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SPARK Institute Comment Letter to DOL About Interim Regs on Disclosure to Fiduciaries of Fees by Service-Providers (PDF)
SPARK Institute 
[Opinion] Aug. 30, 2010
13 pages. Excerpt: [The interim regulation] appears to shift Investment Fund Information disclosure responsibility from investment fiduciary service providers with respect to investments they issue and manage to an unaffiliated, non-fiduciary record keeper. [Further,] we are concerned that record keepers will be obligated to provide record keeping services and, in turn, provide Investment Fund Information for investment options demanded by plan sponsors that do not have materials that are regulated by a State or federal agency.
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