SPARK Inst 408b2 comment 02112008 FINAL

714 HOPMEADOW STREET, SUITE 3 ROBERT G. WUELFING, PRESIDENT SIMSBURY, CT 06070 LARRY H. GOLDBRUM, GENERAL COUNSEL (860) 658-5058 Filed Electronically February 11, 2008 Office of Regulations and Interpretations Employee Benefits Security Administration Attention: 408(b)(2) Amendments Room N-5655 U.S. Department of Labor 200 Constitution Ave., NW Washington, DC 20210 Re: 408(b)(2) Regulations Amendment Ladies and Gentlemen: 1The SPARK Institute, Inc. appreciates this opportunity to comment on the proposed amendment to the regulations under Section 408(b)(2) (the “Proposed Regulations”) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and the related prohibited transaction class exemption (the “Proposed Exemption”) issued by the Employee Benefits 2Security Administration (“EBSA”) on December 13, 2007. The SPARK Institute members include the retirement plan service providers, such as record keepers and investment fund managers, who will be directly affected by any new fee disclosure rules. At the outset, we commend EBSA for attempting to take a measured and flexible approach to address the extremely complex issues relating to fee disclosure in the retirement plan industry. 1 The SPARK Institute represents the interests of a broad based cross section of retirement plan service providers, including members that are banks ...