Date: April 24, 2015
Issue: Regulatory
To: Phyllis Borzi, Assistant Secretary, Employee Benefits Security Administration (EBSA, U.S. Department of Labor); Office of Regulations and Interpretations, EBSA, U.S. Department of Labor; Office of Exeptions Determinations, ESBA, U.S. Department of Labor
Filing Type: Regulatory
Description:Given the potentially massive changes that may be required under the Conflict of Interest Rule, the related prohibited transactionexemptions, and the accompanying Regulatory Impact Analysis (the Proposal) and its cumulative impact on retirement plan participants and beneficiaries, we believe that both the DOL and the public would benefit if EBSA prioritized getting this complex rulemaking process completed with as much time as need to work through all the intricate issues raised in the Proposal. To this end, in addition to extending the comment period, we request that DOL staff also provide a briefing on the Proposal within 21 days of its publication describing in detail what it intended in the base rule and related exemptions, and how they inter-relate. Doing so will allow commenters to better understand DOL’s objective and enable them to provide more meaningful comments targeted towards ensuring a workable rule.