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...
On May 31, the ARA submitted comments to the IRS providing input on the retirement benefits items included in the 2024-2025 Priority Guidance Plan. Specifically, the ARA requested the IRS to issue guidance on several SECURE and SECURE 2.0 Act to provide much needed clarity on catch-up contributions, automatic enrollment, top heavy exemptions, long-term part-time...
On February 20, 2024, the American Retirement Association submitted a comment letter in response to Notice 2024-02 asking the IRS to provide guidance on the eligible automatic enrollment arrangement (EACA) mandate, permit de minimis financial incentives for all employees who make deferral elections (regardless of whether they have a deferral election already have a deferral...
On December 15, 2023, the American Retirement Association submitted comments to the Internal Revenue Service requesting that they formally revoke Section 4 of the Ruling. Revocation of Section 4 will help advance SECURE 2.0’s policy objectives, facilitate compliance with long-term, part-time employee rules, and improve economic efficiency by reducing the complexity and burdens of the...
On October 24, 2023, the American Retirement Association wrote to the Internal Revenue Service to comment on Notice 2023-62 that granted a two-year transition period to comply with Section 603 of the SECURE 2.0 Act. (more…)
On October 10, 2023, the American Retirement Association wrote to the Department of Labor and answered questions relating to various provisions of the SECURE 2.0 Act that impact the reporting and disclosure framework of the Employee Retirement Income Security Act (ERISA). (more…)
On August 23, 2023, the American Retirement Association wrote to the Internal Revenue Service to provide comments on the expansion of the Employee Plan Compliance Resolution System (EPCRS) included in Section 305 of the SECURE 2.0 Act. (more…)
On July 19, 2023, the American Retirement Association and 49 other organizations wrote to the Internal Revenue Service and the Treasury Department to ask them to grant transition relief for two years from the Roth catch-up contribution requirements under Section 603 of the SECURE 2.0 Act. (more…)
On June 29, 2023, the American Retirement Association, along with over 200 other stakeholder organizations, wrote to Reps. Jason Smith (R-MO, 8th) and Richard Neal (D-MA, 1st), Chair and Ranking Member of the House Ways and Means Committee, and Senators Ron Wyden (D-OR) and Mike Crapo (R-ID), Chair and Ranking Member of the Senate Finance...
On November 17, 2022, the American Retirement Association, along with 60 other stakeholder organizations, wrote to the Democratic and Republican Congressional Leadership urging quick enactment of the compilation of retirement provisions known as SECURE 2.0. (more…)
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