New Investment Options (DIAs) and 408b2 Fee Disclosure Timing

[Guest jvajj]

General question about timing of change notice for 408b2 as it relates to new fund additions at a product level. If a company is going to add new DIAs to the potential fund lineup for a product, when do you think the 60 day clock (became aware of the change) would start for purposes of providing a change notice for 408b2? For example, if the new DIAs are going to be "available" for a plan sponsor on July 31, do you think the change notice would need to be effective by 6/1? The timing of these 408b2 notices and the information needed to satisfy 404a5 component of 408b2 makes timing of notices difficult and certainly subject to some interpretation.