[12032]
June 20, 2000
TO: PENSION COMMITTEE No. 42-00
PENSION OPERATIONS ADVISORY COMMITTEE No. 43-00
PARTICIPANTS IN MAY 4TH AND JUNE 12TH CONFERENCE CALLS
RE: REVISED DRAFT COMMENT LETTER ON PROPOSED SECTION 411(D)(6)
RELIEF
Attached is a revised draft of the Institute’s comment letter on the Internal Revenue Service’s
proposed regulations providing special rules under section 411(d)(6) to permit the elimination of certain
extended distribution forms offered in a defined contribution plan and other relief. The draft letter has
been revised to respond to issues raised on a June 12 conference call.
In general, we have tried to strengthen the argument that the relief should require only that a plan
offer a lump sum distribution option and not be required to retain any extended distribution form at all.
We have redrafted section II addressing individuals near retirement to state that no special protections are
needed for these individuals when extended distribution forms are eliminated, because given a lump sum
distribution option, they can easily replicate any eliminated distribution form. Responding to discussion
on June 12, we also have eliminated the section addressing elective transfers. Finally, we have made
numerous technical and editing changes throughout, including clarifying that the section on in-kind
securities addresses an issue raised by the examples in the proposed regulation, not a requirement
proposed in the body of the regulation.
Please review this final, revised draft and provide comments to me by Friday morning, June 23.
The letter must be filed on June 27. You can provide me with comments by telephone at (202) 326-5835,
fax at (202) 326-5841, or e-mail at rgaler@ici.org.
Russell G. Galer
Senior Counsel
Attachment
Attachment (in .pdf format)