Fiduciary Rule Proposal – Additional Exemptions

SIFMA is pleased to provide comments regarding the Department of Labor’s (“Department”) proposed amendments to PTCE 75-1, Parts III and IV, 77-4, 80-83, and 83-1 (the “Class Exemptions”) under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and section 4975 of the Internal Revenue Code (“Code”) (referred to as the “Proposal”). SIFMA appreciates the opportunity to comment and hope that our comments are helpful to the Department as it assesses the impact of these changes to the current exemptions on IRAs, plans and their participants. SIFMA shares the Department’s interest in making sure that plans, their participants and IRAs are treated fairly in the market place and have the ability to trade effectively and efficiently in all markets.

SIFMA hopes that the Department will eliminate these amendments for all the reasons outlined. Should it choose not to do so, these comments point out additional flaws in the drafting.

See Also:

United States Department of Labor: Conflict of Interest Proposed Rule

See Also:

• Executive Summary
• The Fiduciary Rule Itself
• Best Interest Contract Exemption (BIC exemption)
• Principal Transactions
• Prohibited Transaction Class Exemption (“PTCE”) 86-128
• Prohibited Transaction Class Exemption (“PTCE”) 84-24
• Prohibited Transaction Class Exemption (“PTCE”) 75-1, Part V
• Asset Management Group
• NERA Analysis: Comment on the Department of Labor Proposal and Regulatory Impact Analysis
• Deloitte Report on the Anticipated Operational Impacts to Broker-Dealers of the Department of Labor’s Proposed Conflicts of Interest Rule Package