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Comment Letter by Eleven Industry Organizations to DOL on Proposed Focus Groups for Evaluating the Effectiveness of ERISA 408(b)(2) Disclosure Requirements (PDF)
U.S. Chamber of Commerce, Ten Other Organizations Link to more items from this source
[Opinion]
Jan. 6, 2015

"We support the [DOL] doing real-world testing of its rules, and have encouraged the Department to collect information from plan sponsors, participants, and service providers before determining if new regulations are needed. The Department should put its 408(b)(2) 'guide' proposal on hold until it determines whether any changes to the disclosure regulation are needed.... The focus group research should be conducted and results made public before the Department issues a proposed rule ... [We] are still concerned that the sample is not representative. While most plans are small, most participants are in large plans ... [S]ignificant input from large plan sponsors is also necessary ... We continue to have concerns that the focus group script may introduce unwanted bias."

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