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PRC and Covington & Burling LLP comments to IRS on Rev. Proc. 2021-30 (October 14, 2021)

Speech, Statement, Letter, or Comment

PRC submitted comments with Covington & Burling LLP to the IRS on Rev. Proc. 2021-30, which updated selected correction procedures for benefit overpayments under the Employee Plans Compliance Resolution System (“EPCRS”). Read the full comments here. 

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PRC Comments to the IRS on Notice 2021-40, Physical Presence Requirement for Spousal Consent

Speech, Statement, Letter, or Comment

 

PRC submitted comments to the IRS on Notice 2021-40, Physical Presence Requirement for Spousal Consent. Read the full comments here.
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PRC comments to the PBGC on interim multiemployer financial assistance guidance (August 10, 2021)

Speech, Statement, Letter, or Comment

PRC submitted comments to the Pension Benefit Guaranty Coorporation on the Interim Multiemployer Financial Assistance Regulation. Read the full comments here. 

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Comments to the IRS on the 2021-2022 Priority Guidance Plan (May 28, 2021)

Speech, Statement, Letter, or Comment

PRC submitted comments to the IRS on the agency's guidance agenda for the coming year. Read our comments here. 

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Comments to Department of Labor on proposed class exemption “Improving Advice for Workers and Retirees.” (August 6, 2020

Speech, Statement, Letter, or Comment

PRC submitted comments to the Department of Labor on proposed class exemption “Improving Advice for Workers and Retirees.” Read the full comments here. 

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PRC and National Women's Law Center comments on Federal Retirement Thrift Investment Board rule allowing withdrawal from TSPs without spousal consent (May 18, 2020)

Speech, Statement, Letter, or Comment

The Pension Rights Center and the National Women's Law Center submitted comments to the Federal Retirement Thrift Investment Board expressing concerns on an Interim Rule allowing federal retirees to withdraw their Thrift Savings Plan money without notarized spousal consent during the COVID-19 emergency.

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Comments to the US Treasury Department on the American Federation of Musicians & Employers Pension Fund's application to cut retiree benefits (March 2, 2020)

Speech, Statement, Letter, or Comment

The Pension Rights Center submitted comments to the U.S. Treasury Department on the American Federation of Musicians & Employers Pension Fund's application to cut retiree benefits under the Multiemployer Pension Reform Act of 2016.

Read the comments.

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Comments to the Department of Labor on proposed rule for default electronic disclosure (November 22, 2019)

Speech, Statement, Letter, or Comment

The Pension Rights Center submitted comments to the Department of Labor on proposed rule RIN 1210-AB90: Default Electronic Disclosure by Employee Pension Benefit Plans under ERISA. Read the full comments here. 

 

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Comments to the Department of Labor on Proposed Exemption Involving Retirement Clearinghouse, LLC

Speech, Statement, Letter, or Comment

On January 10, 2019 the Pension Rights Center submitted comments to the Employee Benefits Security Administration’s Office of Exempt Determinations (OED) concerning a proposed exemption to the prohibited transaction provisions of ERISA.

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Comments to the Joint Select Committee on Solvency of Multiemployer Pension Plans

Speech, Statement, Letter, or Comment

On September 30th, 2018, the Pension Rights Center submitted comments to the Joint Select Committee on Solvency of Multiemployer Pension Plans.The letter includes three sections:

1) An explanation of how this emerging crisis developed and a critique of MPRA, which reversed the key promise of ERISA: that a plan cannot take away benefits that employees and retirees have already earned.

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