SEC and DOL to Revisit Guidance on Alternative Assets in 401(k) Plans
October 2025
On August 7, 2025, the Trump Administration released the heavily anticipated Executive Order, “Democratizing Access to Alternative Assets for 401(k) Investors”, which represents a significant development and a positive step toward facilitating investment by defined contribution plans in private funds. Defined contribution plans, including 401(k) plans, represent a large source of investment capital, estimated to be more than $12 trillion and steadily rising.
The Executive Order directs the U.S. Department of Labor (the DOL) to reexamine its past guidance regarding the investment of 401(k) plans in alternative assets and, to the extent deemed appropriate by the DOL, issue clarifying guidance. In addition, the Executive Order directs the U.S. Securities and Exchange Commission (the SEC) to, in consultation with the DOL, consider ways in which to facilitate the investment by 401(k) plan participants in alternative assets, which may include, without limitation, “consideration of revisions to existing SEC regulations and guidance relating to accredited investor and qualified purchaser status1.” Below is a set of questions and answers discussing high-level implications of the Executive Order.
Why This Topic For an Executive Order?
To properly contextualize the Executive Order, it is helpful to revisit a plan fiduciary’s duties under the Employee Retirement Income Security Act of 1974, as amended (ERISA) when selecting and monitoring 401(k) plan investment options. Under ERISA, plan fiduciaries are obligated to prudently select and monitor investment options that are made available to 401(k) plan participants, and plan fiduciaries can be held liable for losses resulting from their failure to do so. When evaluating a specific investment alternative for inclusion as an investment option, plan fiduciaries “must engage in an objective, thorough, and analytical process that considers all relevant facts and circumstances and then act accordingly2.”
Why This Topic For an Executive Order?
To properly contextualize the Executive Order, it is helpful to revisit a plan fiduciary’s duties under the Employee Retirement Income Security Act of 1974, as amended (ERISA) when selecting and monitoring 401(k) plan investment options. Under ERISA, plan fiduciaries are obligated to prudently select and monitor investment options that are made available to 401(k) plan participants, and plan fiduciaries can be held liable for losses resulting from their failure to do so. When evaluating a specific investment alternative for inclusion as an investment option, plan fiduciaries “must engage in an objective, thorough, and analytical process that considers all relevant facts and circumstances and then act accordingly2.”
Average Asset Allocation of 401(k) Plan Accounts
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Source: Investment Company Institute
Throughout the years, private funds have steadily been laying the groundwork to enable 401(k) plans to gain greater access to alternative assets. The Executive Order articulates a position that has been steadily gaining momentum—without greater access to investments in alternative asset classes, the more than 90 million 401(k) plan participants are missing out on the “potential growth and diversification opportunities associated with alternative asset investments” currently afforded to institutional investors, high-net-worth individuals, and retirement plans for government workers3.
Throughout the years, private funds have steadily been laying the groundwork to enable 401(k) plans to gain greater access to alternative assets. The Executive Order articulates a position that has been steadily gaining momentum—without greater access to investments in alternative asset classes, the more than 90 million 401(k) plan participants are missing out on the “potential growth and diversification opportunities associated with alternative asset investments” currently afforded to institutional investors, high-net-worth individuals, and retirement plans for government workers3.
Average Asset Allocation of 401(k) Plan Accounts
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Source: Investment Company Institute
Despite these growing sentiments, many 401(k) plan fiduciaries and managers of investment options (e.g., target-date funds) have been slow to incorporate exposure to alternative assets. Many plan fiduciaries and 401(k) investment managers have also been reluctant to offer investment options with alternative asset exposure due to unclear DOL guidance and concerns about ERISA liability—particularly the risk of participant lawsuits alleging imprudent investment selection based on higher risks, lower liquidity, or excessive fees.
The Executive Order specifically identifies the foregoing as impediments that the DOL should seek to address, stating that the “administration will relieve the regulatory burdens and litigation risk that impede American workers’ retirement accounts from achieving the competitive returns and asset diversification necessary to secure a dignified, comfortable retirement4.”
