1210-AC38 comment 3679 Public Investors Advocate Bar Association 06012026

Summary: The Public Investors Advocate Bar Association (PIABA) opposes the proposed rule because it creates a "process-based safe harbor" that they argue weakens fiduciary accountability and investor protections. They contend that the proposal facilitates exposure to complex, illiquid, and opaque alternative investments—such as private equity and cryptocurrency—which are ill-suited for retirement accounts and increase the risk of financial harm to workers.