Comment Letters

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On January 27, 2011, ASPPA, CIKR and NAIRPA submitted comments to the U.S. Department of Labor on the proposed regulation regarding the definition of the term “fiduciary”.[Comment]

On November 3, 2010, ASPPA and CIKR submitted a comment letter to the Securities and Exchange Commission with respect to proposed amendments to the rules for mutual fund distribution fees, including changes to 12b-1 fees. The comments provide recommendations as to how the proposed amendments could be improved, including suggesting the adoption of a plan investor “safe harbor.” [Comment]

On August 29, 2010, ASPPA and CIKR submitted a comment letter to the Department of Labor with respect to the Interim Final Regulation under ERISA §408(b)(2) which relates to the disclosure obligations of certain service providers to retirement plan fiduciaries. The comments provide suggestions and recommendations as to how the Interim Final Regulation could be improved before it becomes effective on July 16, 2011. [Comment]

On June 16, 2009, ASPPA, CIKR and NAIRPA submitted a letter to Senate Health, Education, Labor and Pensions Committee Chairman Edward Kennedy (D-MA) and Ranking Member Michael Enzi (R-WY) in support of Phyllis C. Borzi, nominee for Assistant Secretary of Labor for Employee Benefits Security, Department of Labor. [Letter]

On April 24, 2009, ASPPA, CIKR and NAIRPA submitted a Letter of Support for H.R. 1984 to House Education and Labor Committee Chairman George Miller (D-CA). [HR 1984 Support Letter

On March 6, 2009, ASPPA and CIKR submitted comments to the DOL on legal and policy questions relating to the final investment advice regulation, recommending that the DOL withdraw the class exemption portion of the final regulation. [Comments]

On February 18, 2009, ASPPA and CIKR submitted comments requesting that the DOL extend the effective and applicability date of the final investment regulation by 60 days given the lack of certainty over the ultimate status of the regulation’s final outcome. [Comments

On September 15, 2008, ASPPA and CIKR submitted supplemental comments to the DOL on the participant fee disclosure proposed regulation, suggesting a disclosure alternative to the proposed quarterly statement requirement.[Comments

On September 8, 2008, ASPPA and CIKR submitted comments to the DOL on the participant fee disclosure proposed regulation. [Comments][Press Release

On April 15, 2008, ASPPA and CIKR submitted a Letter of Support to H.R. 3185, as amended, to House Education and Labor Chairman George Miller (D-CA). [H.R. 3185 Support Letter][News Release]

On March 11, 2008, ASPPA, CIKR and the Small Business Council of America (SBCA) submitted comments in opposition to Connecticut 401(k) plan legislation. [CT Written Comments]

On February 11, 2008, ASPPA & CIKR submitted comments to the DOL on ERISA Section 408(b)(2) proposed regulations.  [Comments]