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ERIC, PSCA and U.S. Chamber of Commerce Comment Letter to DOL on FAB 2013-02, Participant Fee Disclosures (PDF)
The ERISA Industry Committee [ERIC], Plan Sponsor Council of America [PSCA] and U.S. Chamber of Commerce 
[Opinion] Sept. 18, 2013
"While the body of the FAB references the 'comparative chart,' we believe the FAB provides a one-time extension, for either 2013 or 2014, for plan administrators with respect to the delivery of all plan-related information described in paragraph (c) of the regulation and investment-related information described in paragraphs (d)(1) and (d)(2) (in effect, all annual notice requirements). We request that the Department confirm that the FAB's relief applies to all of the regulation's annual disclosures and not just the comparative chart. The FAB also indicates that the Department is considering revising the regulation's timing requirement to provide 'reasonable flexibility' to plan administrators on a permanent basis. We strongly encourage the Department to adopt these measures."
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