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AMHCA recommended creation of a time-limited grandfather provision based on the new Tricare Certified Mental Health Counselor (TCMHC) regulations, which permit a transition period lasting five years.
The rule amendments will take effect 90 days after publication in the Federal Register, but investment advisers may rely on the grandfather provisions before then.
This transition rule effectively provided transition relief, in the form of a grandfather provision, to transactions that were clearly in progress as of the enactment date of the rule change and thus were likely structured in reliance on the old rules.
Grandfather provisions applicable to Section 457 may preserve some existing deferred compensation plans.
In late 2000, at the urging of the Napa Valley Vintners Association, the California legislature closed the "loophole" created by the 1986 federal grandfather provision.
It's unclear whether this grandfather provision would include a commitment to make an extension of credit entered into before July 30, 2002, even if funds are not transferred until after such date.
Furthermore, the language of the prohibition, the grandfather provision and other exceptions to the prohibition, and the prohibition's potential impact on other perquisites and programs also raise many questions of interpretation and application.
In 1971, the Texas Legislature created its first major clean air law, which included a grandfather provision exempting existing plants and plants under construction from the requirement to reduce emissions or obtain air permits.
We recommend that existing REITs consider forming a non-qualified REIT subsidiary to conduct third party management or non-customary services (and, perhaps, form a separate non-qualified REIT subsidiary for each service) to take advantage of the grandfather provision.
However, in order not to disadvantage those employees who were close to retirement in 1986 and who intended to take advantage of the existing early retirement subsidies, a grandfather provision was included to guarantee them a retirement benefit at least equal to what they would have received under the final-aver-age-pay plan.
But now the grandfather provision has been repealed, so all debt is subject to the same rules.
For example, the penalty-free withdrawal of principal, while leaving earnings in the contract, is retained under a grandfather provision.
The proposal rules out a grandfather provision to give current B.
However, some synthetic materials are allowed under a grandfather provision.