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American Benefits Council Comment Letter to DOL on Proposed Fee Disclosure Guide (PDF)
American Benefits Council Link to more items from this source
[Opinion]
June 10, 2014
10 pages. "The Department has issued the proposal before gathering information to identify potential problems with the 408(b)(2) regulation and before assessing the significance of any problems relative to the cost of a proposed solution ... The guide proposal contains difficult rules with a substantial cost ... The very large new costs created by the current proposal will be passed on to large plans and participants, while producing, at best, only marginal benefits for large plans[.]"

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