What Does the Executive Order Do?
The Executive Order directs the DOL to: reexamine its guidance relating to a fiduciary’s duties under ERISA in connection with making an asset allocation fund that includes alternative assets available to 401(k) plan participants, and issue clarifying guidance, as it deems appropriate and consistent with applicable law, regarding the DOL’s position on alternative assets and the process that 401(k) plan fiduciaries should follow when making asset allocation funds with exposure to alternative assets available to plan participants. The DOL “may include appropriately calibrated safe harbors” and “prioritize actions that may curb ERISA litigation that constrains fiduciaries’ ability to apply their best judgment in offering investment opportunities to relevant plan participants5.” Further, the Executive Order directs the DOL to consult with the Treasury Secretary, the SEC, and other federal regulators, “as necessary to carry out the policy objectives of this order6.”
How Does the Executive Order Define “Alternative Assets”?
The Executive Order defines “alternative assets” as:
- Direct or indirect investments in “private market investments” (including debt, equity or other financial instruments that are not traded on public exchanges and inclusive of investments with active managers); real estate (including equity and debt investments secured by underlying real estate); commodities; projects financing infrastructure development;
- Investments in actively managed investment vehicles that invest in digital assets (e.g., cryptocurrencies); and
- lifetime income investment strategies, including longevity risk-sharing pools.
Notably, this definition is simultaneously quite specific and also relatively broad —in addition to private equity and real estate, it includes private credit and investment funds that invest in digital assets (e.g., cryptocurrencies).
What Does the Executive Order Do?
The Executive Order directs the DOL to: reexamine its guidance relating to a fiduciary’s duties under ERISA in connection with making an asset allocation fund that includes alternative assets available to 401(k) plan participants, and issue clarifying guidance, as it deems appropriate and consistent with applicable law, regarding the DOL’s position on alternative assets and the process that 401(k) plan fiduciaries should follow when making asset allocation funds with exposure to alternative assets available to plan participants. The DOL “may include appropriately calibrated safe harbors” and “prioritize actions that may curb ERISA litigation that constrains fiduciaries’ ability to apply their best judgment in offering investment opportunities to relevant plan participants5.” Further, the Executive Order directs the DOL to consult with the Treasury Secretary, the SEC, and other federal regulators, “as necessary to carry out the policy objectives of this order6.”
How Does the Executive Order Define “Alternative Assets”?
The Executive order defines “alternative assets” as:
- Direct or indirect investments in “private market investments” (including debt, equity or other financial instruments that are not traded on public exchanges and inclusive of investments with active managers); real estate (including equity and debt investments secured by underlying real estate); commodities; projects financing infrastructure development;
- Investments in actively managed investment vehicles that invest in digital assets (e.g., cryptocurrencies); and
- lifetime income investment strategies, including longevity risk-sharing pools.
Notably, this definition is simultaneously quite specific and also relatively broad —in addition to private equity and real estate, it includes private credit and investment funds that invest in digital assets (e.g., cryptocurrencies).
What is the Current Landscape Regarding 401(k) Plans and Alternative Asset Classes?
In order to meaningfully anticipate what we can expect from the DOL, it is helpful to revisit the current regulatory landscape.
During the first Trump Administration, in June of 2020, the DOL tried to ameliorate concerns over including exposure to alternative assets in 401(k) plans by issuing an information letter (the Information Letter) discussing the inclusion of private equity within professionally managed and diversified 401(k) plan investment options7. By way of background, this type of guidance from the DOL is “informational only and is not binding on the [DOL] with respect to any particular factual situation8.” While not binding, the Information Letter was considered helpful because it confirmed that 401(k) plan fiduciaries could prudently select an investment option that includes exposure to private equity.
