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SPARK Comment Letter to EBSA on 'Open MEPs' and Other Issues Under Section 3(5) of ERISA (PDF)
The SPARK Institute 
[Opinion] Oct. 30, 2019 "[T]he SPARK Institute strongly disagrees with the Department's existing restriction for financial institutions because: [1] it is unsupported by the text of ERISA; [2] it does not provide any meaningful benefits or protections that are not otherwise addressed by ERISA; and [3] it unfairly discriminates against financial services firms ... If a financial services firm is willing to act as the plan sponsor and administrator, and acknowledge its fiduciary status under ERISA in writing, we do not see any legal or policy justifications for limiting the ability of financial services firms to sponsor a defined contribution MEP." MORE >> |
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