"We are concerned that including specific assumptions in the safe harbors described in the Notice will steer plan sponsors to utilize those assumptions to ensure compliance at the expense of flexibility and innovation. In lieu of the safe harbor approach, we urge DOL to adopt a rule under which plan sponsors would be required to provide lifetime income illustrations based on generally accepted investment theories and generally accepted actuarial principles. We urge DOL to include in the rule a clear statement that providing the illustrations required under the rule would be treated as education, and not as a fiduciary act giving rise to either fiduciary or plan liability."  MORE >>