"DOL is using the issuance of the Proposed Rule as an opportunity to collect information from the public in order to make findings necessary to adequately demonstrate that the guide (i.e., the proposed data collection) contemplated by the Proposed Rule is (i) necessary for the proper performance of the functions of the agency, and (ii) will have practical utility. Accordingly, DOL has not completed the threshold steps of determining whether the guide is in fact needed or will be useful to plan sponsors, nor has it developed a realistic estimate of the total time required for [affected] service providers to prepare the guide."

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