Comment Ltr re Participant-Level Fee Disclosure 072307

July 20, 2007 Filed Electronically Office of Regulations and Interpretations Employee Benefits Security Administration Room N–5669 U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, DC 20210 Attn: Fee Disclosure RFI Dear Sir or Madam: The American Benefits Council (“Council”) appreciates the opportunity to comment in response to the Request for Information (“RFI”) issued by the Department of Labor (the “Department”) regarding fee and expense disclosures to participants in individual account plans, published at 72 Fed. Reg. 20,457 (April 25, 2007). The Council is a public policy organization representing principally Fortune 500 companies and other organizations that assist employers of all sizes in providing benefits to employees. Collectively, the Council’s members either sponsor directly or provide services to retirement and health plans that cover more than 100 million Americans. The Council strongly supports the disclosure of pertinent information about the fees and expenses that participants bear in 401(k) and other individual account plans covered by the Employee Retirement Income Security Act of 1974 (“ERISA”). As the RFI points out, approximately 41 million working Americans are covered by individual account plans that allow participants to make their own investment elections from among a menu of investment options offered by the plan. The overwhelming majority of these plans also allow participants to ...