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Coalition Membership and Action Plan

The Coalition is made up of employers of varying sizes that sponsor defined benefit pension plans. Coalition members share a concern about the detrimental consequences for retirement plan design and participant benefit security of declaring hybrid pension plans age discriminatory and of finalizing regulations that will negatively affect defined benefit plan operation and innovation.

The Coalition will achieve its mission through a comprehensive program of education and direct advocacy.

  • Education. The Coalition will educate key policymakers about the range of defined benefit plan designs in existence today, the advantages of these many designs for plan sponsors and participants, and the importance of maintaining a climate of innovation for retirement plan design. The Coalition will also educate these policymakers about the detrimental effects of judicial decisions and legislative proposals that undermine hybrid pension plans. In addition, the Coalition will educate participating employers about the consequences of the proposed regulations and recent court decisions on plan design and plan operation through written materials, conference calls and e-mail updates.
  • Advocacy. The Coalition will pursue a broad advocacy effort to see that its objectives with respect to the age discrimination regulations are achieved and that judicial and legislative developments do not derail successful finalization of the age discrimination regulations. This advocacy effort will include:
     
    • In-person meetings with career officials and political appointees at the regulatory agencies involved in the development of the proposed regulations — Treasury Department, Internal Revenue Service, Department of Labor, Equal Employment Opportunity Commission
    • The submission of detailed written comments to these agencies
    • Outreach to the White House regarding the importance of clarifying that cash balance and pension equity plans satisfy age discrimination requirements
    • Contact with key Senators and Members of Congress (and their staffs) to urge these elected officials to (1) advocate for the Coalition’s desired changes to the proposed regulations, (2) reject legislative proposals that would interfere with the finalization of the proposed regulations, and (3) oppose legislative proposals that would impose onerous mandates on hybrid plan conversions