Insurance Coalition Issues Public Comment to Labor Dept.

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WASHINGTON, Jan. 17 -- The Insurance Coalition has issued a public comment to the U.S. Department of Labor. The comment was written on Jan. 2, 2024, and posted on Jan. 10, 2024.

The comment was signed by Kendra Isaacson.

The comment was on Docket No. EBSA-2023-0015-0001, was sent to Lisa M. Gomez, Assistant Secretary.

Here are excerpts:

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We write on behalf of the Insurance Coalition (the "Coalition"), a group of various types of insurance providers that share a common interest in federal regulations affecting the insurance industry. The group was formed during congressional negotiations on the Dodd-Frank Act and continues to represent a diverse cross-section of life and property and casualty insurance companies. We appreciate the opportunity to provide comments on the Department of Labor's (the "Department") proposed "Retirement Security Rule: Definition of Fiduciary,"/1 Proposed Amendment to Class Exemption PTE 2020-02,2 Proposed Amendment to Prohibited Transaction Exemption 84-24,3 and Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-1284 (referred to collectively hereinafter as "the Proposal" or "Proposed Rule").

Executive Summary

While the Coalition is supportive of the Administration's goal of protecting retirement savers, we are greatly concerned that this Proposal may indeed hurt those it is intended to protect not only...

1 Retirement Security Rule: Definition of an Investment Advice Fiduciary, 88 Fed. Reg. 75,890 (proposed Nov. 3, 2023).

2 Proposed Amendment to Prohibited Transaction Exemption 2020-02," 88 Fed. Reg. 75,979 (Nov. 3, 2023).

3 Proposed Amendment to Prohibited Transaction Exemption 84-24," 88 Fed. Reg. 76,004 (Nov. 3, 2023).

4 Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86128, 88 Fed. Reg. 76,032 (Nov. 3, 2023).

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...by reducing access to financial education but also restricting or eliminating consumer choice as well as reversing the progress Congress has made over the last several years in improving access to lifetime income. To that end, the members of the Coalition are concerned that the negative implications of the Proposal far outweigh the intended benefits. The Proposal is a significant departure from current law as well as the complicated landscape of other federal regulations and state laws governing the insurance industry.

The Coalition has included in this comment letter the questions we asked during the Department's hearing on the Proposal, and as requested, we have provided our preferred answers to certain questions as the Coalition is concerned that some of these questions raise greater structural issues regarding the entirety of the Proposal than we could resolve in this comment letter.

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Conclusion

We appreciate the opportunity to provide these comments and thank you in advance for your consideration of our views. Please do not hesitate to contact us should you have any questions or need additional information as you continue your work on this rulemaking.

Sincerely,

Kendra Isaacson, The Insurance Coalition

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Original text here: https://downloads.regulations.gov/EBSA-2023-0015-0063/attachment_1.pdf