On August 6, 2020, the American Retirement Association wrote to the Department of Labor to comment on the proposed class exemption for investment advice for workers and retirees. In the letter, the American Retirement Association supports the application for an ERISA fiduciary standard for rollover advice, requests clarification of the application of the exemption for Pooled Employer Plans, and asks for a reexamination of the “regular basis” element of the five-part fiduciary test.