[We] wanted to share these top-level concerns with you directly in anticipation of our next opportunity to discuss them and other regulations of concern. Building on our recent TPA victory, we look forward to working together to find even more solutions that keep America moving forward.
BRT remains very concerned about the negative impact many of the Proposed Rule's policies would have on employers and employees alike. We urge the Department to rescind the current NPRM and immediately reevaluate the methodology used to determine the proposed salary threshold.
[If] the Administration believes there is a need to improve contractor compliance with labor laws, it should work with Congress and ensure that any legislation increases efficiency and saves money. The current proposal will do little to achieve these goals and will result in huge costs to the federal government, contractors, small businesses and ultimately American taxpayers.
The broad application of the 40 percent excise tax means that, over time, the health benefit plans of all major U.S. employers will be subject to the tax. The impact of the eventual tax liability resulting from this provision is staggering and will distort the employer-sponsored health care marketplace, leading to dramatic changes in the benefits offered to employees.
In the coming weeks, the Environmental Protection Agency (EPA) will send the Office of Management and Budget a new National Ambient Air Quality Standard (NAAQS) for ozone that
will be among the most expensive regulations in our nation’s history.
Business Roundtable CEOs believe that a smarter regulatory system and a modernized federal permitting process will help drive increased business investment, economic growth and job creation.
Thank you for meeting with us to discuss your pending decision regarding whether it is appropriate to lower the existing ozone National Ambient Air Quality Standard (NAAQS) from its current level of 75 ppb to a level somewhere within the range of 65-70 ppb
A Business Roundtable comment letter raises questions about a recent SEC economic analysis concerning the CEO pay ratio rule and the analysis in the Commission’s consideration of the final rule. BRT also highlights the source of the extraordinary costs and burdens the proposed rule would place on companies and their shareholders and that the information garnered from the rule would be immaterial, if not misleading, to investors. Finally, the Dodd-Frank provision mandating pay ratio should be repealed and, if this proves unachievable, the letter recommends changes that could substantially decrease the proposed rule’s costs and burdens.
Financial professionals should be required to act in the best interests of employee benefit plan participants when providing investment advice to a retirement plan or its participants. While we appreciate the EBSA addressing this issue, we urge the EBSA to reconsider some elements of its proposed definition of fiduciary and the related proposed prohibited transaction exemptions.
We are pleased that The Every Child Achieves Act, as passed by the Senate, makes important progress in each of these areas. We also appreciate the hard work that has gone into bringing this bipartisan legislation to the floor, and we look forward to closely working with you to ensure that ESEA is reauthorized as soon as possible.
The expired provisions are vitally important to creating and maintaining jobs, generating investment, advancing U.S. competitiveness and spurring economic growth. Failure to extend these provisions is a tax increase that will inject further instability and uncertainty into the economy and weaken confidence in the employment marketplace.
Weakening these requirements would undermine accountability provisions designed to ensure that all children – no matter their background or school – receive the education they deserve.