Fiduciary Rule Proposal – Prohibited Transaction Class Exemption (“PTCE”) 84-24

SIFMA is pleased to provide comments regarding the Department of Labor’s (“Department”) proposal to amend and partially revoke Prohibited Transaction Exemption (“PTE”) 84-24 under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). We appreciate the opportunity to comment and hope that our comments are helpful to the Department as it assesses whether changing the current exemption and eliminating the ability of individual retirement accounts (“IRAs”) to rely on the exemption will serve the interests of retirement investors.

SIFMA disagrees with the amendments to, and partial revocation of, PTE 84-24 and urges the Department to permit plans covered by ERISA to decide for themselves how their service providers should be compensated, so long as that compensation is fully disclosed.

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”) 75-1, Part V
• Additional Exemptions
• 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