The American Retirement Association wrote to the American Institute of Certified Public Accountants (AICPA) with recommendations to improve the Proposed Statement on Auditing Standards that would modify the auditing standards related to employee benefit plan subject to ERISA. The American Retirement Association recommended to eliminate the new public disclosure requirement, to retain the materiality threshold...
The American Retirement Association wrote to the Department of Labor to ask for an extension of the transition period and delay of the applicability date of the Fiduciary Regulation recommending a “tiered” approach to determine the applicability date for the delayed provisions of the Best Interest Contract Exemption, the Principal Transaction Exemption, and amendments to...
The American Retirement Association wrote to the Internal Revenue Service to request for relief for taxpayers and service providers adversely affected by Hurricane Harvey. Specifically, American Retirement Association asked for hardship distribution relief and Form 5500 filing deadline relief patterned on past IRS announcements in the wake of Hurricane Sandy in 2012. (more…)
The American Retirement Association wrote to the Department of Labor to respond to the Department’s Request for Information regarding the Fiduciary Rule and Prohibited Transaction Exemptions. In the letter, the American Retirement Association recommends a delay of the January 1, 2018 applicability date for certain provisions of the Best Interest Contract Exemption, the Principal Transaction...
The American Retirement Association wrote to the Department of Labor to request interpretative guidance with respect to the obligation of a covered service provider to disclose a change in the information required to be provided under ERISA Section 408(b)(2) resulting from the June 9, 2017 applicability date for the Fiduciary Rule and related prohibited transaction...
The American Retirement Association wrote to the Internal Revenue Service to recommend an order of priority for Retirement Benefit items to be included on the 2017-2018 Priority Guidance Plan in response to IRS Notice 2017-28. (more…)
The American Retirement Association wrote to the Internal Revenue Service to provide recommendations on mid-year safe harbor amendments in response to IRS Notice 2016-16. The American Retirement Association recommended that the guidance contained in IRS Notice 2016-16 be expanded further in six specific areas. (more…)
The American Retirement Association wrote to the Department of Labor to respond to a request for comment with respect to the Conflict of Interest Regulation and related exemptions. In the letter, the American Retirement Association recommended: 1) that the definition of Level Fee in the Best Interest Contract Exemption be clarified to permit a Level...
The Plan Sponsor Council of America wrote to both the Departments of Labor and Treasury to ask for additional guidance to address the various compliance issues that arise under ERISA and the tax code when there is a missing or nonresponsive participant and to propose a ten-step sample safe harbor program to satisfy those issues....
The American Retirement Association wrote to the Department of Labor to provide comments with respect to the proposed extension of the applicability date for the Conflict of Interest Regulation and related exemptions. The American Retirement Association recommended that the applicability date be delayed until January 1, 2018 and that transitional relief with regard to the...
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