Comments on Acceptance of Public Submissions Regarding the Study of Stable Value Contracts (Request for Comment)

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Date Received
Date Letter Type Commenter Name
Public Comment Robert E. Rutkowski
Public Comment Barbara Novick, Vice Chairman, BlackRock, Inc.
Public Comment Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Public Comment Committee on the Investment of Employee Benefit Assets
Public Comment Dennis M. Kelleher, President & CEO; Stephen W. Hall, Securities Specialist; David Frenk, Director of Research; Better Markets, Inc.
Public Comment Gina Mitchell, President, Stable Value Investment Association
Public Comment I. Michael Greenberger, Law School Professor, University of Maryland, Francis King Carey School of Law, and Brandy Bruyere, Law & Policy Analyst, University of Maryland, Center for Health and Homeland Security, on behalf of Americans for Financial Reform
Public Comment John Caswell, Managing Partner, Galliard Capital Management
Public Comment Leslie A. Schmidt, President, Invesco National Trust Company, and Rich King, Head of Stable Value, Invesco Advisors, Inc.
Public Comment Marijn P. Smit, President, Transamerica Stable Value Solutions Inc.
Public Comment Tim Stumpff, President, Morley Financial Services, Inc.
Public Comment Stephen E. Roth and Frederick R. Bellamy, Sutherland Asbill & Brennan LLP, on behalf of the Committee of Annuity Insurers
Public Comment Christopher Tobe, CFA, Stable Value Consultants, Louisville, Kentucky
Meeting with SEC Officials Memorandum from the Office of Commissioner Aguilar regarding a January 25, 2012, meeting with representatives of the Stable Value Investment Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Paredes regarding a November 16, 2011 meeting with representatives of the Stable Value Investment Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Walter regarding a November 15, 2011 meeting with representatives of the Stable Value Investment Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an October 28, 2011 telephonic meeting with representatives of the Stable Value Investment Association
Public Comment Scott Goebel, Senior Vice President and General Counsel, Fidelity Management & Research Company
Public Comment John Walsh, Acting Comptroller of the Currency
Public Comment Ralph J. Egizi, Chairman, Committee on the Investment of Employee Benefit Assets,
Public Comment Dana C. Wiele, Senior Vice President and Associate General Counsel, RGA Reinsurance Company
Public Comment David A. Stella, Secretary, Wisconsin Department of Employee Trust Funds
Public Comment Eric W. Baumhoff, CFA, Chief Investment Officer, Stable Value, and Douglas A. Barry, CFA, Executive Vice President, BNY Mellon Cash Investment Strategies
Public Comment Nicholas D. Latrenta, Executive Vice President and General Counsel, MetLife, New York, New York
Public Comment Alison H. Micucci, Senior Managing Director, Guaranteed Products, New York Life Investment Management Company
Public Comment Americans for Financial Reform
Public Comment Barbara Novick, Vice Chairman, BlackRock, Inc.
Public Comment Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Public Comment David Graham,Stable Value Director, Pacific Life Insurance Company
Public Comment Dennis Kelleher, President and CEO; Stephen W. Hall, Securities Specialist; and Wallace C. Turbeville, Derivatives Specialist; Better Markets, Inc., Washington, District of Columbia

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-32-11
Release Number
34-65183
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