"Safety at the target date is the most important benefit ... There is no fiduciary upside to taking risk at the target date. Only downside.... There is a 'risk zone' spanning the 5 years preceding and following retirement during which lifestyles are at stake.... Most participants withdraw their accounts at the target date, so 'target death' (i.e., Through) funds are absurd, and built for profit. All TDFs are de facto 'To' funds.... Employers should educate employees about the importance of saving, and report on saving adequacy."

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