Employee Rights and Employment Policy Journal

This article reviews a recent draft directive in the European Community on ccupational retirement pensions and compares it with the two major regulatory effects in the United States, the federal Employee Retirement Income Security Act and the state Uniform Management of Public Employee Retirement Systems Act. The author uses the comparision both to analyze the promise and limitations of the new European Directive and to shed light on the underlying policies of the Directive and the American regulatory initiatives.