DOL hearing promises passionate support and resistance from industry — here's a sample

December 11, 2023 11:49 AM

The Department of Labor's public hearing about the "retirement security rule" proposal will fill two days with panels involving more than three dozen industry professionals and experts.

With the requests to testify and the hearing agenda for Dec. 12 and 13 posted on the agency's website, Financial Planning gathered excerpts from the most substantive preview filings by panel participants. The group of commenters includes the CFP Board, AARP, the Insured Retirement Institute, the Financial Services Institute, the Consumer Federation of America, the Securities Industry and Financial Markets Association, the U.S. Chamber of Commerce, the Public Investors Advocate Bar Association and the Financial Planning Association. The testimony reflects a wide spectrum of views on the potential changes to the definition of "fiduciary" advice to 401(k), IRA and other retirement savers in rollover transactions and certain insurance sales.

For a look at 30 wealth management and insurance professionals testifying at this week's public hearing on the Labor Department's retirement advice rule proposal, scroll down the slideshow. And find other coverage of the possible new regulation here:

Collective Wealth Partners

"Kamila Elliot, CFP, MBA, respectfully requests an opportunity to testify at the hearings on the Department of Labor's proposed 'retirement security rule and associated prohibited exemptions' being held on Dec. 12 and 13, 2023. …

"1. I am CEO and founder of the financial planning firm, Collective Wealth Partners, that provides holistic financial planning advice to black and other resilient communities. All our advisers are CFP professionals and investment advisers dedicated to providing fiduciary advice. I founded this firm because I saw friends and family struggling to find help planning their financial future.

"2. Black and resilient communities are vulnerable to receiving incompetent and unethical advice that can erode their retirement assets and cause financial instability. We see abuses of trust against vulnerable retirement savers on a regular basis. I will provide examples of abuses we have seen in investment advice and annuity sales to black and resilient communities.

"3. Moderate-income retirement investors will not lose access to ethical and competent investment advice after this rule is finalized.

"4. We do not expect a significant change in our business processes once this rule is finalized.

"5. I am pleased that the Department of Labor has proposed the 'retirement security rule,' which updates and modernizes requirements that reflect the reality of today's retirement savings marketplace. Today, retirement investors are responsible for choosing investments for their hard-earned retirement savings. Retirement investors deserve a financial adviser who will act as a fiduciary, in their best interests."

National Pension Partners

"My name is Nicholas Paleveda, a USCF chess master and 3X Florida State Chess champion. I have an MBA from the University of South Florida, a JD in law from the University of Miami, an LLM in tax law from the University of Denver and for 12 years, the former adjunct professor of the graduate tax program at Northeastern University where I was lead faculty for the retirement planning course. I have been an active member of the Florida Bar for 39 years and licensed before the U.S. Tax Court, the 11th Circuit Court of Appeals, the Ninth Circuit Court of Appeals and The Supreme Court. In the last 22 years I have been CEO of a [third-party administrator] firm that manages qualified plans for small companies. I am here to clear up the misconceptions concerning the retirement industry and the fiduciary rule. …

"The fiduciary rule as proposed is unworkable — it misleads the general public and is self-serving to a select group of 'fee-only' planners. Our empirical evidence showed that individuals and corporations set up of new plans reduced by 40% when advisors were confronted by this rule. In practice, it hurts the consumer as less small companies and individuals set up plans for retirement. If the objective is to have only large companies and the U.S. government have retirement plans, I would vote for this rule. But if you support small companies and small business owners, I would vote against this rule."

AARP

"AARP, which advocates for the more than 100 million Americans age 50 and older, would like to respectfully submit their request to testify at the virtual public hearing from Dec. 12-14, 2023, on the proposed retirement security rule: definition of an investment advice fiduciary and associated prohibited transaction exemption amendments. …

"AARP believes enhanced protections for retirement savers and leveling the playing field among financial advisers is critical. This rule addresses this by extending fiduciary requirements to rollover advice, closing regulatory gaps for non-securities products, and covering recommendations to employers.

"Because AARP believes the issues raised by this proposed regulation are extremely important, we request that AARP be given the opportunity to present our views at this hearing. Thank you for your consideration of our request."

