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Draft Comment Letter on Hybrid Regulations: Comments Requested by Monday COB

January 6, 2011

Coalition Members,

Attached for your review is a draft comment letter on the proposed hybrid plan regulations released by the Treasury Department and IRS in October. As you will see, the letter is a joint submission from the Coalition and the American Benefits Council.

We appreciate the input we received from a number of Coalition members about the issues in the proposed regulations that were most important for your companies. The letter makes certain overarching points and then is divided into sections addressing issues related to (1) the market rate of return requirement for interest credits, (2) whipsaw, (3) pension equity plans, (4) post-normal retirement date accruals, and (5) the effective date of the regulations.

The deadline for submission of comments on the proposed regulations is next Wednesday, January 12th. With that in mind, we are asking that you provide us with any comments and suggestions on the draft letter by close of business this coming Monday, January 10th.

We appreciate your understanding for this relatively tight turn-around. Please relay any comments on the letter to Jamey Delaplane at Davis & Harman LLP (jmdelaplane@davis-harman.com; 202-662-2294). E-mail transmission of comments may be the easiest (and feel free to send along a red-line with any suggested edits to the letter) but please also feel free to reach out by phone.