SIFMA provides comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) on the DOL’s proposed regulation under the Employee Retirement Income Security Act of 1974 (ERISA) that would redefine the term “fiduciary” under section 3(21) of ERISA and section 4975(e) of the Internal Revenue Code of 1986.  SIFMA believes the proposed regulation would have unintended consequences including, but not limited to: 1) impacting the ability of millions of Americans to save for retirement; and 2) limiting access to markets, investment products and services providers.

SIFMA testified during a DOL hearing on the Department’s proposed definition of fiduciary on March 1, 2011.

SIFMA provided supplemental comments to DOL on April 12, 2011 to respond to the questions the Department posed during the hearing and respond to certain other comments made by others who testified.