"In the Model Comparative Chart for its new 401k disclosure rule, the DOL broke its sample Model Comparative Chart into two parts. This article will focus on the first part-- Performance Reporting-- specifically, [its] suggested layout for Table 1. As we demonstrate the use of Table 1 via the top ten most widely held mutual funds in 401k plans as identified by BrightScope, some apparent issues immediately pop out. The 401k fiduciary just might find these new disclosure rules could increase fiduciary liability as we'll explain."