Testimony of Phyllis Klein, CAPTRUST Financial Advisors

This document is about the testimony of Phyllis Klein of CAPTRUST Financial Advisors before the ERISA Advisory Council. Klein discusses CAPTRUST's experience with brokerage windows, including data on the prevalence of brokerage windows among the plans they advise and the low level of participant utilization. Klein argues that plan sponsors offer brokerage windows to provide more experienced and sophisticated investors with expanded investment options, and that additional regulatory burdens related to brokerage windows would be unreasonable given the limited participant usage.