"[W]e believe the proposals outlined in the ANPRM could limit the use of current income replacement calculators and stifle industry innovation. We particularly urge the Department to exercise caution in identifying a safe harbor for calculating lifetime income projections. We believe the most effective approach would be to encourage plan sponsors to provide these projections rather than mandate their inclusion on participant statements. This could be accomplished by clarifying that lifetime income projections, based on prudent methodologies and appropriate disclosure of assumptions, are educational tools and do not result in additional fiduciary liability for the plan sponsor."

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