Pension Issues

Policy Accomplishments for 2007

• Defeated attempts to impose an annual limit on nonqualified deferred compensation.
• Successfully lobbied the Treasury Department to delay the effective date of final regulations under Code Section 409A.

• Successful in urging DOE to withdraw a proposal that would eliminate the reimbursement of costs associated with pension and medical benefits for employees of a company's contractors.

• Successfully urged IRS and Treasury to reconsider an IRS interpretation that certain cash balance plan conversions violated the anti-backloading provisions in ERISA. Treasury Department said that it is reviewing the issue and intends to issue guidance in the near future.

• Actively participating in the regulatory process to ensure that the provisions of the Pension Protection Act of 2006 are effectively and efficiently implemented. Submitted comments on the following:
  • Benefit Limitations
  • Annuity Provider Selection
  • Mortality Tables
  • Qualified Domestic Relations Orders
  • Cash Balance Plans
  • Phased Retirement
  • Stock Diversification Notices
  • Qualified Default Investments