Roth Comment 4-26-06

714 Hopmeadow Street, Suite 3 Robert G. Wuelfing, President Simsbury, CT 06070 Larry H. Goldbrum, General Counsel (860) 658-5058 601 Pennsylvania Ave. 10th Floor-North Building Washington DC 20004 Filed Electronically April 26, 2006 CC:PA:LPD:PR (REG-146459-05) Room 5203 Internal Revenue Service POB 7604 Ben Franklin Station Washington, DC 20044 Re: Proposed Regulations Regarding Designated Roth Accounts under Section 402A Dear Sir or Madam: 1The SPARK Institute, Inc. (“SPARK”) appreciates the opportunity to comment on the proposed regulations regarding “Roth Contribution(s).” SPARK members have significant experience with the recordkeeping and administration of retirement plans. Our members are the service providers that will be largely responsible for providing recordkeeping and administrative services for Roth Contributions to a substantial majority of retirement plans. Accordingly, we respectfully request that the Internal Revenue Service (“Service”) consider the following comments. Our members are concerned that the Roth Contributions regulations as currently written are overly complex and difficult for plan sponsors to understand. Consequently, the adoption of 1 SPARK represents the interests of a broad-based cross section of retirement plan service providers, including members that are banks, mutual fund companies, insurance companies, ...