Summary

SIFMA, the Invested Retirement Institute (IRI), and the Financial Services Roundtable (FSR) provide comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) on DOL’s request for data related to the economic analysis DOL is required to undertake in order to re-propose regulations that would substantially modify the definition of a fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA).  The groups share their views on the request and caution DOL that none of signatory trade associations maintain an electronic or hard-copy database containing the information DOL has requested. In addition, the groups have never undertaken the type of costly and extensive survey and system build that would be required to obtain and collate this vast amount of data.

 

 

 

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Date

1

March

2012