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CIEBA of AFP

The Committee on Investment of Employee Benefit Assets


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CIEBA is composed of more than 100 of the largest corporate pension funds in the U.S. with more than 1.4 trillion in retirement plan assets under management on behalf of more than 16 million plan participants and beneficiaries.

Comment Letters

07/31/08 CIEBA's Comments on S. 3268, the Stop Excessive Speculation Act

05/02/08

Letter to Director Golden on the proposed FASB Staff Position.

05/02/08

Letter to PBGC Board and Director Millard on Investment Policy

12/11/07

Letter to Chairman Baucus on Delaying PPA Implementation

12/11/07

Letter to Chairman Kennedy on Delaying PPA Implementation

12/11/07

Letter to Senator Grassley on Delaying PPA Implementation

12/11/07

Letter to Senator Enzi on Delaying PPA Implementation

11/01/07

Comment Letter to Congressman Pomeroy

11/01/07

Comment Letter to Congressman Cantor

7/24/07

Comment Letter to Department of Labor on Fee Disclosure

6/13/07

Letter to the Senate Finance Committee on IRS "Greater of" Interpretation

4/13/07

Comment Letter to FASB on Valuation Guidance for Financial Reporting

3/9/07

Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles

11/10/06

Default Investment Regulation/QDIA Comment Letter

05/31/06

Employers' Accounting for Defined Benefit Pension and Other Postretirement Plans, an amendment of FASB Statements No. 87, 88, 106, and 132(R)

08/12/05

Letter to SEC Regarding Proposed Rule on Regulation NMS (National Market System)

01/25/05

Letter to SEC Regarding Proposed Rule on Regulation NMS (National Market System)

07/29/04

PTE 96-23 Amendments

07/16/04

Cross-Trading and INHAM/QPAM Exemptions

06/24/04

Proposed Rule on Regulation NMS (National Market System)

02/06/04

Letter to SEC Regarding Proposed Rule Amendments to Rules Governing Pricing of Mutual Fund Shares

12/22/03

Letter to SEC Regarding Proposed Rule Security Holder Director Nominations

06/13/03

Letter to SEC Regarding Possible Changes to Proxy Rules

04/16/03

Reference: GIPS Venture Capital and Private Equity Provisions

02/21/03

CIEBA Request for Class Exemption Regarding CrossTrading by or under the Supervision of an In-house Asset Manager

02/13/03

CIEBA of AFP Supports Changes to Pension Funding Discount Rate

11/15/02

Letter Elliot Spitzer concerning the use of lawsuits as the means to address conflicts of interest between research and investment banking

06/18/02

Letter to Richard Grasso, Chairman and CEO, NYSE: Re: CIEBA Commends the Work of the New York Stock Exchange Committee on Corporate Accountability and Listing Standards

06/18/02

Letter to Rep. Cardin and Rep. Portman: Re: CIEBA Support of Enactment of H.R. 4931, The Retirement Savings Security Act of 2002

12/3/01

Scope Exceptions: Contracts Subject to Statement 35, Statement of 110 or Statement Position 94-4.

08/10/01

Letter and Application to Karen Lloyd: Re:  Application No. D-11024

06/29/01

Letter to Ivan Strasfeld: Re: CIEBA Request for "Cross Trading" Class Exemption

06/08/01

Letter to Robert Pickel, Esq: Re: Proposed Amendments to 1992 ISDA Master Agreement

01/12/01

CIEBA Response to DOL Disclosure Obligations Under ERISA; Request for Information; Notice (09/14/00)

10/25/00

House and Senate Members:  Re:  H.R. 1102 Tax Relief Bill

07/17/00

2000 W Allen Reed Letter

06/02/00

Letter to E.F. Williams: Proposed Class Exemption for Securities Cross-Traded by Index/Model-Driven Funds

05/12/00

Letter to Jonathan Katz:  Re: File No. SR-NYSE-99-48

02/14/00

CIEBA comments to DOL on Class Exemption for Securities Cross-Trade

01/24/00

CIEBA comments to SEC on Role of Independant Directors of Investment Companies

07/10/99

Letter to the Honorable Bill Archer on 401(k) Protection Act

01/29/99

Letter to Mr. David M. Strauss on the impact of tax revenues on defined benefit Plans

05/19/98

Letter to Pension and Welfare Benefit Administration on cross trades of securities

04/28/98

Recommendation on Defined Contribution Fee Disclosure

1997

Top 50 List of Underfunded Defined Benefit Pension Plans Eliminated

11/12/97

Letter to Dept. of Labor on Form 5500

07/21/97

Letter to the Honorable Newt Gingrich on the Boxer Amendment

07/18/97

Letter to the Honorable Dick Armey on the Boxer Amendment

07/14/97

Letter to the Honorable John Kasich 401(k) Protection Act

05/15/97

Letter to PBGC Regarding the Adoption of More Current Mortality Tables for Benefit Valuation and Asset Allocation

05/15/97

Letter to Office of the General Counsel on mortality tables

04/09/97

Letter to the Honorable Harris Fawell on the Savers Act

04/07/97

Letter to the Honorable Barbara Boxer on limiting investment in employer stock

02/03/97

Letter to GAO on assets supported by insurance general accounts

09/19/96

Letter to the Honorable Barbara Boxer on Section 1837

02/05/96

Letter to the Honorable Olena Berg on the bulletin on participation investment information

10/17/95

Letter to the Honorable Bill Archer on pension asset transfer provision

10/05/95

Letter to the Honorable Olena Berg on Key Savings and Investment Concepts

07/28/95

Letter to Mr. Ivan Strasfeld on proposed class exemption

07/24/95

Letter to Principles Drafting Committee

07/01/94

Letter to the Honorable Edward Markey opposing derivatives legislation

06/01/94

Letter to the Honorable Daniel Patrick Moynihan opposing Section 901

12/15/93

Letter to Ms. Susan Hicks on Reporting on Investment Contracts

11/08/93

Letter to President William Clinton on NAFTA

11/02/93

Letter to the Honorable Dan Rostenkowski on Unrelated Business Tax Income

10/18/93

Thank you letter to Ms. Sandra Kinet

09/23/93

Investment Practices of ERISA-Governed U.S. Benefit Plans

06/28/93

Letter to the Honorable Olena Berg on proposed prohibition transaction exemption for real estate performance fees

06/28/93

Letter to Mr. Jonathan Katz on securities transaction settlements

09/21/92

Letter to Mr. Jonathan Katz on Bachmann Task Force Report

06/24/92

Letter to Mr. Melvin Thomas on real estate issues for institutional investors

03/13/92

Letter to Mr. Jonathan Katz regarding Release No. IA-1299

10/03/91

Letter to the Honorable David Ball on participant directed individual accounts

09/24/91

Letter to the Honorable Ann Combs on foreign exchange class redemptions

05/13/91

Letter to the Office of Regulations and Interpretations on reposed 404(c) regulations

02/25/91

Letter to Ms. Linda Quinn on corporate proxy rules

09/14/90

Letter to Ms. Jean Webb on CME

03/15/89

Appreciation letter to Mr. Peter McPherson

08/06/87

Letter to Ms. Jean Webb on CME

07/06/87

Letter to Mr. William Proxmire on Section 1323

12/05/86

Letter to Mr. Jonathan Katz on NYSE listing

1993

Comments on Circuit Breakers

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