ASPPA Responds to Treasury’s Regulatory Burden Request
Retirement Plan Professionals Offer Ideas to Streamline Regulations
ARLINGTON, VA, (April 29, 2011) – The following is a statement from Craig P. Hoffman, General Counsel and Director of Regulatory Affairs of The American Society of Pension Professionals & Actuaries (ASPPA) responding to the U.S. Department of Treasury request for information published in the Federal Register on March 30 on how Treasury can streamline or improve the agency’s existing regulations pursuant to President Obama’s Executive Order 13563.
“ASPPA applauds the U.S. Department of Treasury for undertaking this initiative and supports the agency’s efforts to create a regulatory system that both protects the public welfare and stimulates economic growth using the best tools to achieve those regulatory ends pursuant to President Obama’s Executive Order 13563.
In light of the Executive Order, we offer several recommendations on existing regulations to support innovation and reduce administrative burdens for the retirement plan system, including:
- Safe Harbor 401(k) Plans: We recommend that the regulations be expanded to permit mid-year changes to a safe harbor 401(k) plan as long as the change would not significantly impact a participant’s deferral decision in order to facilitate the use of safe harbor plans.
- Electronic Communications: Providing information to participants that is clear, readable and meets their needs helps participants understand their plans and make decisions in connection with them. Plans could maximize their efforts in communicating with participants if they were subject to only one set of regulations. We urge the Department to coordinate with the Department of Labor to create a unified approach for electronic disclosures for retirement plans.
- Interim Amendments: The current amendment process is incredibly complicated, with different amendment deadlines that vary based upon the type of amendment and the plan’s fiscal year. This leads to inadvertent mistakes being made by well-meaning plan sponsors. To minimize this problem, we ask that interim amendments should only be required once every three years.
For more detail on these recommendations and others, please see ASPPA’s comment letter filed with the Department of Treasury today. We look forward to the future release of the Department’s preliminary plan which outlines what regulations will be considered for review to reduce the regulatory burden.”
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About ASPPA: The American Society of Pension Professionals & Actuaries (ASPPA) is a national organization of more than 7,500 retirement plan and benefits professionals that serves as the educator, voice, and advocate for the employer-based retirement system. ASPPA members are administrators, actuaries, advisors, attorneys, accountants, and other financial services professionals who provide consulting and administrative services for qualified retirement plans.
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