CUNA Regulatory Comment Call

Designated Roth Contributions to 401(k) Plans

May 2, 2005

EXECUTIVE SUMMARY

DESCRIPTION OF THE PROPOSAL

QUESTIONS REGARDING THE PROPOSAL

  1. The proposed regulations do not provide guidance regarding the taxation of the distribution of designated Roth contributions. For example, the proposed regulations do not provide guidance regarding the recovery of an employee’s investment in the contract associated with his/her designated Roth contributions. The IRS requests comments on the issues on which guidance is needed with respect to the taxation of such distributions.
















  2. It is noted that information collection proposed in the guidance would be used to ensure that affected Section 401(k) plans comply with separate accounting and recordkeeping requirements. Do you agree with those accounting and recordkeeping requirements?

    Yes _____ No _____

    Why or why not?
















  3. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com