Comment from Church Alliance
Church AllianceSupportAdvocacy
Summary: The Church Alliance, representing 38 denominational benefits organizations, requests that the Department of the Treasury prioritize and publish regulations to streamline the definition of a "church plan" under Section 414(e) of the Internal Revenue Code. They argue that these regulations will provide regulatory certainty, increase efficiency, and reduce compliance costs for faith-based organizations serving nearly one million participants.
To Whom It May Concern:
The Church Alliance appreciates the opportunity to submit the attached comment letter on the Department of the Treasury’s (“Treasury”) 2026-2027 Priority Guidance Plan. As Treasury sets its regulatory priorities for the year ahead, the Church Alliance respectfully requests the inclusion of “Regulations on the definition of church plan under §414(e).” As described in the attached letter, the publication of the proposed regulations would increase regulatory efficiency by streamlining the current patchwork of regulations, guidance, and private letter rulings with respect to church plans and provide regulatory certainty to denominational benefits organizations serving nearly one million church plan participants.
Thank you for your consideration.
Respectfully,
Christopher Wells
Executive Director
Church Alliance