1210-AC38 comment 3656 National Association of Personal Financial Advisors 06012026

Summary: The National Association of Personal Financial Advisors (NAPFA) opposes the Proposed Rule in its current form, arguing that it weakens protections for retirement plan participants by allowing high-fee or risky alternative assets with inadequate safeguards. They advocate for more robust protections, including mandatory participant education, consent, and "opt-in" requirements for alternative investments.