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The Resource for the Global Finance Profession

Position Statements

04/14

Benefit Headlines - April 2014

04/14

Pension Provisions in the Administration's FY 2015 Budget

03/14 

Tax Reform Act of 2014

05/12

Pension Interest Letter to Congress

04/12 

Preserve the Employer-Provided Retirement System

01/08

Mandating Investment Options in Defined Contribution Plans

03/06

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

03/06

Possible Legislative Guidelines for Constructing the Corporate Bond Yield Curve

09/05

CIEBA Report: Final Impact of Pension Reform

04/05

CIEBA Principles for Pension Reform

03/04

The CIEBA Report: The U.S. Pension Crisis


Comment Letters

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
2/28/11

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

05/02/08

Letter to Director Golden on the proposed FASB Staff Position.

05/02/08

Letter to PBGC Board and Director Millard on Investment Policy

12/11/07

Letter to Chairman Baucus on Delaying PPA Implementation

12/11/07

Letter to Chairman Kennedy on Delaying PPA Implementation

12/11/07

Letter to Senator Grassley on Delaying PPA Implementation

12/11/07

Letter to Senator Enzi on Delaying PPA Implementation

11/01/07

Comment Letter to Congressman Pomeroy

11/01/07

Comment Letter to Congressman Cantor

7/24/07

Comment Letter to Department of Labor on Fee Disclosure

6/13/07

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

4/13/07

Comment Letter to FASB on Valuation Guidance for Financial Reporting

3/9/07

Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles

11/10/06

Default Investment Regulation/QDIA Comment Letter

05/31/06

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

08/12/05

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

01/25/05

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

07/29/04

PTE 96-23 Amendments

07/16/04

Cross-Trading and INHAM/QPAM Exemptions

06/24/04

Proposed Rule on Regulation NMS (National Market System)

02/06/04

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

12/22/03

Letter to SEC Regarding Proposed Rule Security Holder Director Nominations

06/13/03

Letter to SEC Regarding Possible Changes to Proxy Rules

04/16/03

Reference: GIPS Venture Capital and Private Equity Provisions

02/21/03

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

02/13/03

CIEBA of AFP Supports Changes to Pension Funding Discount Rate

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