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Text of New York City Bar Comments on DOL Interim Final QDRO Rule (PDF)
New York City Bar 
May 9, 2007
13 pages. Excerpt: We suggest some modifications to clarify concerns where: (1) a DRO is issued after, or revises a prior DRO; (2) a DRO is issued after certain events, such as the death, divorce or remarriage of the participant; or (3) other QDRO requirements or protections may be violated by a DRO that meets condition (1) or (2), such as a DRO that violates the prohibition on a QDRO from requiring a plan to provide increased benefits (determined on the basis of actuarial value).
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