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American Bankers Association Comment Letter to EBSA on Proposed Regs on Default Investment Alternatives (PDF)
American Bankers Association 
Nov. 15, 2006
5 pages. Excerpt: [W]e request clarification: (1) That the prohibition on imposing financial penalties does not preclude compliance with SEC Rule 22c-2; (2) That bank trustees are not precluded from serving as investment manager of a QDIA; (3) That the 30-day notice requirement would not apply under certain limited circumstances (such as in the case of new hires) where such notice may not be practical;[.]
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