Comments & Letters
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 […]
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 […]
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 […]
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.
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.
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”).
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.
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.