Comments & Letters
02/16/24

SOR Coalition Opposes Appropriations Riders to Proposed Retirement Security Rule

The Save Our Retirement Coalition issued a letter voicing our opposition to appropriations riders that would prohibit the use of funds to finalize, implement, or enforce the Department of Labor’s (DOL) proposed Retirement Security Rule.

Comments & Letters
01/05/24

PRC Stands With Coalition To Urge DOL To Finalize Fiduciary Rule

The Pension Rights Center, alongside a group of over forty organizations and individuals, expressed strong support for the DOL’s Retirement Security Proposal, which would strengthen protections for retirees and workers who seek professional investment advice.  

Comments & Letters
01/04/24

PRC Advocates for Conflict-Free Investment Advice

The PRC expressed strong support in written comments for a proposed DOL rule that would ensure that investment professionals who give retirement-related financial advice do so in the best interests of workers and retirees. Read our full comments here.  

Comments & Letters
10/18/23

PRC Responds to DOL Request for Information on Reporting and Disclosure

The Pension Rights Center submitted comments on October 18th in response to a Request for Information concerning the Paper Statements provision of Secure 2.0. Read the PRC’s response to the Request for Information here and our comments on Subsection F here.

Comments & Letters
10/04/23

Senior Policy Counsel Norman Stein Testifies Before the ERISA Advisory Council

Norman Stein, PRC’s Senior Policy Counsel, and Anna-Marie Tabor, a visiting law professor at the University of Massachusetts School of Law and the former director of the Pension Action Center, testified before the Council about the risks posed by electronic recordkeeping and recommended stronger consumer protections including the creation of an electronic shoebox of relevant […]

Comments & Letters
07/24/23

Senior Policy Counsel Norman Stein Testifies Before the ERISA Advisory Council

As part of PRC’s efforts to advocate for stronger consumer protections for retirees, Stein entered a written statement and appeared before the Council on July 18, during a day-long meeting in which the Labor Department’s advisory body heard testimony on possible changes to DOL’s Interpretative Bulleting (IB) 95-1. Stein was joined by nearly two dozen […]

Comments & Letters
05/15/23

Senior Policy Consultant Norman Stein Testifies Before the IRS

PRC’s Senior Policy Consultant Norman Stein testified before the IRS and the Department of the Treasury on April 11th, urging them to take measures to protect spousal retirement rights. Read his testimony here:

Comments & Letters
03/31/23

PRC Comments to IRS on Physical Presence Requirements

The PRC filed comments with the IRS registering its strong disapproval of a proposed rule that would eliminate the long-standing requirement that a spouse can only sign away their right to a survivor’s benefit knowingly and voluntarily in the physical presence of a notary or plan official in order to safeguard against fraud and coercion […]

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 […]