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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
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
The IAA strongly urged the DOL to withdraw its proposal because it reflects a fundamental misunderstanding about how investment advisers consider ESG factors as part of the investment process. The IAA also argued that the additional requirements in connection with ESG investments were unnecessary, unclear and would have negative impacts on investors.
July 30, 2020
IAA, Joint Trades Letter to the DOL Requesting Extension of Comment Period for DOL ESG Proposal
The IAA joined other trade associations to submit a letter to the DOL requesting an extension of the comment period for the DOL’s ESG proposal.
July 20, 2020
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