September 18, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 45-91
RE: LABOR HEARING ON PROPOSED FOREIGN EXCHANGE EXEMPTION
__________________________________________________________
As you recall, a proposed ERISA prohibited transaction
class exemption relating to certain employee benefit plan foreign
exchange transactions was discussed at the last Investment
Advisers Committee meeting. The exemption provided a method
whereby custodian banks could execute foreign exchanges for the
plans for which they serve as parties-in-interest or fiduciaries.
However, the exemption did not extend to standing orders, a
common practice in this area.
The Department of Labor announced on September 16, 1991
that it will hold a public hearing on Thursday, October 3, 1991
regarding the proposed exemption because of the substantial
number of comments it received requesting broadening of the
exemption. Requests to be heard should be submitted by September
20, 1991. A copy of the notice of public hearing is attached.
Also attached is a copy of the proposed exemption.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
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