Subject: File No. 4-582
From: Rod W. Bare
Affiliation: Director, Asset Allocation Strategies, Morningstar, Inc.

June 5, 2009

Ladies and Gentlemen,

Morningstar respectfully requests the opportunity to testify and answer questions at the hearing scheduled for June 18th. With 30 years of asset allocation research via our Ibbotson subsidiary and 25 years of securities and investor-experience research at Morningstar, we are well-positioned to help explore today's target-date issues.

Our proposed outline for testimony:
1. The case for risk profile choice in the glide path (10 min)
2. The case for adequate asset class diversity (5 min)
3. The case for low-cost, transparent security selection (5 min)

Attached is a short paper that introduces these concepts. We would be pleased to discuss the specific utility of these ideas in detail at the hearing and in follow-on discussions.


Rod Bare
Director, Asset Allocation Strategies
Morningstar, Inc.

(Attached File #1: 4582-14.pdf)