"As states move toward performing retirement functions currently performed exclusively by the private sector, it would be helpful for all stakeholders to understand whether states will be provided with special exemptions from rules universally applicable to the private sector. And states need to know their potential liabilities.... [P]articipants in these arrangements, who would no longer have the protections of ERISA under proposed regulations issued by the [DOL], need to know if the Code's protections will be fully applicable. And service providers participating in the state programs need to understand what potential liabilities could arise."  MORE >>