"We believe this review of the 408(b)(2) regulation is premature and based on unidentified anecdotal evidence of small businesses that is contrary to the actual experience of our members. In particular, it is our view that: [1] It is premature and imprudent to propose to amend the section 408(b)(2) regulation to add more disclosure rules before determining whether any changes are needed (and whether the costs of those changes justify whatever benefits the Department identifies). [2] The proposed focus groups are not properly constructed because [a] they ignore large-plan fiduciaries, and [b] they rely upon recollection of disclosures th at plan fiduciaries received almost two years ago. [3] The focus group 'script' contains a number of biases that could prevent the results from being reliable and valid."

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