SIFMA provides comments to the Benefits Tax Counsel of the U.S. Department of Treasury on final regulations for Section 403(b) of the Internal Revenue Code.  While SIFMA believes that the final regulations will help enhance compliance with the Internal Revenue Code and ultimately strengthen an important opportunity for many participants to save for retirement on a tax-qualified basis; the abbreviated time period allowed to implement new rules relative to custodian transfers is causing a great strain on the 403(b) community that will negatively impact 403(b) participants, eligible employers, and 403(b) vendors in the next few years. SIFMA urgently requests that the Treasury and the IRS delay its new requirements regarding information sharing agreements (“ISAs”) with respect to 403(b) arrangements that were transferred in compliance with Revenue Ruling 90-24, and to provide further clarification regarding investment providers, the ability to obtain signatures or written statements from employers in certain situations, and other topics.