The Information Letter specified certain factors that a plan fiduciary should consider when evaluating such an investment option, including: whether the investment option will offer plan participants diversified risks over a multi-year period and provide an appropriate range of expected returns net of fees (including management fees, performance compensation and other fees that impact returns); whether the investment option will be operated by investment professionals and overseen by plan fiduciaries with the requisite capabilities, experience and stability taking into account the nature, size and complexity of the private equity component; whether the investment option’s allocation to private equity is sufficiently limited to reflect the unique characteristics of private equity (e.g., cost, complexity, disclosure and liquidity); and whether the investment option has adopted liquidity and valuation features sufficient to allow participants to take benefits under the plan and direct exchanges among available investment options in a manner consistent with the plan’s terms9.
The Information Letter led some plan fiduciaries to focus on incorporation of private equity and private credit strategies into target-date funds and managed account products to provide appropriate diversification and mitigate liquidity concerns. While the DOL’s guidance was specific to private equity, many of the considerations discussed in the Information Letter could help fiduciaries evaluate other alternative asset classes.
In December of 2021, the DOL under the Biden Administration issued a supplemental statement to the Information Letter (the Supplemental Statement)10. While the Supplemental Statement did not change the fundamental principles set forth in the Information Letter, it did strike a different tone. The Supplemental Statement cautioned plan fiduciaries that they may not have adequate resources to prudently evaluate investment options with exposure to private equity. As a result, plan fiduciaries may need assistance from qualified third-party advisors to prudently make such evaluations. The Supplemental Statement likely sapped some of the momentum created by the Information Letter.
The Executive Order specifically directed the DOL to consider whether to rescind the Supplemental Statement, and on August 12, 2025, the DOL rescinded this guidance11.
The Information Letter specified certain factors that a plan fiduciary should consider when evaluating such an investment option, including: whether the investment option will offer plan participants diversified risks over a multi-year period and provide an appropriate range of expected returns net of fees (including management fees, performance compensation and other fees that impact returns); whether the investment option will be operated by investment professionals and overseen by plan fiduciaries with the requisite capabilities, experience and stability taking into account the nature, size and complexity of the private equity component; whether the investment option’s allocation to private equity is sufficiently limited to reflect the unique characteristics of private equity (e.g., cost, complexity, disclosure and liquidity); and whether the investment option has adopted liquidity and valuation features sufficient to allow participants to take benefits under the plan and direct exchanges among available investment options in a manner consistent with the plan’s terms9.
The Information Letter led some plan fiduciaries to focus on incorporation of private equity and private credit strategies into target-date funds and managed account products to provide appropriate diversification and mitigate liquidity concerns. While the DOL’s guidance was specific to private equity, many of the considerations discussed in the Information Letter could help fiduciaries evaluate other alternative asset classes.
In December of 2021, the DOL under the Biden Administration issued a supplemental statement to the Information Letter (the Supplemental Statement)10. While the Supplemental Statement did not change the fundamental principles set forth in the Information Letter, it did strike a different tone. The Supplemental Statement cautioned plan fiduciaries that they may not have adequate resources to prudently evaluate investment options with exposure to private equity. As a result, plan fiduciaries may need assistance from qualified third-party advisors to prudently make such evaluations. The Supplemental Statement likely sapped some of the momentum created by the Information Letter.
The Executive Order specifically directed the DOL to consider whether to rescind the Supplemental Statement, and on August 12, 2025, the DOL rescinded this guidance11.
What Can We Expect With Regard to Cryptocurrencies and 401(k) Plans?
As the DOL considers next steps relating to this asset class, it will do with the DOL’s prior guidance in mind.
In March of 2022, the DOL issued Compliance Assistance Release No. 2022-01 (the 2022 Crypto Release), expressing serious concern about cryptocurrencies and cautioning “plan fiduciaries to exercise extreme care before they consider adding a cryptocurrency option to a 401(k) plan’s investment menu12.” In the 2022 Crypto Release, the DOL highlighted several difficulties faced by plan fiduciaries when evaluating cryptocurrencies, including: the speculative and volatile nature of cryptocurrencies; the difficulties associated with ensuring that participants make informed decisions in connection with investments in cryptocurrency; custodial and recordkeeping issues arising as a result of the unique nature of cryptocurrencies; concerns relating to the reliability and accuracy of cryptocurrency valuations; and uncertainties created by the evolving regulatory landscape applicable to cryptocurrencies.
