*Letters

Requirements for a 408(b)(2) Guide

Published on:
April 11, 2014

SIFMA, the American Bankers Association (ABA), the American Council of Life Insurers (ACLI), the Investment Company Institute (ICI), The Spark Institute, Inc. (SPARK) provide comments to the Office of Management and Budget (OMB) on the proposed amendment to the Information Collection Request (ICR) included within the Department of Labor’s (DOL’s) March 12, 2014 notice of proposed rulemaking, Amendment Relating to Reasonable Contact or Arrangement under Section 408(b)(2) – Fee Disclosure.

In the event that OMB concludes that it does not have the authority to delay its ICR analysis, the groups urge OMB to disapprove the ICR and direct DOL to resubmit it after an adequate record is developed.

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