"DOL's proposal would (more or less) re-define any asset allocation recommendation that identifies specific funds, and any communication about distributions that recommends a specific form of distribution, as 'advice.' ... [T]he proposal problematizes communications to participants about distributions. And the proposed participant education 'carve out' would, in effect, set the limits to what an 'educator' can say about distributions without triggering advice status. Clearly, you couldn't say anything favoring (recommending) one distribution option over another."