Federation of Americans for Consumer Choice

"It is clear to FACC — as it surely must be to the Department — that these proposals are utterly irreconcilable with the holdings of the Fifth Circuit Court of Appeals' decision in Chamber of Commerce of United States of America v. United States Department of Labor (Fifth Circuit 2018). In Chamber of Commerce, the Fifth Circuit vacated the Department's 2016 'fiduciary rule' as being unauthorized and inconsistent with ERISA [the Employee Retirement Income Security Act]. Like the current proposal, the 2016 fiduciary rule displaced the Department's time-honored 1975 rule setting forth a five-part test for determining who is an investment advice fiduciary under the statute. …

"The Department's newly proposed definition proceeds to blatantly defy the holdings in Chamber of Commerce with the absence of any recognition or discussion of what constitutes a relationship of trust and confidence under common law. Remarkably, it skips over such analysis and replaces it with an assumption that a relationship of trust and confidence routinely exists in common commercial dealings between a financial professional and client. The proposed guidance looks only at whether an investor expects that he or she can 'place their trust and confidence' in a professional to recommend an investment that is in the investor's best interest — a far cry from the rigorous elements demanded by courts in order to find a fiduciary relationship under common law. Where the Fifth Circuit held that it would ordinarily be 'inconceivable that financial salespeople or insurance agents will have an intimate relationship of trust and confidence with prospective purchasers,' the proposed rule indefensibly provides that even one-time recommendations will be treated as fiduciary investment advice if 'the circumstances indicate that the recommendation is based on the retiree's particular needs and circumstances and may be relied upon for making an investment decision that is in the investor's best interest.' …

"This comment letter is not intended to be an exhaustive catalog of the problems with the Department's latest proposals. It is, instead, a preview of the legal challenge that awaits the new rule and exemption if and when they are promulgated by the Department. FACC wishes to make clear on the record that which is obvious from any objective reading of the latest proposal: the Department is transparently ignoring the clear dictates of Chamber of Commerce and once again attempting to circumvent Congress's intent in ERISA. The Fifth Circuit flatly rejected the Department's first effort in 2016; FACC has no doubt the courts will do the same if these proposals proceed.

"If the Department is truly open to consideration of the multiple ways in which the proposed rule departs from ERISA and the other industry and regulatory developments that obviate the need for further rulemaking — which FACC finds doubtful at this stage — we would urge these proposals be withdrawn in their entirety. This would spare the Department and industry unnecessary controversy and litigation, as well unnecessary confusion for investors as these repeated rulemaking efforts drag on incessantly. The Department itself seems to recognize that the SEC and state insurance departments are already addressing similar issues, and the Department's 2023 rulemaking package will therefore contribute little beyond a fresh round of legal actions."

CFP Board

"Dan Moisand, CFP, chair of the board of directors of CFP Board, respectfully requests an opportunity to testify at the hearings on the Department of Labor's proposed retirement security rule and associated prohibited exemptions being held on Dec. 12 and 13, 2023. My written testimony has not yet been submitted.

"I plan to make the following points:

"1. CFP Board has been a strong advocate in favor of a uniform fiduciary standard, consistent with the standard currently applied to investment advisers under the Investment Advisers Act of 1940. CFP Board's mission is to credential competent and ethical financial planners, uphold CFP certification as the recognized standard and advance the financial planning profession.

"2. CFP professionals work at firms representing the full cross-section of business and compensation models. Our professionals agree that they will deliver fiduciary-level services when providing financial advice. Our experience shows that advisers can, and currently do, successfully provide fiduciary level service under a variety of business models and compensation arrangements.

"3. Firms have been operating under Regulation Best Interest since 2020. Despite industry concerns about Reg BI causing them to leave unprofitable relationships, the number of investment advisers and the assets they manage have increased since Reg BI was implemented. Among other things, firms use technology to economically serve moderate-income investors, including those saving and investing for a secure retirement.

"4. The NAIC issued a model 'best interest' rule for insurance producers recommending annuities. The NAIC model Regulation does not apply a fiduciary standard and does not rise to a Reg BI standard.

"5. The proposed retirement savings rule updates the regulations under ERISA to reflect the realities of today's retirement marketplace. The proposed rule seeks to fill regulatory gaps that leave retirement investors vulnerable to advice that is not in their best interest."

Insured Retirement Institute

"We remain extremely troubled and disappointed by the Department's refusal to grant the reasonable request by IRI and 17 other financial services industry organizations to extend the comment period regarding the proposal and to postpone the hearing until sometime after the comment period closes, as has been the Department's longstanding custom. Nevertheless, IRI and our members have a significant interest in this rulemaking effort, and we look forward to sharing our views and perspectives to the best of our ability in the brief period of time you have provided for stakeholders to review, digest, analyze and formulate substantive feedback on this extremely consequential and complex regulatory package."

