ArcelorMittal, Arouca, Dennis

I am writing regarding NPRM RIN 1215-AB64. I am Vice President Labor Relations for ArcelorMittal USA. We are the USA's largest steel company employing about 20,000 employees with over $15 billion revenues. We are part of ArcelorMittal, the world's largest steel company with revenues of over $90 billion, and 330,000 employees in 60 countries worldwide. We have relationships with dozens of labor organizations across the globe. In the USA we have collective bargaing relationships with the United Steel Workers, and other groups. We sponsor a number of benefit programs, including pensions, health care, training, credit union and other welfare matters. I urge you to extend the deadline for Comment at least 60 days. Because of the prior exemption for those plans that file a 5500, we had not been following this matter closely. The removal of this exemption now requires that we address this in detail. We are concerned in part with the burdensome administrative costs this will impose on staff, whch inevitably will come out of plan assets which are intended for other purposes, and result in pressure to increase employer contributions. This Administration pledged to reduce and/or minimize the regulatory burden on employers but this effort seems to be going in the opposite direction. In addition, the professionals with whom we must meet to now address this initiative in detail all are consumed with the April 15 deadline for tax filings and are not fully available until after that date. An extension for comment until June 18 will enable us to properly consider this NPRM and comment accordingly. Thank you.