Specifically, the ARA encouraged the IRS to allow for plans to calculate all matching contributions on a payroll period basis, confirm that a plan may match QSLPs throughout the year without...
ARA Submits Comments on IRS Notice 2024-55
On October 7, the ARA submitted comments to the Internal Revenue Service (IRS) recommending that the Service clarify recently issued guidance related to several provisions enacted by the SECURE 2.0 Act. Specifically, the ARA’s comments encouraged the Service to provide anti-cutback relief to permit the elimination of EPED and DAVD provisions, allow administrators to rely...