Advisory Opinion on Target Date/Lifecycle Mutual Funds

This document is an advisory opinion from the U.S. Department of Labor on whether the assets of target date or lifecycle mutual funds constitute plan assets under ERISA and whether the investment advisers to such funds would be considered fiduciaries to the investing plans. The opinion concludes that the fact that a target date or lifecycle fund's assets consist of shares of affiliated mutual funds does not, on that basis alone, make the fund's assets plan assets or the investment advisers fiduciaries under ERISA.