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Testimony on Behalf of American Benefits Council and CIEBA Addresses the Swap-Related Issues Raised by Dodd-Frank for Private Retirement Plans Governed by ERISA (PDF)
American Benefits Council; Committee on Investment of Employee Benefit Assets [CIEBA] 
[Opinion] Feb. 16, 2011 8 pages. "With respect to the derivatives title of Dodd-Frank, there is one issue, however, that is dwarfing all others: timing. The agencies are attempting to perform a complete restructuring of a nearly $600 trillion market with rules developed over a few months. It simply is not possible to do that in a way that takes into account all relevant factors." MORE >> |
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