VIA FAX
February 2, 1996
TO: PENSION COMMITTEE No. 5-96
RE: DRAFT INSTITUTE COMMENT ON DOL PROPOSED PLAN ASSET
REGULATION
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Attached please find a draft of comments the Institute is preparing to submit to the
Department of Labor regarding its proposed regulation altering the time frame in which plan
assets must be deposited in trust. This draft will be discussed at the Pension Committee
meeting scheduled for Tuesday, February 6, 1996, and in greater detail, at the meeting
scheduled to discuss recent Department of Labor enforcement activity, which is scheduled for
the morning of Wednesday, February 7, 1996.
We are interested most particularly in comments and suggestions regarding (1) the
alternative time frame for deposit, which is proposed in the draft, and (2) the concept of
establishing an intermediate account for plan assets to enable data reconciliation to occur prior
to the allocation of plan assets to individual participant accounts.
Russell G. Galer
Assistant Counsel - Pension
Attachment