ICI Draft Recommendations for 2018-2019 Treasury/IRS Priority Guidance Plan -- Retirement Plan Items
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June 5, 2018 TO: Pension CommitteePension Operations Advisory Committee RE: ICI Draft Recommendations for 2018-2019 Treasury/IRS Priority Guidance Plan -- Retirement Plan Items
Notice 2018-43 invites public comment on recommendations for Treasury’s 2018-2019 Priority Guidance Plan.[1] The Institute plans to submit a letter recommending retirement plan items to be included on the list by the Notice’s deadline of June 15, 2018.
Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2018-2019 Priority Guidance Plan, all of which we requested in prior letters to the IRS and Treasury.[2] These include additional guidance on 403(b) plan terminations and additional guidance relating to the one-per-year limit on IRA rollovers. Specifically, the letter recommends that IRS issue guidance regarding waivers of inadvertent violations of the one-per-year limit on IRA rollovers in circumstances where the inadvertent violations are beyond the control of the IRA holder. In addition, our letter requests changes to the Employee Plans Compliance Resolution System to allow self-correction of plan loan errors and missed required minimum distributions and to expand the program to allow correction of certain IRA errors.
Please let us know if you have comments on the draft letter. The draft letter includes only retirement security items; the Institute will submit a separate letter with recommendations regarding regulated investment companies. If you have any comments on the draft, please contact Elena Chism at 202/326-5821 (elena.chism@ici.org) by close of business on Tuesday, June 12, 2018.
Elena Barone Chism
Associate General Counsel - Retirement Policy
endnotes
[1] Notice 2018-43 is available at https://www.irs.gov/pub/irs-drop/n-18-43.pdf.
[2] For a copy of the Institute’s recommendations for the 2017-2018 Priority Guidance Plan, see ICI Memorandum No. 30726, dated June 2, 2017 available at https://www.ici.org/my_ici/memorandum/memo30726. The 2017-2018 Priority Guidance Plan is available at https://www.irs.gov/pub/irs-utl/2017-2018_pgp_3rd_quarter_update.pdf (items related to retirement benefits appear on pages 10-13).