1210-AC38 comment 3679 Stable Value Investment Association 06012026

Summary: The Stable Value Investment Association (SVIA) supports the proposed rule but argues that the current examples in the safe harbor are too focused on traditional mutual funds and do not adequately account for the unique liquidity, valuation, and benchmarking characteristics of stable value products. They request that the Department include specific guidance and examples for stable value investments to ensure fiduciaries can use these products with certainty and reduced litigation risk.