Consumer Federation of America

"My name is Micah Hauptman and I am the director of investor protection at the Consumer Federation of America. … If invited to testify, I would focus on the need for updating the regulatory definition of fiduciary investment advice under ERISA, and rebutting arguments put forward by various industry opponents regarding the proposed rule.

"Within these general topics, I would be prepared to comment on the following points:

"1. Why it's critical that loopholes in the current regulatory definition of fiduciary investment advice be closed so that rollover advice, advice to retirement plans, and advice regarding non-securities are covered.

"2. Why the Securities and Exchange Commission's Regulation Best Interest does not fully address the problem of conflicted retirement investment advice.

"3. Why the National Association of Insurance Commissioners' (NAIC's) 'model suitability rule for annuity transactions' does not provide the strong protections retirement investors need and expect.

"4. Why industry opponents' claim that the proposal is no different from the 2016 rule is meritless.

"5. Why industry opponents' claim that the proposal would result in a loss of access to advice is meritless and inconsistent with their legal claims before the Fifth Circuit that they provide arms' length commercial sales pitches like car dealers, not advice.

"6. Despite their legal claims to the contrary, market participants function as advice providers in positions of trust and confidence with the retirement savers they serve. The proposed redefinition appropriately captures the types of relationships and interactions that retirement savers reasonably view as advisory in nature."

Financial Services Institute

"FSI is an industry group that serves as the voice of independent broker-dealers and independent financial advisors. …

"Independent financial advisors are small-business owners and job creators with strong ties to their communities. These financial advisors provide comprehensive and affordable financial services that help millions of individuals, families, small businesses, associations, organizations, and retirement plans. Their services include financial education, planning, implementation, and investment monitoring. Due to their unique business model, FSI members and their affiliated financial advisors are especially well positioned to provide Main Street Americans with the affordable financial advice, products, and services necessary to achieve their investment goals.

"FSI has been an active participant in the regulatory process on this issue since 2010. While FSI has not yet had the opportunity to prepare written comments prior to this scheduled hearing, and DOL has rejected requests to move the hearing until after the comment period closes to allow adequate time to review the proposal and provide meaningful input, we remain committed to engaging at every opportunity in this process given that the proposal impacts thousands of FSI members and the Main Street Americans who our members assist in planning for a dignified retirement."

Ron Rhoades

"Associate professor of finance and director of the Personal Financial Planning Program, Gordon Ford College of Business, Western Kentucky University; and principal, Scholar Financial, LLC, a fee-only registered investment adviser. …

"My testimony will not represent the views of any institution, firm, organization, motley crew, gang or cult with whom I am presently associated or have ever been kicked out of. …

"1) I review the requirement that all choices in defined contribution plans governed by ERISA meet the requirements of the prudent investor rule, a tough standard of care which requires adequate diversification to minimize certain risks, not wasting plan participants' assets through high-fee/high-cost investments, and the minimization of the long-term tax drag upon investment returns.

"2) The argument made by some broker-dealer firms, asset managers, and insurance companies that the DOL's rulemaking limits 'choice' is a red herring. By its very nature, the fiduciary duties imposed by ERISA constrain conduct, and by doing so counter greed. The U.S. Supreme Court, when opining on ERISA's prudent investor rule, concluded that bad investment choices have no place in retirement plan accounts. Defined contribution plan accounts benefit from economies of scale, that should not be thwarted by high-cost products. The academic evidence is clear — higher-cost products underperform, on average, similar investments that have lower fees and costs.

"3) The DOL's rule proposals align with the common law imposition of fiduciaries for those in relationships of trust and confidence between the fiduciary and the entrustor. Very few plan sponsors are experts as to investment strategies and products. Plan sponsors rely upon those who provide recommendations as to investments and annuities for their expertise. Most 'retirement plan consultants' implicitly accept the imposition of fiduciary duties under common law principles through their titles, words and conduct. Yet many of these retirement plan consultants provide conflicted advice, or, even worse, provide illusory "fiduciary guarantees" that are meaningless. Plan sponsors, and plan participants, deserve the protection of fiduciary advice, and more importantly conflict-free investment recommendations.

