Retirement: Hybrid Plans
Legislative — proposals, bills and analysis from the 109th and 110th Congresses (2006-present)
Regulatory — administrative rules and information from U.S. offices and agencies
Judicial — current and past court cases and amicus briefs
Press Releases — Council statements and advisories to the news media
(Items in italic are available only to Council members.)
Official Source Documents
October 9, 2007 — Letter to U.S. Treasury Department from House of Representatives Members Regarding Backloading and Hybrid Plans
September 27, 2007 — Letter to U.S. Treasury Department from House Ways and Means Committee Members Regarding Backloading and Hybrid Plans
September 25, 2007 — "Dear Colleague" Letter from Ways and Means Committee Leaders Soliciting Signatures for Letter to U.S. Treasury Department Regarding Backloading and Hybrid Plans
September 24, 2007 — Letters from Treasury Department to Congress Regarding Backloading Issue and Hybrid Plans [to Grassley | to Enzi]
September 20, 2007 — Letter to U.S. Treasury Department from Additional Senators Regarding Backloading and Hybrid Plans
August 1, 2007 — Letter from Senators to Treasury Department on Application of PPA Whipsaw Distribution Rules
May 9, 2007 — Letter to U.S. Treasury Department from Senate HELP Committee Republicans Regarding Hybrid Plans
August 3, 2006 — Senate summary of HR 4
July 25, 2006 — New Miller Motion to Instruct Conferees on Pension Bill
July 20, 2006 — Text of House Debate on Rep. Miller's Motion to Instruct Conferees
July 20, 2006 — Miller Motion to Instruct Conferees on Hybrid Plans, Airline Pilots
April 6, 2006 — Motion to Instruct Pension Bill Conferees on Hybrid Plan Provisions
April 6, 2006 — Talking Points from Rep. George Miller on Motion to Instruct Conferees
March 27, 2006 — Letter from Senators Bond/Talent to Pension Bill Conferees on Hybrid Plans
March 21, 2006 — Senator Burr "Dear Colleague" Letter Regarding Hybrid Plan Provisions in Pension Bill
March 8, 2006 — Joint Committee on Tax side-by-side of pension bills
Council Materials
July 2, 2007 — ACTION ALERT: Calls to Congress needed, Treasury Department must reconsider backloading rules for participants' sake
June 13, 2007 — Group Letters to Congress Regarding "Greater-of" Backloading Issue
May 24, 2007 — Effect of IRS Backloading Interpretation on Both Hybrid and Traditional Plans
October 5, 2006 — Council Chart Comparing Defined Benefit Plan Funding and Hybrid Plan Issues to Current Law
July 24, 2006 — Letter to Congress concerning hybrid pension plans and pension reform legislation
July 20, 2006 — Council Letter to House Urging Rejection of Miller "Motion to Instruct"
July 12, 2006 — Model Letter to Senate on Hybrid Pension Plans
June 29, 2006 — ACTION ALERT: Calls to Republican conferees still needed: urge support of design-based approach to hybrid plans
June 29, 2006 — Model Letter for Companies to Congressional Offices on Hybrid Plan Provision in Pension Bill
April 6, 2006 — ACTION ALERT: Calls to House offices critically needed: urge rejection of Motion to Instruct Conferees
April 6, 2006 — Council Alert to House Offices on Hybrid Plans and Motion to Instruct Conferees
April 5, 2006 — ACTION ALERT: Urge Your Representatives: Reject Efforts to Limit Clarification of Hybrid Pension Plans in Pension Bill
March 29, 2006 — ACTION ALERT: Sign On to Business Community Letter to Conferees Urging Comprehensive Hybrid Plan Solution
March 29, 2006 — Business Community Letter to Conferees on Hybrid and Multiemployer Plans
March 21, 2006 — ACTION ALERT: Urge Republican Senators to sign on to "Dear Colleague" letter on hybrid plan reform
March 13, 2006 — ACTION ALERT: Contact retirement bill conferees, ask their support for a comprehensive, design-based approach to hybrid plans
March 13, 2006 — Council Talking Points: Final Retirement Legislation Should Include Comprehensive Clarification of the Validity of Hybrid Plans without Costly Mandates
January 31, 2006 — Council Issue Brief on Hybrid Plan Designs
January 30, 2006 — Side by Side Chart Comparing Hybrid Provisions of Retirement Bills (H.R. 2830/S. 1783), Administration Proposals and Current Law
Official Source Documents
October 28, 2011 — PBGC Proposed Regulations on Benefit Determinations and Plan Valuations for Statutory Hybrid Plans under PPA
October 12, 2011 — IRS Notice 2011-85: Guidance on Effective Dates for Hybrid Plan Regulations
October 5, 2011 — IRS Revenue Procedure 2011-49: Rulings and Determination Letters
October 18, 2010 — IRS Final Regulations on Hybrid Retirement Plans
October 18, 2010 — IRS Additional Proposed Regulations on Hybrid Retirement Plans
November 10, 2009 — IRS Announcement 2009-82: Hybrid Plan Guidance
June 17, 2008 — Proposed Treasury/IRS Regulations on Backloading/Accrual Rules to "Greater Of" Formulas
February 1, 2008 — IRS Revenue Ruling 2008-07: Guidance on Backloading Rules
