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The Investment Company Institute ("ICI") voiced concerns regarding the Department of Labor's rule proposal defining the term "fiduciary" under ERISA. The ICI called the proposed rule "unworkable." In two more of what has been a series of comment letters, ICI raised numerous areas of concern including: the proposal would restrict the ability of investors to get the basic information they need to make informed investment choices – for example, by leaving key terms ambiguous and by revising current law to restrict the type of investment education that can be provided without triggering fiduciary