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American Benefits Council Comment Letter to IRS Regarding Proposed Regs on Electronic Communications (PDF)
American Benefits Council 
[Opinion] Oct. 12, 2005
"The proposed regulations appear to indicate that if a plan relies on consumer consent (instead of the alternative method) to provide electronic notices, electronic records cannot include oral communications or recordings of oral communications (see Prop. Reg. Section 1.401(a)-21(b)(5)."
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