Earlier this year, the DOL reversed course and issued Compliance Release 2025-01 (the 2025 Crypto Release), which rescinded the 2022 Compliance Release in its entirety13. The DOL stated that the 2025 Crypto Release restored “the Department's historical approach by neither endorsing nor disapproving of, plan fiduciaries who conclude that the inclusion of cryptocurrency in a plan's investment menu is appropriate. When evaluating any particular investment type, a plan fiduciary's decision should consider all relevant facts and circumstances and will “necessarily be context specific14.” Despite the DOL’s shifting guidance, plan fiduciaries have remained cautious about adding cryptocurrency exposure to 401(k) investment options because ERISA’s core fiduciary duties remain the same—ERISA fiduciaries are bound by a duty to prudently select and monitor investment options.
Earlier this year, the DOL reversed course and issued Compliance Release 2025-01 (the 2025 Crypto Release), which rescinded the 2022 Compliance Release in its entirety13. The DOL stated that the 2025 Crypto Release restored “the Department's historical approach by neither endorsing nor disapproving of, plan fiduciaries who conclude that the inclusion of cryptocurrency in a plan's investment menu is appropriate. When evaluating any particular investment type, a plan fiduciary's decision should consider all relevant facts and circumstances and will “necessarily be context specific14.” Despite the DOL’s shifting guidance, plan fiduciaries have remained cautious about adding cryptocurrency exposure to 401(k) investment options because ERISA’s core fiduciary duties remain the same—ERISA fiduciaries are bound by a duty to prudently select and monitor investment options.
A Brief History of DOL Guidance on 401(k) Plans and Cryptocurrency
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A Brief History of DOL Guidance on 401(k) Plans and Cryptocurrency
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The DOL will also consider next steps against the backdrop of the current administration’s broader approach to digital assets15. In the months since President Trump’s inauguration, federal financial regulators have dramatically shifted their stance towards digital asset activities. The U.S. banking regulators, the Commodity Futures Trading Commission (the CFTC) and the SEC have, like the DOL, rescinded prior guidance stating that digital assets activities should be subject to greater scrutiny, care, or analysis or otherwise treating digital assets differently from other asset classes.
For example, on January 23, 2025, less than a week after President Trump was inaugurated, the SEC withdrew Staff Accounting Bulletin 121, which had required firms custodying crypto assets to include those assets on balance sheets, considering the greater risks they presented. The CFTC has also withdrawn Staff Advisory 23-07, which had warned derivatives clearing organizations to consider the risks of digital assets activities more carefully than other assets16. Additionally, federal banking regulators have withdrawn prior statements requiring banking organizations to obtain pre-approval for digital assets activities17.
The SEC and the CFTC have also taken specific steps to facilitate and encourage digital assets activities. The SEC, for instance, has established a Crypto Task Force that is considering various kinds of exemptive relief from securities regulations to facilitate tokenization, while the CFTC has explored steps to promote trading of digital assets on designated contract markets.
These actions align with the views the administration has expressed in the President’s Working Group Report Strengthening American Leadership in Digital Financial Technology (the PWG Report)18. In that report, the administration made clear that its policy is to take a “technology-neutral” approach to financial regulation and to eliminate the prior administration’s practice of imposing special or additional requirements on digital assets. In the eyes of the current administration, that practice effectively amounted to the regulators utilizing financial regulation to outlaw digital assets19. The PWG Report further expresses the policy view that financial regulators need to take steps to promote digital assets to make “American digital asset markets to become the deepest and most liquid in the world20.”
