Subject: File No. S7-12-10
From: William J. Tugaw
Affiliation: CEO, SST Benefits Consulting

April 9, 2012

As a consulting firm that assists 457(b) defined contribution plan sponsors with understanding TDFs that are included in their portfolio, it strikes us unusual that there has been little discussion on the risk of the TDF portfolio. All discussion had to do with asset allocation and glidepath. It seems to us that the SEC should require benchmarks to guide TDF product designers. Two different bond portfolios could have extremely different risk characteristics, so a simple discussion of asset allocation doesn't go far enough to tell an investor the risk assumed.

Products should have a target date in their name, a glidepath for asset allocation and a risk (aggressive, moderate, conservative) for risk based upon SEC approved benchmarks.