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Advisory Committee on Tax Exempt and Government Entities (ACT ...

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Improving the Employee Plans Compliance Resoluti<strong>on</strong> System: A Roadmap For Greater ComplianceThe <strong>ACT</strong> recommends that the fee structure outlined in secti<strong>on</strong> 12.02 of Rev. Proc.2006-27 be modified under <strong>on</strong>e of the following approaches to reflect the intent of PPAsecti<strong>on</strong> 1101(b)(5):(1) Modify the fee structure to be based <strong>on</strong> the number of affected Participantsrather than the total number Participants. This modificati<strong>on</strong> could be implemented byusing the existing fee structure but referencing affected Participants instead ofParticipants as follows:Number of Affected Plan ParticipantsFee20 or fewer $ 750 21 to 50 $ 1,000 51 to 100 $ 2,500 101 to 500 $ 5,000 501 to 1,000 $ 8,000 1,001 to 5,000 $15,000 5,001 to 10,000 $20,000 Over 10,000 $25,000 (2) Modify the existing fee structure to reflect a more reas<strong>on</strong>able fee by combiningsome of the existing brackets <strong>and</strong> applying the fee schedule to affected Participants,thereby making it more reas<strong>on</strong>able for large <strong>and</strong> small employers as follows:Number of Affected Plan ParticipantsFee250 or fewer $ 1,000 251 to 1,000 $ 2,500 1,001 to 5,000 $ 5,000 Over 5,000 $10,000 (3) Replace the existing fee schedule with an Alternate Fee Schedule basedpartially <strong>on</strong> the number of affected Participants <strong>and</strong> partially <strong>on</strong> the total number ofParticipants. Determinati<strong>on</strong> of the fee would be a three-step process: 621. Determine the porti<strong>on</strong> of the fee based up<strong>on</strong> the total number of plan Participants:Total Number of Plan ParticipantsFee20 or fewer $ 37521 to 50 $ 50051 to 100 $ 1,250101 to 500 $ 2,500501 to 1,000 $ 4,00062 The following proposed fee structure is calculated by reducing each dollar amount <strong>on</strong> the existing fee schedule by 50%. Thesereduced dollar amounts are used in the corresp<strong>on</strong>ding lines of each of the following charts.ADVISORY COMMITTEE ON TAX EXEMPT AND GOVERNMENT ENTITIES (<strong>ACT</strong>) June 11, 2008 28

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