Subject: File No. 4-582
From: Arun S Muralidhar
Affiliation: Chairman, AlphaEngine Global Investment Solutions

May 26, 2009

I have been working with a few corporate clients on improving their Target Date Fund offerings as we help them with SMART Rebalancing of their asset allocation. Having examined the current product line up find that the risks borne by participants are not clearly explained or managed. I am writing a book (my fourth and to be published by Cambridge Univ Press) and the last chapter is on improving Target Date Fund offerings. I enlose a preliminary draft of the chapter as I plan to improve it further in the next few days (having done work on benchmarking and ranking these funds on a risk-adjusted basis - I have developed measures of risk and skill adjusted performance that have won awards in the industry).

COMMENTS ATTACHED

(Attached File #1: 4582-4.pdf)