10 pages. "[ICI urges] the Department to interpret the definition of employer more broadly, specifically by expanding the category of persons able to act indirectly in the interest of employers ... Any concerns the Department may have with respect to permitting MEP sponsorship by financial services firms can be mitigated by using established methods for ensuring both the legitimacy and qualifications of the MEP sponsor and protection from conflicts of interest. Failure to expand the interpretation as recommended likely will result in market distortions and inefficiencies, to the detriment of retirement savers."  MORE >>