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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
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