December 28, 2007 — IRS Hybrid Retirement Plan Proposed Regulations
August 29, 2007 — Senate HELP/Finance Committee Letter to Treasury Regarding Backloading Rules
December 21, 2006 — IRS Notice 2007-6 Regarding Cash Balance and Other Hybrid Defined Benefit Pension Plans
Council Materials
December 31, 2012 — Council Letter to Treasury Regarding Hybrid Plan Regulatory Issues (with Coalition to Preserve Defined Benefit Plans & ERIC)
December 3, 2012 — Council Letter to Treasury Regarding Hybrid Plan Regulatory Issues (with Coalition to Preserve Defined Benefit Plans & ERIC)
December 3, 2012 — Council Answers to Treasury Questions Regarding Hybrid Plan Regulatory Issues (with Coalition to Preserve Defined Benefit Plans & ERIC)
August 29, 2012 — Benefits Briefing Presentation Slides: Hybrid Plan Issues & Questions
August 22, 2012 — Treasury/IRS Meeting Summary: Hybrid Plan Regulations
September 7, 2011 — Group Submission to Treasury/IRS Regarding Critical Issues for Hybrid Plan Regulations
January 12, 2011 — Council letter regarding IRS Rules on Hybrid Plans
August 20, 2010 — Summary of Pension Equity Plan Issues
October 1, 2009 — Group Letter to Treasury Regarding Hybrid Plan Guidance
October 8, 2008 — Summary of Employer Meeting with Treasury and IRS Regarding Proposed Hybrid Plan Regulations
September 16, 2008 — Council Comment Letter to IRS on Backloading/Accrual Rules to "Greater Of" Formulas
March 27, 2008 — Council Comment Letter to Treasury/IRS on Hybrid Retirement Plans
August 22, 2007 — Group Letter to Treasury Regarding Backloading Issue
July 18, 2007 — Letter to Treasury Regarding Application of the Anti-backloading Rules under Internal Revenue Code Section 411
April 16, 2007 — Council Comment Letter on IRS Notice 2007-6, Regarding Cash Balance Guidance
Official Source Documents
October 19, 2009 — U.S. Second Circuit Court of Appeals Decision in re Citigroup Pension Plan ERISA Litigation
August 21, 2008 — Ninth Circuit Court Decision in Hurlic v. Southern California Gas Company
July 9, 2008 — U.S. Second Circuit Court of Appeals Decision in Hirt v. Equitable
November 20, 2007 — U.S. District Court for the Southern District of New York Decision in Citibank ERISA Litigation
August 27, 2007 — Decision by U.S. District Court of Appeals for the Sixth Circuit in the case of Drutis, et al v. Rand McNally and Co.
December 12, 2006 — U.S. District Court for the Southern District of New York decision in In Re Citigroup Pension Plan ERISA Litigation
October 30, 2006 — U.S. District Court for the Southern District of New York Opinion in re J.P. Morgan Chase Cash Balance Litigation
September 19, 2006 — Supplementary Decision in Hirt v. Equitable
August 7, 2006 — Seventh Circuit ruling in Cooper v. IBM
July 11, 2006 — Delaware District Court Decision in Charles et al v. PEPCO
March 31, 2006 — U.S. District Court of Connecticut Decision in Richards v. FleetBoston
Council Materials
August 20, 2008 — Updated Cash Balance Plan Litigation Chart (Courtesy of Davis & Harman)
May 30, 2008 — Council Amicus Brief with 2nd Circuit U.S. Appeals Court in re Citigroup Pension Plan ERISA Litigation
May 29, 2007 — American Benefits Council Amicus Brief in Hirt v. Equitable (U.S. Second Circuit Court of Appeals)
February 27, 2007 — Council Amicus Brief in Drutis v. Rand McNally & Co.
January 16, 2007 — Council Amicus Brief in re Citigroup Pension Plan ERISA Litigation
Council testimony: complete, flexible hybrid plan rules essential for sustaining defined benefit pension system
January 26, 2011
Pension Reform · Savings Initiatives · Social Security · Stock Programs · Misc. Retirement
Health
Health Care Reform (PPACA), General & Misc. Items
- Employer Shared Responsibility
- Market Reforms & Adult Child/Age-26 Coverage
- Preventive Care & Value-Based Design
- Quality Improvement & Delivery Reform
- Essential Benefits
- Tax & Revenue Issues
- Grandfathered Plans
- Claims and Appeals
- Summary of Benefits & Coverage
- Informational Reporting/W2
- Health Insurance Exchanges
- State Innovation
- Medical Loss Ratio & Mini-Med Plans
- Automatic Enrollment
- Wellness Programs
- Accountable Care Organizations
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Consumer-Directed Plans (HSAs/FSAs/HRAs)
Health Information Technology & HIPAA Privacy
Retirement
Defined Contribution/ 401(k) Plan Reform
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- Investments
- Plan fees
- Taxation of Retirement Plans/Limits
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- PBGC Deficit & Premiums
- Business Conduct Standards
Retirement Plan Administration
Other Issues
Tax Reform, Deficit Reduction & Federal Budget
- FACTA Issues
- FBAR Issues
- Puerto Rico Plans
- Non-Qualified Deferred Compensation
- Code Section 409(A), 457(A), 162(m) issues
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