Subject: File No. 4-582
From: Michael Henkel
Affiliation: Envestnet Asset Management

May 22, 2009

Investors definitely have a problem understanding target date funds. That is why Envestnet conducted the survey that is attached to determine just what types of perceptions investors have about these funds. The problem, however, is not with the funds themselves. Overall, they do a very good job of providing professionally managed, diversified portfolios that get more conservative as retirement nears.

The problem is that no one regularly tells the investor his or her outcome in personalized terms if they chose a specific fund. By outcome, I mean what is the income they are likely to replace at a given level of probability when they retire. The second attachment shows one form of an illustration that shows this outcome.

The greatest benefit of this type of personalized communication is that an appropriate savings rate can be calculated and regularly presented to the investor. Note in the survey on page 19, investors select setting the appropriate savings rate as the lowest priority in the decisions they need to make for retirement planning.

Whether or not target date funds should be more conservative or less conservative is an investing problem that the best minds in finance can debate for years and never reach a conclusion. However, if all target date funds are forced to be more conservative then the savings rate decision only gets more important.

(Attached File #1: 4582-1a.pdf) (Attached File #2: 4582-1b.pdf)