Acting Assistant Secretary Ali Khawar
Employee Benefits Security Administration
U.S. Department of Labor
200 Constitution Ave., NW
Washington, DC 2210

Re: RIN 1210-AC05

Secretary Khawar:

SIFMA appreciates the opportunity to provide comments to the Department of Labor (“Department”) regarding proposed regulations to change the procedures governing prohibited transaction exemptions. We believe the proposed changes are far more extensive than perhaps the Department understood when it proposed these changes and would have the unintended consequence of harming participants and beneficiaries preparing for retirement. There is no corresponding benefit that would warrant such extensive changes to a process that has been working for decades. In light of the significant harm we believe the proposed changes would inflict on plans and participants, the Department should withdraw these proposed changes and engage with stakeholders regarding what, if any, changes to the exemptions process would help improve the process and help ensure, as Congress intended, that plans will continue to benefit from innovative investment transactions and access to markets.

We also request the Department hold a hearing on these proposed changes, and we request the opportunity to testify.