Comments & Letters
01/23/23

PRC Comments on Proposed Amendment to Prohibited Transaction Exemption PTE 2002-51

The PRC submitted comments to EBSA on a proposed amendment to the Voluntary Fiduciary Correction Program for timely deposits of participant contributions into 401(k) plans that would establish a self-correction component for certain plans. To encourage employers to deposit contributions on time, we recommend keeping a three-year limitation period on frequency of using the program.

Comments & Letters
12/23/22

PRC Letter to IRS on Notice 2022-27, Physical Presence Requirement for Spousal Consents

The PRC sent a letter to the IRS urging the Service to protect spousal retirement rights by restoring its requirement that a spouse’s surrender of rights to retirement benefits must occur in the physical presence of a notary or plan administrator to ensure that the consent is executed without fraud, coercion, or duress.

Comments & Letters
08/11/22

PRC Recommendations to IRS on Agenda Items for the 2022-2023 IRS Priority Guidance Plan

The  Pension Rights Center submitted comments to  the  IRS requesting the  agency  to include in  its Priority Guidance Plan several items to  better  protect consumers,  including: (a)  directing  plans to provide  former employees  who leave before retirement  with  a single  complete  statement  of  their earned benefits ; (b) asking the agency to rethink its position on allowing plans […]

Comments & Letters
08/04/22

PRC letter to the IRS on OMB 1545–2187, Proposed Collection of Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits

The Pension Rights Center sent a letter to the IRS urging the Service to strengthen protections for “deferred vested” participants – those who have earned retirement benefits but have left their jobs before collecting benefits. The Center specifically asked the Service to change its guidance to require plan administrators to provide a single unified individual benefit statement […]

Comments & Letters
06/03/22

PRC letter to the Senate HELP Committee on the RISE & SHINE Act

The Pension Rights Center sent a letter to the Senate HELP Committee in support of specific consumer protections in the discussion draft of the Retirement Improvement and Savings Enhancement to Supplement Healthy Investments for the Nest Egg Act (RISE & SHINE Act), but expressed disappointment that the discussion draft bill does not include the critical […]

Comments & Letters
05/04/22

PRC, National Women’s Law Center, and WISER comments to the Federal Retirement Thrift Investment Board on new TSP recordkeeping system

PRC, National Women’s Law Center, and WISER offered comments on the Notice of Proposed Rulemaking issued by the Federal Retirement Thrift Investment Board and the ways in which the Thrift Savings Plan’s new recordkeeping system will impact the rights of participants and beneficiaries. Read the full comments here.

Comments & Letters
03/29/22

PRC letter to the Committee on Ways and Means in support of specific provisions of the Securing a Strong Retirement Act of 2022

PRC sent a letter to Chairman Neal and Ranking Member Brady of the House Ways and Means Committee in support of specific provisions of the Securing a Strong Retirement Act of 2022, including those related to recoupment and the Retirement Savings Lost and Found.

Comments & Letters
10/14/21

PRC and Covington & Burling LLP comments to IRS on Rev. Proc. 2021-30

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”).

Comments & Letters
09/30/21

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

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

Comments & Letters
08/13/21

PRC comments to the PBGC on interim multiemployer financial assistance guidance

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

Comments & Letters
05/28/21

Comments to the IRS on the 2021-2022 Priority Guidance Plan

PRC submitted comments to the IRS on the agency’s guidance agenda for the coming year.

Comments & Letters
05/10/21

PRC letter to the Committee on Ways and Means in support of the Securing a Strong Retirement Act of 2021

PRC sent a letter to Chairman Neal and Ranking Member Brady of the House Ways and Means Committee in support of the Securing a Strong Retirement Act of 2021, particularly the provisions that address issues related to recoupment and lost retirement plans.