"PSCA does not support a mandate.... It will be helpful for the Department to explain how it determined that its authority under Section 505 permits this broad interpretation of Section 105.... The safe harbor in the intended regulation will result in a major reduction in the availability of other retirement income calculators, to the detriment of participants.... The ANPRM should be product neutral... Projections are critical to any lifetime income... [T]he Department should issue guidance relating to the provision of retirement income calculators similar to the guidance issued under Interpretive Bulletin 96-1 that relates to participant investment education."  MORE >>