Specifically, ASPPA said the Department should combine and integrate required notices where possible, coordinate timing requirements so that participants do not receive multiple notices on various topics throughout the year, and coordinate with the U.S. Department of Labor to eliminate duplicative disclosures.
In a letter responding to the U.S. Department of Treasury request for information on how it can streamline or improve the agency’s existing regulations, Craig P. Hoffman, General Counsel and Director of Regulatory Affairs of ASPPA, also recommended that the Treasury work with the DoL to create a unified approach for electronic disclosures for retirement plans.
Other recommendations included;
- that mid-year changes to a safe harbor 401(k) plan be permitted (and updated notices provided), to the extent that the changes would not be expected to significantly impact a participant’s deferral decision;
- that all elections that affect the funding for a plan year be formalized in an attachment to the Schedule SB for the year and that elections regarding credit balances be permitted in all instances to specify a determinable formula in lieu of stating a specific dollar amount. ASPPA and the ASPPA College of Pension Actuaries (ACOPA) also recommend that the ability to make standing elections be expanded, so employers are not required to make the same election each and every plan year and that standing elections be permitted to be written in a manner so as to remain in force as long as the employer continues the business relationship with the individual or company named on the election, even in the event of a change in the individual actuary who prepares the Schedule SB for that plan; and
- that the interim amendments only be required once every three years.
The comment letter is here.