"4) The DOL should go further: a. Plan sponsors, who are fiduciaries, should be cautioned to always engage only fiduciaries as investment consultants who proactively eschew conflicts of interest. A true fiduciary avoids revenue-sharing payments and other third-party compensation that create nefarious conflicts of interest, in recognition of the fact, as many a jurist has opined, that a fiduciary cannot serve two masters."

Insurance Coalition

"We write on behalf of the Insurance Coalition (the Coalition), a group of insurance companies that share a common interest in federal laws and regulations impacting the 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 write today because many Insurance Coalition members are impacted by the Department of Labor's (the Department) proposed 'retirement security rule: definition of an investment advice fiduciary' (proposal). While we support the Employee Benefit Security Administration's (EBSA) goal of protecting retirement investors, the proposal is a significant departure from current law and will require the members of our Coalition to navigate a myriad of federal regulations and state laws, which affect the members of the Coalition in different ways. Given the complexity and importance of this issue, we are writing to request an extension of at least 30 days beyond the current comment period, which is currently scheduled to end on Jan. 2, 2024.

"We are committed on behalf of our members and the entire insurance industry to provide as thoughtful, productive, and detailed a response to the Proposal as possible. Because of that commitment, we believe that the current comment period does not provide sufficient time to prepare such a response. Moreover, there is precedent for at least a 90-day comment period for such a proposal."

Kathleen McBride

"Founder, FiduciaryPath, 402(a) named fiduciary specialist, Fiduciary Wise, founding member and current chair, The Committee for the Fiduciary Standard. … My testimony is my own and will not reflect the views of any organization. …

"1. The importance of addressing the circa 1975 five-part test that was issued in an era during which corporate pensions were the norm, and employers were responsible for providing a pension plan for employees.

"2. Why it is crucial for all retirement savers to receive advice and recommendations that are solely in their best interest, from intermediaries who must act as a fiduciary for that advice, without carveouts, loopholes or escape hatches.

"3. Rollovers.

"4. A discussion of why 'choice' is a false narrative when that 'choice' would harm the retirement saver and at the same time enrich the provider of that 'choice,' false 'recommendation' or 'advice.'

"5. Why the discussion should continue regarding how many investment product providers had already started to change products, compensation, and procedures when the Fifth Circuit decision derailed the 2016 DOL Rule.

"6. How the claims from banks, broker-dealers and insurers who threatened to stop working with clients of more modest means were untrue. Other firms were, and still are, working as fiduciaries to clients of all sizes, inside and outside of retirement accounts.

"7. A discussion of the harm caused by high cost, low payout annuities with features that can be changed by the insurer, in the insurer's favor, and typically do not show how long it would take and how low the probability is for retirement investors to break even on an annuity.

"8. A discussion of insurance and brokerage compensation practices that materially harm retirement investors, especially those investors who have been falsely persuaded that they are receiving fiduciary recommendations or advice."

Groom Law Group

"We represent a client group that includes a number of the nation's leading providers of products and services in the retirement investment marketplace. These providers serve retail customers who pursue a number of goals, institutional investors who seek to manage retirement plan investment risk, and other intermediaries and individuals who aid in the effort to achieve retirement security. This client group has significant concerns regarding the Department's proposed 'retirement security rule' and the various proposed amendments to certain related prohibited transaction exemptions. …

"Our clients are working diligently to provide substantive comments on the proposal by the Department's Jan. 2, 2024 deadline. We are concerned, however, that the Department only provided 37 working days (excluding the two days that the Department will hold the hearing) in the comment period and that the Department has thus far declined requests to extend the comment period. We note that Assistant Secretary Gomez has asked groups to take a close look at the proposal and acknowledged that 'there have been so many changes since the last rule came out.' As a result, we were surprised when Assistant Secretary Gomez indicated that an extension that would allow for additional public input is unnecessary as 'EBSA believes that its current proposal reflects significant input it has received from public engagement with this project since 2010.' Without an extension, the Department authorizes a rushed process that will hinder the public's ability to digest and meaningfully comment on the complex and comprehensive proposed package."

Family Investment Center

"Dan Danford, CFP, founder/CEO, Family Investment Center, St. Joseph, Missouri. … I am a CFP registered advisor, and a member of the National Association of Personal Financial Advisors (NAPFA). Our firm is an SEC-Registered Investment Advisor since 1998 in the Kansas City/St. Joseph metro area. We offer financial planning and investment management services to upper middle-class families and individuals (primarily). All services are provided on a fee-only basis, and always have been. I wish to address the issue of fiduciary responsibility for all ERISA retirement accounts and clients. I began my career as a bank trust officer specializing in employee benefit accounts and have served as a professional fiduciary for almost 40 years."

