Human Resources
Legislative Thought Leadership

Aon Hewitt Submits Comments on Temporary Nondiscrimination Relief for Closed Defined Benefit Plans


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On February 28, 2014, Aon Hewitt submitted comments to the Internal Revenue Service (IRS) regarding the proposed long-term solutions set forth in Notice 2014-5 regarding:

  • The ability of a defined benefit (DB) plan and a defined contribution (DC) plan to satisfy nondiscrimination testing requirements on a benefits basis; and
  • Other possible related modifications to other nondiscrimination testing requirements.

The guidance was issued by the IRS on December 13, 2013.

The comment letter discusses:

  • The nondiscrimination testing issues that plan sponsors currently face, as well as the prevalence of these issues;
  • An analysis of how the Notice 2014-5 proposals would apply to plan sponsors based on Aon Hewitt’s experience with our clients; and
  • Recommended relief provisions for the IRS’s consideration. The Aon Hewitt comment letter was authored by Janice Harbold (U.S. Retirement) and Eric Keener (U.S. Retirement).

The Aon Hewitt comment letter was authored by Janice Harbold (U.S. Retirement) and Eric Keener (U.S. Retirement).

Download Aon Hewitt Submits Comments on Temporary Nondiscrimination Relief for Closed Defined Benefit Plans