Date: December 5, 2016
To: Office of Regulations and Interpretations, Employee Benefits Security Administration, U.S. Department of Labor
Filing Type: Regulatory
Description: The Chamber has substantial concerns with the Annual Reporting and Disclosure Proposed Rule1 implementing the Notice of Proposed Forms Revisions. It improperly seeks to collect data for purposes of the ACA that the Agencies lack authority to require on the Form 5500. It significantly expands the disclosure requirements for pension plans, increasing the burden without a corresponding increase in benefit, and fostering further confusion about reasonable fees and other issues by compelling reporting of data elements that are not comparable.