Subject: File No. 4-582
From: David S. Kosterlitz

May 26, 2009

Dear SEC:

Side by Side Comparison of Target Date Funds’ Glide Paths should be publicly available

It would be helpful if there were a way that the public could have a “side-by-side” comparison chart that would compare the “glide paths” (the policy, formula or benchmarks which govern the fund’s reallocation of assets by asset category each year as the target date approaches). This should also include the “Lifestyle Funds” (target date funds) in the Federal Thrift Savings Plan (TSP) and the target funds of the major mutual fund companies like Vanguard, Fidelity, T. Rowe Price, and the like. Right now one must simply pick a fund company and a target date, and hope for the best. I do not believe that the investor receives any information about the “glide path.” Greater disclosure and transparency on the glide paths would be most welcome and is needed for investors to meaningfully compare different fund companies’ offerings of Target Date Funds.

Greater education about how to use Target Date Funds effectively for one’s situation should be disseminated by a regulatory agency

It may also be relevant to note that some programs offer target date funds which do not exactly fit into a person’s retirement income needs. For example, the TSP offers a Target 2010 fund and a Target 2020 fund, when I might actually need a 2015 fund. I think investors would benefit from greater education about these funds and how to use them most effectively in their own retirement planning.

Thanks for the opportunity to make my comments.


David S. Kosterlitz