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The IAA supported the proposed safe harbor for the use of electronic disclosure, particularly the “notice and access” approach, and encouraged the Department of Labor to apply the safe harbor to documents furnished upon request and allow for consolidated delivery of documents.
November 22, 2019
Comments on DOL Proposal to Amend the QPAM Exemption
The IAA responded to a Department of Labor proposal to amend the QPAM Exemption. While we support the DOL’s efforts to protect the interests of Plans and Plan participants, we are concerned that the potential impacts of the proposal would extend beyond these objectives and would have negative consequences that may not be in the best interest of Plans and their participants.
October 11, 2022
IAA, Joint Trades Letter Requesting Extension of Comment Period for QPAM Proposal
The IAA and other trade associations urge the DOL to extend the comment period for a proposal that would significantly narrow the availability of the QPAM Exemption.
August 19, 2022
Extension of DOL Fiduciary Duty Enforcement Policy
To allow members sufficient time to fully implement the Department of Labor’s fiduciary exemption, the IAA requested an extension of the DOL’s non-enforcement policy, set to expire on December 20, 2021.
September 23, 2021
Comments on DOL Proxy Proposal
The IAA strongly opposed and urged the DOL to withdraw its proposal on proxy voting and the selection and monitoring of proxy advisory firms because it represents a significant departure on how plan fiduciaries view their proxy voting responsibilities, and would substantially increase compliance costs without providing measurable benefits to plan participants and beneficiaries.
October 05, 2020
IAA, Joint Trades Letter to the DOL Requesting Extension of Comment Period for DOL Proxy 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 Proxy proposal.
September 25, 2020
Comments on DOL Proposed Fiduciary Exemption
The IAA submitted a comment letter to the DOL recommending that the DOL confirm that “hire me” discussions are not fiduciary investment advice. The IAA also recommended that the class exemption cover all types of digital advice and should permit greater flexibility for overseeing compliance with policies and procedures.
August 06, 2020
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