"We believe that unless certain steps are taken the statements can do more harm than good. Our concern is that an over simplified methodology can unintentionally mislead the plan participant. In particular, we are concerned that the proposed 'safe harbor' methodology will lead to widespread adoption by most vendors since it will be perceived as the only 'safe choice,' even though it mi ght give materially inaccurate projections and stifle innovation. We believe six modifications will greatly improve the proposed rule by adding flexibility and help more plan participants to reach retirement success."

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