Securities Industry and Financial Markets Association

"The Securities Industry and Financial Markets Association (SIFMA) requests to testify at the public hearing on the 'retirement security rule: definition of an investment advice fiduciary and associated prohibited transaction exemption amendments' on Dec. 12, 2023. On Nov. 8, 2023, SIFMA, along with 17 other trade associations, submitted a written comment to request an extension of the comment period. I, Lisa Bleier, managing director and associate general counsel, head of wealth management, retirement and state government relations at SIFMA, would be testifying."

Dana Muir

"My testimony would be in support of the proposed rule and related [prohibited transaction exemptions], including the proposed rule's foundation in ERISA's language, the importance of Department of Labor regulation of retirement plan assets, gaps in protections provided by other rules on investment advice, issues I have identified in my academic work on rollovers to IRAs and responses to industry criticisms of the rule.

"I am employed at the Ross School of Business at the University of Michigan, however, my testimony would be on my own views as an academic who has studied ERISA for more than 30 years and not as a representative of my employer."

U.S. Chamber of Commerce

"U.S. Chamber of Commerce represents approximately 300,000 direct members and indirectly [represents] the interests of more than 3 million companies and professional organizations of every size, in every industry sector and from every region of the country. Many of the Chamber's members sponsor and provide services to ERISA-governed retirement plans and retirement vehicles governed by the Internal Revenue Code."

Public Investors Advocate Bar Association

"The Public Investors Advocate Bar Association ("PIABA") is an international bar association comprised of attorneys who represent investors in disputes with the securities industry. Since its formation in 1990, PIABA has promoted the interests of the public investor in all securities and commodities arbitration forums, while also advocating for public education regarding investment fraud and industry misconduct.

"PIABA requests to testify in support of the proposed rule. PIABA would like to provide examples of American investors who have been harmed and how this rule change will benefit these investors going forward."

American Retirement Association

"The American Retirement Association (ARA) is comprised of the American Society of Pension Professionals & Actuaries (ASPPA), the American Society of Enrolled Actuaries (ASEA), the National Association of Plan Advisors (NAPA), the National Tax-Deferred Savings Association (NTSA) and the Plan Sponsor Council of America (PSCA). Brian Graff, the CEO of the ARA, will be testifying on behalf of the ARA. Mr. Graff's testimony will concern the applicability of the proposed retirement security rule and related proposed amendments to prohibited transaction amendments to, among other things, small retirement plans and service providers to those plans."

Financial Planning Association

"The Financial Planning Association (FPA), is the leading membership organization for certified financial planner professionals and the only organization solely representing those individuals engaged in the financial planning process. FPA supports nearly 17,000 members and 79 chapters and state councils across the country, and encourages high standards of professional competence, ethical conduct and clear, complete disclosure when serving clients."

The Committee of Annuity Insurers

"The Committee is a coalition of life insurance companies formed in 1981 to participate in the development of federal policy with respect to tax, securities, ERISA and banking law issues affecting annuities. The Committee's current 32 member companies represent approximately 80% of the annuity business in the United States and are among the largest issuers of annuity contracts to IRAs and employer-sponsored retirement plans."

Benjamin Edwards

"I am a law professor at the William S. Boyd School of Law at the University of Nevada, Las Vegas. I write in my personal capacity to request to testify on my own behalf at the upcoming hearing on the 'retirement security rule: definition of an investment advice fiduciary and associated prohibited transaction exemption amendments.' Much of my academic career has focused on investor protection issues. …

"If invited to testify, I would focus on the need for implementing a consistent fiduciary standard for retirement savers, and on rebutting arguments put forward by various industry opponents regarding the proposed rule.

"Within these general topics, I would be prepared to comment on the following points:

"1. How industry opposition to fiduciary reforms has a history of making false or incomplete statements to regulators;

"2. Why existing regulations such as the Securities and Exchange Commission's 'Best Interest' standard or the National Association of Insurance Commissioners' 'Best Interest' standard fall short; and

"3. How conflicts of interest in the advice process may undercut our economy's ability to allocate capital effectively."

