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Compliance December 13, 2008
IMHO: The Gift of Time
My eldest has been carrying a heavier than “recommended″ class load this semester.
Reported by Nevin E. Adams
That – combined with her choice of classes – has meant that she’s been trying to get ready for finals and writing several critical papers all at the same time. Now, she’s a gifted student, and more committed to her studies than most (or so she has convinced her father and mother) – but the pressure was certainly mounting. Just when she thought it couldn’t possibly all get done on time, she asked for – and got – an extension on one of the papers.
Not that she did so with enthusiasm. She is very conscientious about her work and deadlines, and on more than one occasion has pulled the infamous “all-nighter’ to meet them. This time, however, she was smart enough to acknowledge the need and make the request. And while the extension was modest, it seems likely to give her enough mental “room’ to devote the requisite level of attention to the array of competing priorities that the end of a college semester brings with it.
You don’t have to be in school to know that things can get pretty crazy this time of year, even in the best of times – and these are surely not the best of times. Just about everybody I talk to in this business is busier than ever, caught up not only in the usual plethora of year-end duties, but in a whole new set of issues brought on by the roiling markets. Indeed, one need look no further than the provider firms and advisory businesses that have, in recent weeks, expanded their call center hours or capabilities to appreciate the uptick in activity.
In the middle of all this turmoil, it was refreshing, therefore, to get from Uncle Sam one of the rarest of gifts – time.
During the last week alone, we got another year to deal with the document requirements of 403(b), a(nother) reprieve on 409A reporting of deferred compensation, and some breathing room so that the funding requirements of the Pension Protection Act can be more rationally assimilated with the current market realities (though President Bush still has to sign the last, and the initial signals suggest that he’s not yet convinced this is a good idea, despite the unanimous voice vote of both houses of Congress).
There are those, of course, who may take issue with those extensions; let’s face it, those that manage to find a way to comply with the original deadlines might naturally presume that everyone would have made the same effort. Still, IMHO, with the possible exception of the 403(b) extension (and even there, plan sponsors have to conduct plan operations as if the document were in place from the original date, so the “relief’ is probably less than it might otherwise seem), the extra time seems fair, reasonable, and timely. In each situation, plan sponsors, their advisers, and advocates took the time to make a compelling case about the need for a little more time (I will say that having to read/assimilate and report on all this activity makes our jobs a bit more complicated). To their credit, those in a position to grant those requests listened – and, IMHO, cautiously and carefully, acquiesced.
And for those of us impacted by such matters, the holidays just got a little bit easier.