Search the News Archive

Joint Trade Organization Comment Letter to DOL Requesting Extension of Comment Period on Proposed Proxy Voting Regs (PDF)

"The American Bankers Association [ABA], the American Council of Life Insurers [ACLI], the Defined Contribution Institutional Investment Association [DCIIA], the Insured Retirement Institute [IRI], the Investment Adviser Association [IAA], the Investment Company Institute [ICI], the Securities Industry and Financial Markets Association [SIFMA], and the SPARK Institute ... respectfully request a 30-day extension of the deadline for public comments on the Proposal, currently scheduled to end on October 5, 2020. The Department acknowledges that the Proposal represents a material departure from the current rules. Thus, the Proposal warrants a comprehensive review in order to properly consider its impact on plan fiduciaries, plan investments and current practices."

Comment Letter from Five Trade Associations to DOL on Proposed 408(b)(2) Guide Requirement (PDF)

"DOL is using the issuance of the Proposed Rule as an opportunity to collect information from the public in order to make findings necessary to adequately demonstrate that the guide (i.e., the proposed data collection) contemplated by the Proposed Rule is (i) necessary for the proper performance of the functions of the agency, and (ii) will have practical utility. Accordingly, DOL has not completed the threshold steps of determining whether the guide is in fact needed or will be useful to plan sponsors, nor has it developed a realistic estimate of the total time required for [affected] service providers to prepare the guide."

Joint Trade Associations Comment Letter to DOL on Proposed 408(b)(2) Focus Groups (PDF)

"We believe this review of the 408(b)(2) regulation is premature and based on unidentified anecdotal evidence of small businesses that is contrary to the actual experience of our members. In particular, it is our view that: [1] It is premature and imprudent to propose to amend the section 408(b)(2) regulation to add more disclosure rules before determining whether any changes are needed (and whether the costs of those changes justify whatever benefits the Department identifies). [2] The proposed focus groups are not properly constructed because [a] they ignore large-plan fiduciaries, and [b] they rely upon recollection of disclosures th at plan fiduciaries received almost two years ago. [3] The focus group 'script' contains a number of biases that could prevent the results from being reliable and valid."