SIFMA provides comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) on a proposed amendment to Prohibited Transaction Exemption (PTE) 80-26 for certain interest free loans to employee benefit plans under the Employee Retirement Income Security Act of 1974, as amended (ERISA) and the Internal Revenue Code of 1986, as amended, RIN 1210-ZA21.  The amendment proposes relief to avoid the unexpected taxation of IRAs, and the loss of tax-qualified retirement savings for those IRAs. 

SIFMA requests that DOL revise the effective date language to clarify that relief will not be denied at the end of the 6-month exemption period; and that DOL “confirm that a universal, unilateral written amendment that makes clear that any cross-collateralization provision in any IRA or plan agreement is void, invalid and of no force and effect will meet the requirements of the exemption.” In addition, SIFMA asks for other clarifications and revisions to proposal language.