Using comment letters and testimony, ASPPA Government Affairs responds to new legislation, proposed changes to existing regulations, and proposed new regulations. Any action that would change existing pension policy or affect the work of pension professionals is the object of ASPPA comments from Government Affairs. In its role of closely monitoring legislative and regulatory actions, ASPPA Government Affairs directs its comments and testimony to appropriate agencies, clearly reflecting the stance of ASPPA and its members. 


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On January 23, 2012, NTSAA and ASPPA submitted comments to the Internal Revenue Service in support of the inclusion of 403(b) plans in the prototype program for pre-approved plan documents. IRS officials have recently indicated that budget concerns may result in a reexamination of whether to include 403(b) plan documents in the pre-approved plan program. NTSAA and ASPPA believe that a prototype program for 403(b) plans is essential for the proper administration of the tax laws and that it would be a mistake to abandon this integral component of 403(b) compliance.  [Comment]

On December 30, 2011, ASPPA and ACOPA submitted comments to the Pension Benefit Guaranty Corporation (PBGC) providing comments on the proposed rule relating to benefit determinations and plan valuations for statutory hybrid plans. ASPPA and ACOPA recommended that: (1) proposed regulations regarding §4022 be temporary, effective only for plan terminations occurring before the effective date of final Treasury regulations regarding market rate of return; and (2) PBGC should re-propose these rules in a manner that is consistent with the final Treasury regulations after the final market rate of return regulations are issued.[Comment]

On December 20, 2011, ASPPA submitted comments to the Internal Revenue Service requesting clarification of the notice requirement with respect to separated participants who are listed on IRS Form 8955-SSA and its predecessor, Schedule SSA to Form 5500. [Comment]