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March 21, 2023
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Legal Context of Defined Contribution Plan for Fiduciaries
One of the core responsibilities of defined contribution plan fiduciaries is selecting the investment options that will be available to participants in the plan. This paper summarizes the principles governing the exercise of that responsibility in 50 years of law, regulation, regulatory guidance, and court decisions.
December 13, 2022
Comments on DOL Proposal to Amend the QPAM Exemption
The IAA responded to a Department of Labor proposal to amend the QPAM Exemption. While we support the DOL’s efforts to protect the interests of Plans and Plan participants, we are concerned that the potential impacts of the proposal would extend beyond these objectives and would have negative consequences that may not be in the best interest of Plans and their participants.
October 11, 2022
We responded to a Department of Labor proposal to amend the procedures governing the submission of prohibited transaction exemption (PTE) applications. We strongly believe that eliminating the possibility of non-public discussions will significantly limit valuable informal discussions that would serve all parties well, including plans and plan participants.
October 07, 2022
We responded to a Department of Labor request for information on how it can address climate-related financial risks in retirement plans. We urged the DOL that any potential rulemaking should be principles-based and the DOL should not explicitly or implicitly favor one type of investment strategy over another. We also recommended that the DOL should assess its recent ESG Proposal before any further rulemaking and should coordinate with the SEC prior to any potential rulemaking.
May 16, 2022
Comments on DOL ESG and Proxy Proposal
We support the DOL’s proposal related to ESG investing and proxy voting and recommend that the DOL remove certain ESG-specific language in the rule text and remove the proposed “collateral benefit” disclosure.
December 13, 2021