1210-AC38 comment 1610 IronFjord Wealth Management 0527206

Submitted by IronFjord Wealth Management Registered Investment Adviser (RIA) IronFjord Wealth Management submits this comment in strong opposition to the proposed rule permitting private equity investments in 401(k) plans. We urge the Department of Labor to reject this proposal and fulfill its core mandate: protecting the retirement security of American workers. Who We Are and Why This Matters IronFjord Wealth Management is a flat-fee registered investment adviser. I am James Mayo, CFA, CFP, EA, MBA, and I am the principal of this firm. We serve clients on a fiduciary basis, meaning we are legally and ethically obligated to act in our clients’ best interests at all times. Almost every client I have served has had a 401(k) or a rollover IRA that originated from one. Retirement accounts are not abstract policy instruments to me. They are the life savings of real people who worked for decades to accumulate them. I am writing this comment because I believe this proposal would cause direct and measurable harm to those savers. I want to be direct about what I believe this proposal is: an effort by private equity firms to access the largest pool of retail capital in the country. 401(k) plans hold trillions of dollars. Private equity wants access to that capital. The Department of Labor should not be the one to open that door. Liquidity Risk Is Incompatible with Retirement Plan Design Private equity investments are, by design, illiquid. Lock-up periods of five to ten years are common. A participant who faces a job loss, medical emergency, or early retirement may have limited ability to access these assets when needed. This structural mismatch cannot be resolved with disclosure language. When a worker needs their money, they need their money. Fees Are a Direct Transfer of Wealth Away from Retirement Savers Private equity funds typically carry management fees of 1.5% to 2% annually, plus carried interest of 20% on gains. As a CFA charterholder, I can state plainly: compounding fee drag over a 20- or 30-year accumulation period is devastating to retirement outcomes. When low-cost index funds with expense ratios under 0.10% are widely available, exposing participants to this fee structure is indefensible under any reading of the fiduciary standard. Complexity Benefits the Seller, Not the Saver Private equity valuations rely on internal estimates, not market prices. The typical 401(k) participant is a teacher, a nurse, a contractor, a small business owner. They are not equipped to evaluate these risks, and in most cases neither are plan sponsors. When people cannot understand what they own, they cannot protect themselves. Addressing the Counterargument Proponents argue that private equity offers return potential unavailable through public markets. That argument belongs in a conversation about endowments and pension funds with dedicated investment staff and the ability to negotiate terms. It does not belong in a conversation about the retirement accounts of working Americans. The return premium associated with private equity, to the extent it exists net of fees and illiquidity costs, has not been demonstrated to translate reliably into the retail defined-contribution context. A Direct Request to the Department of Labor The Department of Labor was created to protect workers. ERISA was enacted to protect retirement savers. I am asking the Department to honor both mandates by rejecting this proposal. The people whose retirement security is at stake did not ask for this. This proposal serves private equity firms seeking a new and enormous source of capital. It does not serve retirement savers. The Department should say so and reject it. Respectfully submitted, James Mayo, CFA, CFP, EA, MBA Principal, IronFjord Wealth Management