"[T]he Proposal will negatively impact a variety of powerful tools and guidance that SPARK members make available to Americans saving in 401(k), 403(b) and 457(b) retirement plans ... [B]ecause of the expansive scope of the tools, programs, guidance, and even spreadsheets that the Proposal covers, SPARK members that provide recordkeeping and other services to defined contribution plans but also happen to be regulated (or have an affiliate that is regulated) as an investment adviser or broker-dealer, will be required to undertake a massive compliance effort simply to identify the tools and guidance that could be impacted."  MORE >>