DOL reviews foreign currency exemption paperwork rules
Published Date: 3/14/2025
Notice
Summary
The Department of Labor is asking for public feedback on rules that banks and brokers must follow when handling foreign currency trades for employee benefit plans. These rules help protect workers’ retirement money by requiring clear records and confirmations. Comments are open until April 14, 2025, so affected banks, brokers, and plan managers should weigh in soon!
Analyzed Economic Effects
4 provisions identified: 2 benefits, 2 costs, 0 mixed.
Six-Year Access to FX Transaction Records
Banks, broker-dealers, and affiliates must keep records of foreign currency transactions for six years from the date of the transaction and make them available upon request to specified interested persons, including plan fiduciaries, participants and beneficiaries, the IRS, and the Department of Labor. You (as a participant or beneficiary) can request those transaction records from the plan counterparty within that six-year window.
Banks/Brokers Must Have FX Policies
Banks, broker-dealers, and their affiliates that rely on Prohibited Transaction Exemption 94-20 must maintain written policies and procedures for trading foreign currencies with employee benefit plans. This is a formal recordkeeping and compliance requirement that applies to affected financial firms.
Fiduciaries Receive Written Trade Confirmations
For each foreign currency transaction with an employee benefit plan, the bank or broker must provide a written confirmation statement to the independent plan fiduciary directing the transaction. This gives the plan fiduciary a transaction-level record directly from the trading counterparty.
Estimated Compliance Burden for Respondents
The Department estimates this information collection applies to 225 respondents with 1,125 total responses, a total estimated annual time burden of 188 hours, and total estimated annual other costs of $0. These are the agency's published numeric estimates of the paperwork burden tied to the exemption's information requirements.
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