Church Alliance Submits Comment Letter to IRS and Treasury on Agency Guidance on Church Plan Clarification Act Provisions of the PATH Act (August 3, 2016)


On August 3, the Church Alliance submitted a comment letter to the Internal Revenue Service and Treasury Department, addressing the recent enactment of the Church Plan Clarification Act (“CPCA”, which was enacted as part of the “PATH” Act of 2015) and potential guidance that the agencies may issue. In the comment letter, the Church Alliance suggests that the issuance of a notice or other similar sub-regulatory guidance that addresses certain considerations set forth in the letter would be helpful as church benefit programs seek to move forward under the new law. Among other things, the comment letter addresses clarifications that could be made with respect to the new controlled group rules for church organizations, the immediate effective date of the church plan transfers and mergers rules, and clarifications with respect to automatic enrollment guidance and rules on investments by church plans in collective trusts.