Comments & Letters
Comments to the Department of Labor on Proposed Exemption Involving Retirement Clearinghouse, LLC
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. The application for the exemption was submitted by the Retirement Clearinghouse, LLC (RCH) to permit the imposition of a fee to certain participant […]
Comments to the Joint Select Committee on Solvency of Multiemployer Pension Plans
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 […]
PRC letters in support of multiemployer legislation introduced by Senator Sherrod Brown (D-OH) and Congressman Richard Neal (D-MA)
The Pension Rights Center sent a letter to U.S. Senator Sherrod Brown (D-OH), expressing its support for the Butch Lewis Act of 2017. Read the letter here [PDF]. The Pension Rights Center sent a letter to Representative Richard Neal (D-MA), expressing its support for the Rehabilitation of Multiemployer Pensions Act of 2017. Read the letter […]
Comments on 2017 Draft Instructions for Form 8955-SSA
The Pension Rights Center submitted comments to the Internal Revenue Service on the draft Instructions for Form 8955-SSA. The comments emphasized the importance of deferred vested statements to participants. The statements are based on information reported on Form 8955-SSA. The Center urged the IRS to reject earlier guidance that permitted plans to give less comprehensive […]
Letter to U.S. Senate on Congressional Review Act resolutions to overturn the Department of Labor rule on “Savings Arrangements Established by States for Non-Governmental Employees”
The Pension Rights Center sent a letter to key leadership in the U.S. Senate urging senators to vote against two resolutions that would overturn the common-sense rule issued by the Department of Labor in 2016 to expand retirement savings opportunities for private-sector workers who are not covered by an employer-sponsored retirement plan, such as a traditional […]
Letter to U.S. House of Representatives leadership urging a “no” vote on the Congressional Review Act Resolutions to overturn the Department of Labor’s common sense rule on “Savings Arrangements Established by States for Non-Governmental Employees
The Pension Rights Center sent a letter to key leadership in the U.S. House of Representatives urging them to vote against two resolutions that would overturn the common-sense rule issued by the Department of Labor in 2016 to expand retirement savings opportunities for private-sector workers who are not covered by an employer-sponsored retirement plan, such […]
Comments to U.S. Department of Labor on the Proposed Revision of Annual Information Reports (December 5, 2016)
The Pension Rights Center submitted comments to the U.S. Department of Labor on its proposed revisions to the Form 5500, the form retirement plans use to report data to the federal government. The Center’s comments include recommendations that the Form 5500: Add questions concerning the default features of individual account plans; Clarify the definition of “active […]
Comments to the U.S. Treasury Department on the New York State Teamsters Conference Pension and Retirement Fund’s application to cut retiree benefits (December 21, 2016)
The Pension Rights Center submitted comments to the U.S. Treasury Department on the New York State Teamsters Conference Pension and Retirement Fund’s application to cut retiree benefits under the Multiemployer Pension Reform Act of 2016. In its comments, the Center urges the Treasury Department to reject the application because: The application fails to demonstrate that […]
Comments to Pension Benefit Guaranty Corporation on expansion of Missing Participants Program (November 21, 2016)
The Pension Rights Center submitted comments in response to the Pension Benefit Guaranty Corporation’s request for comments on the proposed expansion of its Missing Participants Program to include participants and beneficiaries in terminating defined contribution plans, multiemployer plans and small professional service plans.
Pension Rights Center comments to Treasury Department on Iron Workers Local 17 Pension Plan’s application to cut retiree benefits (October 14, 2016)
The Pension Rights Center submitted comments to the Treasury Department regarding the Iron Workers Local 17 Pension Plan’s application to cut retiree benefits under the Multiemployer Pension Reform Act of 2014. In its comments, the Center urges Treasury to reject the Iron Workers Local 17 application because: The application does not demonstrate that the proposed […]
Joint letter to Congress on threats posed by proposed “composite” multiemployer pension plans (September 8, 2016)
the Pension Rights Center joined with retiree and labor organizations by sending a letter to the U.S. House of Representatives expressing extreme opposition to draft legislation that would create a new type of pension plan called a “composite” multiemployer plan. This draft legislation would substantially weaken the funding status of currently-existing multiemployer plans, putting at […]
PRC comments to Treasury on the Central States Pension Fund’s application to cut retiree benefits (December 10, 2015)
The Pension Rights Center submitted comments to the Treasury Department regarding the Central States Pension Fund’s (CSPF) application to cut retiree benefits under the Multiemployer Pension Reform Act of 2014. In its comments, the Center urges Treasury to reject CSPF’s application because The application fails to demonstrate that the plan took all reasonable steps to […]
