This document is about the testimony of Michelle (Mickie) G. Murphy of Blue Benefits Consulting, Inc. before the ERISA Advisory Council. Murphy discusses her firm's experience with brokerage windows in smaller retirement plans, including plans that offer only brokerage accounts as the investment option. While generally supportive of brokerage windows, Murphy suggests that for plans without a designated default investment option, there should be a minimum standard of care requiring the plan sponsor to select and monitor a default brokerage firm and advisor to protect less sophisticated participants.