1 See Institute Memorandum to Pension Members No. 47-96, dated September 25, 1996 and Institute Memorandum to Pension Committee No. 32-96, dated July 10,
1996.
VIA FAX
October 10, 1996
TO: PENSION COMMITTEE No. 44-96
RE: DRAFT BUNDLED SERVICES ADVISORY OPINION REQUEST FOR REVIEW
AND COMMENT
______________________________________________________________________________
Attached for your review is a draft request for an advisory opinion regarding the
treatment of bundled services products under ERISA’s prohibited transaction rules. The
Institute plans to file this submission jointly with the American Bankers Association next week.
As you were previously informed1, this request is the result of several meetings with the
Department of Labor regarding other pending advisory opinion requests relating to bundled
services, most notably, the "Frost Bank" letter request.
As we intend to file this next week, please submit any comments by close of business on
Friday, October 11, 1996. Comments or editing suggestions can be sent by fax at either
202/326-5839. Alternatively, you can discuss the draft with either Cathy Heron (202/ 326-5830)
or myself (202/326-5835).
Russell G. Galer
Assistant Counsel - Pension