The ERISA Industry Committee Warns Regulators Against Banking Changes that Disadvantage Retirement Plans

WASHINGTON – January 16, 2024 — The ERISA Industry Committee (ERIC) today told regulators that a proposed regulation targeting banks would unfairly and negatively impact private sector defined benefit retirement plans and ultimately harm plan participants – retirement savers who count on plan funds to provide a secure, comfortable post-employment life for themselves and their families.
ERIC outlined its comments in a letter to the Office of the Comptroller of the Currency, the Federal Reserve System, and the Federal Deposit Insurance Corporation regarding a proposed rule, “Large Banking Organizations and Banking Organizations with Significant Trading Activity” (colloquially known as the “Basel III Endgame”).  The proposed rule would constitute a wholesale overhaul of the capital holding requirements for banks.
“The ‘Basel III Endgame’ proposal provides preferential treatment to publicly traded entities but fails to include many ERISA-covered pension plans, including those sponsored by ERIC member companies,” said Andy Banducci, ERIC Senior Vice President, Retirement and Compensation.  “If it is implemented without improvement, the proposed rule will create relative disadvantage for these pension funds, and ultimately produce higher costs and more risks that will harm plan participants.”
The full text of ERIC’s response to regulators is here.


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About The ERISA Industry Committee
ERIC is a national advocacy organization that exclusively represents large employers that provide health, retirement, paid leave, and other benefits to their nationwide workforces. With member companies that are leaders in every sector of the economy, ERIC advocates on the federal, state, and local levels for policies that promote flexibility and uniformity in the administration of their employee benefit plans.