1210-AC38 comment 3584 CFP Board 06012026

Summary: The CFP Board opposes the proposed rule because it risks reducing fiduciary judgment to a "check-the-box" procedural exercise and could facilitate the inclusion of complex, high-cost alternative investments in retirement plans. They argue the rule should be revised to preserve the "act accordingly" requirement, remove rules-based examples from the operative text, and clarify that a facially prudent process does not shield fiduciaries from liability for imprudent outcomes.