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The Yale Law Professor Letters: Data and Approach Deserve a Failing Grade (PDF)
Fiduciary Benchmarks 
[Opinion] Aug. 15, 2013
"The benchmark groups are poorly constructed, the fee analysis is incorrect and they miss the importance of cost-drivers and value-factors in their analysis.... [T]his makes the letters inappropriate for decision making from a fiduciary standpoint.... [B]eing a fiduciary is the highest duty known under the law. In that regard, any fiduciary initiative to review plan fees requires the use of data and methods that ensure results are accurate and complete."
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