January 13, 1992
TO: PENSION COMMITTEE NO. 4-92
RE: PROHIBITED TRANSACTION EXEMPTIONS 77-4 AND 77-9
__________________________________________________________
Attached for your review prior to the upcoming Pension
Committee Meeting is a draft letter to the Department of Labor
requesting an information letter concerning certain prohibited
transaction issues under Prohibited Transaction Class Exemption
77-9, raised by a recent individual exemption application.
Please review the scenarios presented, especially those dealing
with principal and agency transaction distinctions, to determine
whether they are consistent with industry practices.
Also attached is a recent request from the Department of
Labor concerning industry practice under Prohibited Transaction
Class Exemption 77-4, which we will also discuss at our upcoming
meeting.
Kathy D. Ireland
Associate Counsel - Pension
Attachments