Subject: File No. S7-12-10
From: Stephen M Batza
Affiliation: President CEO, MTL Insurance Company

April 10, 2014

I applaud the SEC's effort to make Target Date Funds (TDFs) more transparent to investors. The initial question, as I understand it, is whether the expected "glide path" of the TDF provides sufficient information, or if a standardized, risk-based "glide path" illustration is necessary to protect investors.

My initial reaction is that a risk-based illustration may create more confusion than enlightenment. With that said, it would be beneficial to see an example of what such an illustration would look like. The level of its complexity may determine whether such a disclosure is worthwhile.