Dalbar has told the Employee Benefits Security Administration that EBSA has based proposed sales standards for 401(k) plan rollovers on a faulty premise: that rollover decisions are investment decisions.
"Rollover decisions are primarily driven by spending choices, personal obligations, estate considerations and longevity risk," Dalbar says, in an outline of Dalbar executives' views that was sent to EBSA. "Only after the rollover decision is made can attention be turned to the investment decisions."
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