DEPARTMENT OF LABOR PROPOSED REGULATIONS RELATING TO THE DEFINITION OF PLAN ASSETS UNDER ERISA

by Robert S. Goldfarb on February 27, 1980
by Robert S. Goldfarb

Mr. Ian D. Lanoff, Administrator
Pension and Welfare Benefit Programs
U.S. Department of Labor
200 Constitution Ave., N.W.
Washington, D.C. 20216

Dear Mr. Lanoff:
This letter is in response to the Department of Labor’s (DOL’s) request for comments on its proposed regulation defining pension plan assets under the Employee Retirement Income Security Act of 1974 (45 FR 7521). DOL particularly invited “testimony on the present and anticipated effects of the proposal on investment… in
companies which are sources of capital for small businesses, including venture capital companies.”  The Council on Wage and Price Stability has reviewed DOL’s proposed regulation, and is concerned that there is no analysis of either its
benefits or its costs. Moreover, the categories of benefits and costs that DOL considers pertinent are not specified. Such an analysis is essential for effective evaluation of the proposed rule. The Council staff has identified a number of benefit and cost elements that should be considered in a DOL analysis. These are described in the attached memo. The Council urges DOL to withhold final action on the proposed rule until DOL provides an analysis of its benefits and costs.
Sincerely,

R. Robert Russell

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