The American Retirement Association wrote to the Department of Labor in response to the request for comments on the proposed guidance for payroll deduction IRA programs offered by states and to request a public hearing be held on the proposal. In the letter, the American Retirement Association recommended that the non-ERISA safe harbor under the proposed rule be expanded to apply to comparable payroll deduction programs established and administered by private sector providers and that the safe harbor be available to any payroll deduction IRA program without regard to whether it is mandated by a state law.