Groom submitted a letter to the Internal Revenue Service (IRS) on October 6, 2009, to respond to the Treasury’s request for comments regarding the Report of Foreign Bank and Financial Accounts (FBAR) and the accompanying instructions. Alison Bennett reported on the letter in the article, “FBAR Reporting Should Be Limited For Pension Plans, Trusts, Commenters Say ” published on October 8th, 2009 in Pension & Benefits Daily.