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The Resource for the Global Finance Profession

Position Statements


Statement on the Administration's Proposal to Strengthen Middle Class Retirement Security - February 2015


Benefit Headlines - September 2014


Benefit Headlines - August 2014


Benefit Headlines - April 2014


Pension Provisions in the Administration's FY 2015 Budget


Tax Reform Act of 2014


Pension Interest Letter to Congress


Preserve the Employer-Provided Retirement System


Mandating Investment Options in Defined Contribution Plans


Pension Conference Agreement Should Set Parameters For Yield Curve and Guarantee Transparency and Public Input


Possible Legislative Guidelines for Constructing the Corporate Bond Yield Curve


CIEBA Report: Final Impact of Pension Reform


CIEBA Principles for Pension Reform


The CIEBA Report: The U.S. Pension Crisis

Comment Letters

 7/21/2015     DOL Proposed Rule on Conflicts of Interest
 5/28/2015 Global Pension Coalition - NBNI G-SIFI
 4/15/2015   Joint Statement to Senate Finance Working Group on Savings and Investment
 3/5/2015   QLACs
11/24/14   Comments on Proposed Rules Related to Margin for Uncleared Swaps
10/30/14    S2855 Trade Letter
10/30/14   HR5381 Trade Letter
05/16/14    Re: RP-2014 and MP-2014 Comments
05/13/14    PBGC Company Letter to Congress
2/28/14   Nondiscrimination Testing - Comments to Treasury and IRS (Notice 2014-5)
8/7/13    Pension Benefit Statements Project - DOL ANPRM (RIN 1210-AB20)
6/3/13    Reportable Events and Certain Other Notification Requirments (RIN 1212-AB06)
4/8/13   Comment Letter to Pensions/Retirement Tax Reform Working Group Committee on Ways and Means
2/20/13    Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and Derivatives Clearing Organizations (RIN 3038-AD 88)
9/14/12    Global Pension Coalition: Comments on Proposed Rules Related to Margin for Uncleared Swaps
8/27/12    Proposed Interpretive Guidance Regarding the Cross-Border Application of the Swap Provisions of the Commodity Exchange Act (RIN 3038-AD57) and Exemptive Order Regarding Compliance with Certain Swap Regulations (RIN 3038-AD85)  
7/30/12   Field Assistance Bulletin No. 2012-02 Thank You Letter
2/10/12   Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds
12/22/11   Further Comments on Protection of Cleared Swaps Customer Contracts and Collateral
  11/04/11    RIN 3038-AD60 / Swap Transaction Compliance and Implementation Schedule: Clearing and Trade Execution Requirements
11/02/11   PBGC - Joint Letter on Premiums 
9/30/11    RIN 3038-AD51 / Customer Clearing Documentation 
9/30/11 Stable Value Contract Study 
8/08/11 Protection of Cleared Swaps Customer Contracts and Collateral
7/22/11 Further Definition of "Swap," "Security Based Swap"
7/11/11 Margin Requirements for Uncleared Swaps
7/11/11 Proposed Rules Related to Marging for Uncleared Swaps
6/03/11 Relationship Documentation Requirements for SDs & MSPs
6/03/11 Reopening-Extension of Comment Periods SD Repositories
6/03/11 Reconciliation & Portfolio Compression for SDs and MSPs
6/03/11 Reopening & Extension of Comment Periods Swap Data
6/03/11 Business Conduct Standards for SDs and MSPs
4/11/11 Swap Trading Relationship Documentation for SDs & MSPs, and Orderly Liquidation Termination Provision in Swap Trading
3/25/11 Concerns and Questions: Pending Committment letter
3/08/11 Core Principles and Other Requirements for SEFs

