DOL Proposed Rule on Auto-IRAs Established by Municipalities for Private-Sector Workers - Draft Comment Letter
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September 23, 2016
TO: PENSION COMMITTEE No. 6-16PENSION OPERATIONS ADVISORY COMMITTEE No. 5-16 RE: DOL PROPOSED RULE ON AUTO-IRAs ESTABLISHED BY MUNICIPALITIES FOR PRIVATE-SECTOR WORKERS - DRAFT COMMENT LETTER
Attached for your review and comment is a draft letter to the Department of Labor responding to the proposal regarding payroll-deduction IRA programs established by state political subdivisions (i.e., cities and counties) for private-sector workers.[1] The proposal would extend the newly final safe harbor rule for state-run payroll-deduction IRA programs[2] to political subdivisions of states, so that such programs would not be considered employee benefit plans under ERISA.
The draft letter incorporates by reference our January 19, 2016 comment letter on the state-run auto-IRA proposal.[3] To view the January letter, please click here.
Please let us know if you have any comments or suggestions on the draft by Noon E.T. on Wednesday, September 28. The deadline for comments to the Department of Labor is September 29, 2016.
Elena Barone Chism
Associate General Counsel
endnotes
[1] For a description of the proposal, see Memorandum to Pension Members No. 24-16 and Bank, Trust and Retirement Advisory Committee No. 30-16 [30172], dated August 25, 2016. The proposal is available here: https://www.gpo.gov/fdsys/pkg/FR-2016-08-30/pdf/2016-20638.pdf.
[2] For a description of the final rule, see Memorandum to Pension Members No. 24-16 and Bank, Trust and Retirement Advisory Committee No. 30-16 [30172], dated August 25, 2016. The final rule is available here: https://www.gpo.gov/fdsys/pkg/FR-2016-08-30/pdf/2016-20639.pdf.
[3] See Memorandum to Pension Members No. 2-16 [29661], dated January 21, 2016.