This document is about the testimony provided by Norman Stein, a professor at the Drexel University Earle Mack School of Law, on the settlor/fiduciary doctrine and its implications for regulating pension de-risking transactions. Stein argues that while plan design decisions are settlor functions not subject to ERISA fiduciary duties, the implementation of those decisions involves fiduciary responsibilities that the Department of Labor should address through guidance and regulations.