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ERIC Comment Letter to DOL on Proposed Fee Disclosure Guides (PDF)
The ERISA Industry Committee [ERIC] Link to more items from this source
[Opinion]
June 10, 2014
"[T]he guide requirement contained in the Proposed Amendment should not apply with respect to very large plans as it would generate additional costs to plans, participants, and service providers without a corresponding benefit to participants.... [G]enerating a guide would require service providers to create new systems, even if they only service very large plans that would not benefit from the guide.... DOL should only exclude very large plans with 5,000 or more participants or at least $100 million in assets from the guide requirement."

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