Federal Regulatory Affairs

Developing Industry Positions on Legislative and Regulatory Issues

Committee Objectives

1. To provide a forum for developing industry consensus on federal rulemakings by federal regulatory agencies and self-regulatory agencies, including the SEC, FINRA, Department of Treasury and Department of Labor.
2. To assist the Insured Retirement Institute staff in conveying the Institute's position to the appropriate members of Congress, the Executive Branch, and federal regulators.

Current Working Groups

1. Fiduciary Standard Working Group
2. Treasury/Labor RFI Working Group
3. DOL Fiduciary Definition Working Group
4. VA Summary Prospectus Working Group

Committee Initiatives

1. Submitting the following comment letters to the Securities and Exchange Commission, FINRA, Department of Labor, and Department and Treasury and other federal agencies on rulemaking  proposals, including:
   1. Lifetime Income Disclosure Act
   2. Proposed Department of Labor Fiduciary Definition Rule
   3. SEC Study on the Uniform Fiduciary Standard of Care
   4. Request for Information by the Departments of Treasury and Labor Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans
   5. Draft Proposed SEC Rule to Permit the use of a Variable Annuity Summary Prospectus
   6. SEC Request for Comments on Existing Private and Public Efforts to Educate Investors
2. Identifying other initiatives that would be beneficial to the industry and consumers and developing action plans to advance those initiatives

Federal Legislative & Regulatory Issues - IRI Testimony & Comment Letters

1. IRI Comment Letter to SEC Staff Regarding SEC Release NO. 34-64306 Comment Request on Existing Private and Public Efforts to Educate Investors (June 21, 2011)
2. IRI Comment Letter Regarding FINRA Regulatory Notice 10-25 Registration and Qualification Requirements for Certain Operations Personnel (July 30, 2010)
3. IRI Response to Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans (April 29, 2010)
4. IRI Comment Letter to Assistant Secretary Phyllis Borzi, Department of Labor's Employee Benefits Security Administration, Regarding Proposed Fiduciary Rule (February 3, 2011)
5. IRI Hearing Testimony to the Department of Labor Regarding Proposed Fiduciary Rule (March 1, 2011; testimony provided on behalf of IRI by Theresa Antanasio, Ameriprise)
6. IRI Follow-Up Comment Letter to the Department of Labor Regarding Proposed Fiduciary Rule (April 8, 2011)

Committee Meetings

1. In person: At selected IRI conferences and as needed.
2. Conference calls: Regularly, as needed.

Committee Minutes

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Committee Participation

The committee has nearly 200 members, representing more than 60 companies and organizations.

How Do I Join?

You must be a member of the Insured Retirement Institute to participate. Complete this form to be added to this committee.

Committee Leadership

Chair: Dan Fitzpatrick, Executive Director, Legal and Compliance, Morgan Stanley Smith Barney

Insured Retirement Institute Liaison

Lee Covington, SVP, Government & Regulatory Affairs, and General Counsel
John Little, SVP, Federal Affairs
Karen Alvarado, Vice President, Regulatory Affairs and Compliance