Human Resources
Thought Leadership

Aon Hewitt Submits Comments on Proposed Regulations for Hybrid Defined Benefit Plans

On January 12, 2011, Aon Hewitt submitted comments to the Internal Revenue Service on proposed rules for hybrid defined benefit pension plans. The proposed regulations were published in the Federal Registeron October 19, 2010.

Aon Hewitt's comment letter offers detailed analysis on the ten questions posed to respondents in the preamble to the proposed regulations. Additionally, Aon Hewitt discusses the following areas of concern relating to the proposed regulations, including:

  • Interest crediting rates based on diversified market indices;
  • Regulatory effective date for collectively bargained plans;
  • Proposed requirements for whipsaw relief; and
  • Accrual rule issues.

The full comment letter is available below.

Aon Hewitt Comments on Proposed Regulations for Hybrid Defined Benefit Plans