CBF Joint Letter to Treasury and Internal Revenue Service on Issuing Proposed Regulations Providing Nondiscrimination Relief for Closed Defined Benefit Plans

CC:PA:LPD:PR (REG-125761-14)
Room 5203
Internal Revenue Service
POB 7604
Ben Franklin Station
Washington, DC 20044

Dear Sir or Madam,

The undersigned organizations would like to thank Treasury and the Internal Revenue Service (IRS)for issuing proposed regulations providing nondiscrimination relief for closed defined benefit plans. We believe the proposed regulations are a tremendous first step in addressing concerns as companies modify plans to meet the needs of the workforce and businesses. Acknowledging that these are complex rules and every DB plan has a specific plan structure and will need to review and assess these rules individually, the following is provided to highlight key areas that we believe need to be considered or addressed. Furthermore, we commend you for withdrawing the Qualified Supplemental Executive Retirement Plans provisions from the proposed defined benefit (DB) nondiscrimination relief.

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