Confirmation, Reconciliation, Compression for SDs & MSPs

2/22/11   Swap Data Repositories
2/22/11   Further Definition of Swap Dealer
2/22/11 Business Conduct Standards for Swap Dealers
2/22/11 Ten Organizations Joint Comment Letter
2/07/11 Swap Data Recordkeeping and Reporting Requirements
  Real-Time Reporting of Swap Transaction Data
  Reporting, Record Keeping, and Daily Trading Records
1/18/11 Protection of Cleared Swaps Customers Before and After
12/03/10 Investment of Customer Funds
11/18/10 Proposed Rule Defining Family Offices
11/3/10 Major SWAP Participant Status Would Harm Plans and Participants
11/1/10 Standardization for ERISA Plans
10/29/10 Segregation of Customer Margin for Cleard SWAPS
10/28/10 ERISA Pension Plans' Perspective
10/19/10 Business Conduct Standards and ERISA Plans
9/20/2010 Major SWAP Participant Letter
08/17/10 ABC and CIEBA Comment Letter on ISDA Additional Provisions Protocol
06/11/10 Senate SWAP Letter
06/11/10 House SWAP Letter
04/30/10 CIEBA Submits Comments to Request for Information on Lifetime Income in Retirement Plans
4/27/10 Coalition Comments on FBAR Regulations
1/19/2010 Joint Letter to Senate Agriculture Chair Blanche Lincoln on Pension Swap Investments
12/22/09 Joint Letter to Senate Agriculture Ranking Member Saxby Chambliss on Pension Swap Investments
1/19/2010 Letter to Congress on Funding Relief
12/22/09 Joint Letter to the President on Funding Relief
10/02/09 CIEBA Comments on Foreign Bank Account Reporting (FBAR)
10/01/09 Joint Letter to Congress on Funding Relief
9/30/09 CIEBA Comments on IAS 19 Employee Benefits Discount Rate
8/14/09 CIEBA Comments to SEC on Proxy Access Rules
7/29/09 Pension Industry Comment Letter to Legislators and Regulators on Pension Funding Relief
5/08/09 Joint Letter to the Department of Treasury on Urgent Pension Funding Solutions
11/06/08 Joint Comment Letter on PPA Delay
09/16/08 CIEBA Comments on Fee Disclosure
07/31/08 CIEBA's Comments on S. 3268, the Stop Excessive Speculation Act


Letter to Director Golden on the proposed FASB Staff Position.


Letter to PBGC Board and Director Millard on Investment Policy


Letter to Chairman Baucus on Delaying PPA Implementation


Letter to Chairman Kennedy on Delaying PPA Implementation


Letter to Senator Grassley on Delaying PPA Implementation


Letter to Senator Enzi on Delaying PPA Implementation


Comment Letter to Congressman Pomeroy


Comment Letter to Congressman Cantor


Comment Letter to Department of Labor on Fee Disclosure


Letter to the Senate Finance Committee on IRS "Greater of" Interpretation


Comment Letter to FASB on Valuation Guidance for Financial Reporting


Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles


Default Investment Regulation/QDIA Comment Letter


Employers' Accounting for Defined Benefit Pension and Other Postretirement Plans, an amendment of FASB Statements No. 87, 88, 106, and 132(R)


Letter to SEC Regarding Proposed Rule on Regulation NMS (National Market System)


Letter to SEC Regarding Proposed Rule on Regulation NMS (National Market System)


PTE 96-23 Amendments


Cross-Trading and INHAM/QPAM Exemptions


Proposed Rule on Regulation NMS (National Market System)


Letter to SEC Regarding Proposed Rule Amendments to Rules Governing Pricing of Mutual Fund Shares


Letter to SEC Regarding Proposed Rule Security Holder Director Nominations


Letter to SEC Regarding Possible Changes to Proxy Rules


Reference: GIPS Venture Capital and Private Equity Provisions


CIEBA Request for Class Exemption Regarding CrossTrading by�or�under the Supervision of an In-house Asset Manager


CIEBA of AFP Supports Changes to Pension Funding Discount Rate

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