Subject: File No. 4-582
From: James P Lauder
Affiliation: CEO, Global Index Advisors, Inc.

June 4, 2009

Global Index Advisors, Inc (GIA) respectfully requests the opportunity to present testimony at the June 18 Target Date Fund Joint Hearing.

As a firm, GIA is focused exclusively on the design and delivery of Target Date benchmarking tools for fiduciaries as well as the development of prudent Target Date products for investors. We designed the first benchmarks for Target Date Funds, the Dow Jones Target Date Indexes, in 2004 and currently manage over $4 billion in target date assets to that strategy. Our efforts over the past years have been to, first, help plan fiduciaries make better decisions by understanding the potential risk various target date offerings place on participants. And second, to deliver a transparent and fiducially sound target date offering to plan sponsors looking to balance the accumulation of participant assets with the need to protect and preserve those assets as participants near retirement.

This experience provides us a unique perspective on the Target Date space.

GIA is prepared to offer testimony on the following topics:

1. Glide path design (5 minutes):Mitigating Longevity Risk Volatility Risk, The impact of significant volatility in the years immediately prior to and after retirement, The role of product provider motivation versus participant best interest

2. Evaluation, Monitoring, and Communication (5 minutes): Understanding and communicating potential risk in advance, Matching fund provider philosophy with participant risk tolerances, Setting and managing plan sponsor/participant expectations, Ongoing performance evaluation

Attached you will find a April 29th letter to Chairman Schapiro providing further information on GIA, the Target Date Fund market, and specific suggestions for better education and communication of potential Target Date Fund risk to fiduciaries. Please do not hesitate to contact us with any questions about the information submitted. Thank you again for your time and consideration.

(Attached File #1: 4582-11.pdf)