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Retirement Advisor Council Comment Letter to DOL Regarding Proposal to Conduct Focus Groups to Evaluate Effectiveness of Fee Disclosure Regs (PDF)
Retirement Advisor Council 
[Opinion] May 12, 2014
"[T]he universe you intend to study consists of small pension plans with fewer than 100 participants. Although this size segment is large in numbers of plans, participants of plans in this segment are a fraction of the universe affected by regulation 408(b)(2).... [F]ocus groups are qualitative in nature, meant to discern a range of attitudes or behaviors, not their frequency. Quality of the research is less a factor of the number of focus group attendees than of the variety of recruits.... [We] recommend that you solicit input and feedback not only from plan sponsors but also from Professional Retirement Plan Advisors whom plan sponsors have hired in a fiduciary capacity.... We believe you will collect more complete information asking about the role of the Advisor in the relationship throughout the discussion."
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