Subject: File No. 4-582
From: Chris Tobe, CFA
Affiliation: Senior Consultant BCAP and Trustee Kentucky Retirement Systems

May 22, 2009

I think I bring a unique perspective to the Target Date debate. Attached is my Feb. 2009 piece on 2010 Funds.
Also below is my 2006 letter to DOL during the original QDIA debate.

I believe the creation and makeup of Target Date funds are driven by the level of fees they produce for managers.