Comments & Letters
PRC Responds to Multi-Agency Request for Information on Reporting and Disclosure
The Pension Rights Center issued comments on May 22nd in response to a Request for Information from the Department of the Treasury, the IRS, the DOL, EBSA, and the PBGC on Section 319 of SECURE 2.0.
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.
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.
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.
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.
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 […]
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 […]
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:
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 […]
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.
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.
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 […]
