Office of Regulations and Interpretations
Pension and Welfare Benefits Administration
U.S. Department of Labor
Room N-5669
200 Constitution Avenue, NW
Washington, DC  20210

Attention: 2001 National Summit on Retirement Savings

TO WHOM IT MAY CONCERN:

CIEBA was formed sixteen years ago to provide a nationally recognized voice exclusively for ERISA-governed corporate pension plan sponsors on current fiduciary and investment issues.  It is an organization representing over 100 of the largest corporate pension funds in the United States.  Its membership consists of corporate financial officers who administer and manage, as fiduciaries, the investment of over $1 trillion in retirement plan assets on behalf of over 15 million plan participants and beneficiaries.

CIEBA supports improved retirement security and increased investment management efficiency by:

• Informing pension plan sponsors of legislative, regulatory and investment issues affecting defined benefit and defined contribution plans.
• Providing a forum for discussion of these issues and development of effective solutions.
• Helping its members address these issues and effectively conduct their fiduciary responsibilities.
• Serving as an informative resource representing the views of corporate pension plan sponsors to legislative and regulatory bodies.
• Supporting constructive policy and legislative initiatives.
• Building understanding and support of the private industry pension system.

CIEBA is a unique organization with a focus on the investment of funds for federally regulated pension, profit-sharing, employee saving and employee welfare plans.  CIEBA has testified before Congress and regulatory agencies to express opinions on various issues, including retirement savings.

Additionally, it is via surveys of its membership where CIEBA can provides exclusive information on trends within the industry and on issues members are currently addressing.  The Membership Profile Survey, conducted annually, highlights trends in asset allocation, equity turnover, indexation, internal and external management and cash funding assumptions.  In 1999, over 100 CIEBA members responded to the survey and collectively were responsible for the management of approximately $807 billion in pension assets and $515 billion in defined contribution plan assets which provide benefits for 15.2 million plan participants.

Although DC plan assets have grown faster than those of DB plans, almost twice the number of employees are covered by DB plans and almost 60% of the benefit payments and distribution come from DB plans.  By comparison, contributions to DC plans were six times greater than those to DB plans in 1999.  While DC plan assets are growing in both size and importance, the DB plans remain the cornerstone of the retirement plans for most of the employees of CIEBA's member companies.  This survey confirms the importance of traditional defined benefit plans in providing income security.

With the increasing trend towards providing retirement benefits through defined contribution plans, these plans are also increasingly giving participants control over the investment of their plan accounts.  In order for participants in these plans to effectively accumulate assets for their retirement, they must be knowledgeable about financial and investment matters or be able to obtain qualified financial advice. An important way to address this issue is through education.  CIEBA has long been an advocate of investment education for plan participants and many CIEBA companies have undertaken comprehensive participant education efforts.  These education programs have covered general investment concepts such as the power of compounding, the risk of inflation, asset allocation and diversification.  They also may cover estimating retirement income needs.  The programs are provided through a number of different vehicles, such as phone voice response systems, newsletters and brochures, internet sites and seminars. CIEBA is able to demonstrate an increasing trend towards providing participant investment education programs from 1994 through 1998.

However, investment education alone is not sufficient.  Many plan participants are asking for more guidance or "advice" on how to apply the general financial and investment concepts to their particular situations.  The issue now is how best to provide it.  CIEBA believes that the topics of investment education and advice are extremely relevant and timely topics for discussion at the upcoming Summit.

The on-going debate on Social Security is one that CIEBA continues to monitor.  In an effort to further the public and private education on this subject, CIEBA released a report prepared at its request on "Implications of Investing Social Security Funds in Financial Markets".  The report was prepared by economists at four leading investment firms who examined scenarios for investment of a portion of the Social Security Trust Fund in equities and prepared an independent study that addressed long-term expected return, liquidity implications, effect on interest rates, and influence on corporate American.  The  analyses and overall report may be helpful to the Summit as the debate continues on Social Security reform and the merits of private investment of Social Security funds.

CIEBA supports the SAVER ACT and believes it will help to further the debate on a more secure retirement system for the nation's employees and our plan participants and their beneficiaries.

CIEBA offers these comments and looks forward to working further to establish an agenda for this Summit and to participating in the Summit.

Sincerely,

/s/ Robert Angelica
Chairman