Subject: File No. 265-28
From: Tibor Vas, CPA
Affiliation: Shareholder of small CPA firm

January 8, 2016

I would like to propose a modest change as to the allowable investments for 403(b)for consideration. These plans are limited basically to mutual funds and annuities. Individuals close to retirement are very vulnerable because of this limited option. I would like to suggest individuals in these types of plan are allowed to investment in Certificate of deposits, Treasuries, municipal bonds (highest quality only) and corporate bonds (again the highest quality). By expanding the options, individuals can be taught about laddering and holding to maturity. It avoids or at least mitigates the danger of interest movements, redemptions and liquidity influences. Targeted funds and even passive mutual funds in our current environment for soon to be retired individuals actually, I believe, violates fiduciary responsibility.

Also, I would strongly suggest since retirement plans are already deferral accounts, annuities not be permissible options. These are complex options with much higher fees that invest in a very similar manner as mutual funds etc. If individuals want to supplement there retirement outside the 403(b) that would be a personal option.

I would love to discuss this issue and if this organization is not the one I should be communicating with please let me know who to contact. Or simply forward this email to that party.

Thank you,
T. Vas