1210-AC38 comment 3537 American Association for Justice 06012026

Summary: The American Association for Justice (AAJ) opposes the proposed rule because it creates a safe harbor that they argue diminishes the statutory duty of prudence for fiduciaries. They contend that the rule improperly reduces the standard of care required by ERISA, shields plan managers from accountability, and undermines the ability of beneficiaries to enforce their rights through litigation.