The Omnibus Reconciliation Act of 1990 made retroactive changes to the rules related to separating Federal employees. While the rules were made retroactive to October 1. 1990. the implementing regulations were not promulgated until February 1991. This four month period between the enactment of the law and the promulgation of the implementing regulations has adversely affected any Federal employee who withdrew their retirement contributions during this period. This matter was brought to my attention by Sandra Schatz Landis. my constituent who was on maternity leave from the Immigration and Naturalization Service (INS). a former bureau of the Department of Justice at the time in question. On November 5. 1990. Ms.
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