National Association for Fixed Annuities

"We will be presenting the viewpoint of NAFA membership, which represents the fixed annuity marketplace and, in particular, the independent distribution channel. NAFA member companies and entities include insurance carriers, independent marketing organizations, industry-supporting technology and consulting companies, and independent producers, advisors, brokers, and general agents."

Alternative and Direct Investment Securities Association

"ADISA supports the Department's efforts to improve access to wise financial advice and appreciates the opportunity to continue this discussion of important issues for the protection of investors and their ability to access alternative markets."

Finseca

"I [CEO Marc Cadin] will be testifying on behalf of Finseca, an organization representing more than 8,700 financial security professionals who help Americans achieve financial security through holistic financial plans that include investments, retirement (including annuities), and life insurance. Independent research by Ernst and Young confirms such planning produces better outcomes for all consumers who use it."

Donald Jones

"Founder, Fiduciary Wise, ERISA 402(a) named fiduciary and ERISA 3(16) plan administrator fiduciary firm, steering committee for the Committee for the Fiduciary Standard, founder and first chairperson for the Committee for Board Certified Fiduciaries. … My testimony is my own and will not reflect the views of any organization. …

"I was involved in my first retirement plan in 1973, that's right, pre-ERISA, and now over 50 years later I suppose I have been involved in over 5,000-10,000 ERISA plans. But approximately 15 years ago I decided to leave corporate America in various service provider capacities to become an independent ERISA 402(a) named fiduciary, because I was convinced the financial industry had been less than honest with the plan fiduciaries, plan participants and the beneficiaries that plan fiduciaries dealt with. …

"The main reason that so many plan participants receive non-fiduciary services that are not the 'highest standards known to law' is that so many firms and individuals in the investment industry avoid their ERISA fiduciary duties by using the outdated five-part test in the 1975 definition of who is an investment fiduciary.

"Testimony I would welcome to give:

"1. The 1975 definition of an investment fiduciary originated in a predominantly defined-benefit world, where the plans were managed generally by an ERISA 3(38) investment manager. Today's ERISA DC plans are generally managed by the plan participants and, most often with some help by non-fiduciary brokers. The nearly 50-year-old definition of an investment fiduciary does not meet what today's retirement savers need — advice that is solely in the best interest of plan participants. That must be changed for the protection of the innocent and unsophisticated plan participant and their beneficiaries. And may I add, what a great job the U.S. Department of Labor EBSA division did on these new proposed changes.

"2. The greed-based argument that a change in the 1975 definition would limit the 'choice' is false in every way.

"3. The DOL's proposal to align all retirement plans under one umbrella as it relates to fiduciary governance under Title I of ERISA is not only correct, but again, in the best interest of the participants and beneficiaries."

Investment Company Institute

"The institute will submit a comment letter on the proposed definition of an investment advice fiduciary and associated prohibited transaction exemption amendments at a later date. The Institute's testimony will express concerns with the proposal and its potential impact on retirement savers."

Betterment

"Betterment was launched in 2010 and pioneered the use of technology to provide investment advisory services primarily over the internet. Betterment's offering is focused on long-term goals and building wealth. We help clients identify savings goals (such as retirement), select managed portfolios, and track their progress towards those goals. Our portfolios are composed primarily of globally diversified, low-fee exchange-traded funds. We serve individual investors (including through relationships with third-party advisers), as well as employer-sponsored retirement plans through our Betterment at Work platform. As of August 30, 2023, Betterment managed over $40 billion on behalf of over 800,000 clients, with a median age of around 40."

American Investment Council

"The AIC is an advocacy and resource organization established to develop and provide information about the private investment industry and its contributions to the long-term growth of the U.S. economy and retirement security of American workers. Member firms of the AIC consist of the country's leading private equity and growth capital firms united by their successful partnerships with limited partners and American businesses."

Spark Institute

"The Spark Institute represents retirement plan recordkeepers, mutual fund companies, brokerage firms, insurance companies, banks, consultants, trade clearing firms and investment managers. Collectively, our member firms administer the retirement plans for over 110 million American workers."

Institute for Portfolio Alternatives

"The IPA is the leading trade organization representing asset managers, broker-dealers, registered investment advisers and other entities that provide portfolio diversifying investments to investors. For over 35 years, the IPA has advocated for increased investor access to alternative investment strategies with low correlation to equity markets, as part of a diversified portfolio. Such strategies include real estate, public and private credit and other real assets through investment vehicles such as non-listed real estate investment trusts and business development companies, closed-end funds and interval funds, among others."