Hanson Bridgett has filed extensive comments the IRS in response to their recent advance notice of proposed rulemaking with regard to the determination of governmental plan status. We are concerned that the proposed changes have the potential to establish wide-ranging rules that will affect millions of plan participants and retirees, their government retirement plans and the plan sponsors.

Our comments respectfully submit that substantial change is needed, and we believe the IRS understands this need because of the specific requests for comment set out in the notice. We look forward to a dialog with the IRS to assist it in resolving its concerns in a manner that also meets the needs of government systems, participating government agencies, individual participants and their beneficiaries.

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