"[IRIC] specifically supports the uniformity of the disclosure ... [P]articipants will receive a consistent message on lifetime income regardless of their employer or their recordkeeper.... IRIC requests additional clarity on the latitude the Department is providing with respect to adherence to the specific language outlined in the IFR.... [IRIC suggests] that the Department make it clear that projecting balances to age 67 using reasonable assumptions is education as defined by I.B. 96-1 and would not be considered fiduciary advice under Section 3(21) of ERISA."  MORE >>