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The Committee on Investment of Employee Benefit Assets Comments on Fee Disclosure (PDF)

Excerpt: [CIEBA] members have identified several areas of concern in the proposed regulation and we encourage the Department to revisit these issues prior to finalizing the regulation.

Results of CIEBA Survey on Pension Reform Impact on Defined Benefit Plans (PDF)

5 pages. Excerpt: In the spring of 2005, the Committee on Investment of Employee Benefit Assets (CIEBA) asked its members - chief investment officers of many of the nations' largest corporate pension plans - to respond to a survey on the impact of proposed changes to rules governing defined benefit pension plans and how these changes could affect pension plans and the workers and retirees in those plans.

CIEBA Comment Letter to DOL on Improving Investment Advice for Workers and Retirees -- Strengthening Protections for Rollovers (PDF)

"CIEBA continues to believe that DOL should re-evaluate the Five Part Test, which was issued well before the proliferation of 401(k) plans. Those who market and recommend rollovers to plan participants should be fiduciaries under ERISA, and the Five Part Test should make it much more clear that rollover providers are almost invariably acting as fiduciaries in the context of the rollover."

CIEBA Presentation Before the PBGC Advisory Board on Defined Benefit Plans (PDF)

21 page PowerPoint Presentation. Excerpt: On December 8, 2009, CIEBA members testified before the PBGC Advisory Board on the state of defined benefit plan investments and the challenges they face in the current funding environment[.]

CIEBA Comment Letter to FASB on Employers' Accounting for Defined Benefit Pension and Other Postretirement Plans (PDF)

5 pages; May 31, 2006. Excerpt: Piecemeal Accounting Reform -- Pension accounting is, by its nature, complex. While it may appear that Phase I represents a 'simple' movement of information from the notes to the balance sheet, it is a major change. Such an action seems premature and counterproductive when the Financial Accounting Standards Board (FASB) indicated that it will undertake a comprehensive review of pension accounting, including measurement issues.

Testimony on Behalf of American Benefits Council and CIEBA before House Subcommittee Hearing on Over-the-Counter Derivatives Market (PDF)

13 pages. "[C]ertain proposed regulations affecting ERISA plans could have very adverse effects on plans, none of which were intended by Congress."

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)

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."

CIEBA Letter on Proposed FASB Staff Position to Amend FASB Statement 132 (revised in 2003), Employers' Disclosures about Pensions and Other Postretirement Benefits (PDF)

5 pages. Excerpt: As the chief investment officers for 110 major private-sector retirement plans, CIEBA members recognize the desirability of increased transparency and comparability in the financial statements of public companies. However, we posit that the proposals contained in this FSB will not lead to a meaningful increase in transparency and may reduce comparability.

CIEBA Testifies at ERISA Advisory Council Hearing on 401(k) Brokerage Windows

"[W]hile 54% of CIEBA Members offered some form of a brokerage window, only 2.8% of plan assets are invested through the window.... [W]hile utilization may be low, CIEBA Members still view windows as an important feature to retain participation for savers looking for options outside a 401(k) plan designated menu.... [W]hile windows help participation, undue monitoring obligations would lead plans to potentially eliminate the option in their plans."

Amicus Brief Filed by CIEBA Supporting Clear Limits on Pleading Standards in ERISA Fee Litigation (PDF)

"ERISA was intended to ensure the fair and prudent administration of employee retirement plans. It was not intended to empower federal judges to second-guess the fee selections of fiduciaries in a competitive market. Nor was it designed to facilitate an enormous wealth transfer from plan fiduciaries to the plaintiffs' bar, with no benefit to plan participants. Meritorious claims should prevail, but the type of cookie-cutter nuisance lawsuits that have become so prevalent must meet a swift end." [Hughes v. Northwestern Univ., No. 18-2569 (7th Cir. Mar. 25, 2020; cert. pet. granted No. 19-1401, Jul. 2, 2020)]