On September 2, 2022, the American Retirement Association wrote to the Department of Labor to request additional time to comment on the Proposed Amendment to Prohibited Transaction Class Exemption 84-14. (more…)
On May 16, 2022, the American Retirement Association wrote to the Department of Labor to respond to the Department’s Request for Information on possibly agency actions to protect life savings and pensions from threats of Climate-Related Financial Risk. (more…)
On December 13, 2021, the American Retirement Association wrote to the Department of Labor to provide our views on the proposed rule entitled: “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights”, that includes climate change and other environmental, social, and governance (ESG) factors in a new prudent investment safe harbor. (more…)
On November 1, 2021, the American Retirement Association wrote to the Department of Labor to respond to the request for comments on the notice of proposed revisions to the Form 5500 Annual Return/Report of Employee Benefit Plans (more…)
On March 23, 2021, the American Retirement Association and Ceres wrote to the Department of Labor with concerns about the ESG Final Rule. The ARA to asked the Department to issue FAQs clarifying the ESG factors are material financial factors under the Rule and to modify the Rule to permit ESG investments in qualified default...
On November 30, 2020, the American Retirement Association wrote to the Department of Labor to ask that the Form 5500 and related instructed be revised so that the determination of whether a plan is exempt from the annual audit requirement is based on the number of plan participants (including long-term part-time employees) with account balances...
On November 17, 2020, the American Retirement Association wrote to the Department of Labor with comments on the Interim Final Rule regarding Lifetime Income Illustrations on the Pension Benefit Statements. In the letter, the ARA told DOL it strongly supports enhancing participants’ understanding of their retirement plan benefits. (more…)
On October 5, 2020, the Plan Sponsor Council of America, part of the American Retirement Association, wrote to the Department of Labor to comment on the proposed Fiduciary Duties Regarding Proxy Voting and Shareholder Rights. PSCA is concerned that the proposal would increase litigation risks for plan sponsors and plans and believes existing guidance adequately...
On October 1, 2020, the American Retirement Association wrote to the Department of Labor to comment on the proposed Registration Requirements for Pooled Plan Providers with the primary concern being that the proposal underestimates the time needed to comply with the registration requirements before January 1, 2021. (more…)
On August 6, 2020, the American Retirement Association wrote to the Department of Labor to comment on the proposed class exemption for investment advice for workers and retirees. In the letter, the American Retirement Association supports the application for an ERISA fiduciary standard for rollover advice, requests clarification of the application of the exemption for...