In comments filed with the US Department of Labor, CFA and the National Employment Law Project (NELP) express skepticism regarding the Department’s proposed individual prohibited transaction exemption involving Retirement Clearinghouse, LLC (RCH). CFA and NELP fear that the program may leave investors no better off, and potentially worse off, than they are today while producing a windfall for a private company. Given these concerns, it’s imperative that the Department ensure that there are sufficient guard-rails in place to curb any potential abuse and ensure that if the program does not deliver on its stated objectives, the Department quickly terminates the exemption.

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