[Opinion]

9/21/2006: Text of American Bankers Association Comments on Proposed Revision of Form 5500 (PDF) (American Bankers Association)

11 pages. Excerpt: [T]he proposal will require massive technology changes across the financial industry since 'plan specific' information as opposed to plan aggregate information is not currently tracked. In addition, significant clarification is needed regarding indirect compensation and its allocation.... Finally, changing the Form 5500 in the manner proposed will not, we believe, achieve the public policy goal of better disclosure. Increased disclosure is not meaningful disclosure.