The DOL will also consider next steps against the backdrop of the current administration’s broader approach to digital assets15. In the months since President Trump’s inauguration, federal financial regulators have dramatically shifted their stance towards digital asset activities. The U.S. banking regulators, the Commodity Futures Trading Commission (the CFTC) and the SEC have, like the DOL, rescinded prior guidance stating that digital assets activities should be subject to greater scrutiny, care, or analysis or otherwise treating digital assets differently from other asset classes.
For example, on January 23, 2025, less than a week after President Trump was inaugurated, the SEC withdrew Staff Accounting Bulletin 121, which had required firms custodying crypto assets to include those assets on balance sheets, considering the greater risks they presented. The CFTC has also withdrawn Staff Advisory 23-07, which had warned derivatives clearing organizations to consider the risks of digital assets activities more carefully than other assets16. Additionally, federal banking regulators have withdrawn prior statements requiring banking organizations to obtain pre-approval for digital assets activities17.
The SEC and the CFTC have also taken specific steps to facilitate and encourage digital assets activities. The SEC, for instance, has established a Crypto Task Force that is considering various kinds of exemptive relief from securities regulations to facilitate tokenization, while the CFTC has explored steps to promote trading of digital assets on designated contract markets.
These actions align with the views the administration has expressed in the President’s Working Group Report Strengthening American Leadership in Digital Financial Technology (the PWG Report)18. In that report, the administration made clear that its policy is to take a “technology-neutral” approach to financial regulation and to eliminate the prior administration’s practice of imposing special or additional requirements on digital assets. In the eyes of the current administration, that practice effectively amounted to the regulators utilizing financial regulation to outlaw digital assets19. The PWG Report further expresses the policy view that financial regulators need to take steps to promote digital assets to make “American digital asset markets to become the deepest and most liquid in the world20.”
What Can We Expect From the DOL in Response to the Executive Order?
To comply with the Executive Order and within 180 days of the date of its publication (i.e., by early February 2026), the DOL is likely to issue clarifying guidance. We may see a notice of proposed rulemaking, which will include proposed regulations and invitation for public comment. If the DOL goes this route, after the comment period closes, the DOL will review and consider all comments and develop a final rule.
It is difficult to predict with certainty the substance of the guidance the DOL will issue. With respect to private equity, real estate, private credit, and related private fund investments, the proposed regulations may seek to memorialize the guidance contained in the Information Letter and provide greater clarity and specificity, particularly with respect to criteria fiduciaries may look to in prudently balancing potentially higher fees against the potentially greater long-term net returns and investment diversification presented by alternative assets. The Executive Order also emphasizes the DOL clarifying the fiduciary duties owed to plan participants when introducing alternative assets into a 401(k) plan’s investment lineup. To this end, and as contemplated by the Executive Order, the DOL may provide a “safe harbor” for plan fiduciaries who include investment options with exposure to these alternative assets, subject to specified conditions being met.
What Can We Expect From the DOL in Response to the Executive Order?
To comply with the Executive Order and within 180 days of the date of its publication (i.e., by early February 2026), the DOL is likely to issue clarifying guidance. We may see a notice of proposed rulemaking, which will include proposed regulations and invitation for public comment. If the DOL goes this route, after the comment period closes, the DOL will review and consider all comments and develop a final rule.
It is difficult to predict with certainty the substance of the guidance the DOL will issue. With respect to private equity, real estate, private credit, and related private fund investments, the proposed regulations may seek to memorialize the guidance contained in the Information Letter and provide greater clarity and specificity, particularly with respect to criteria fiduciaries may look to in prudently balancing potentially higher fees against the potentially greater long-term net returns and investment diversification presented by alternative assets. The Executive Order also emphasizes the DOL clarifying the fiduciary duties owed to plan participants when introducing alternative assets into a 401(k) plan’s investment lineup. To this end, and as contemplated by the Executive Order, the DOL may provide a “safe harbor” for plan fiduciaries who include investment options with exposure to these alternative assets, subject to specified conditions being met.
There is precedent for the DOL providing “safe harbor” protection to plan fiduciaries; under the DOL’s regulations relating to “qualified default investment alternatives” (QDIAs), plan fiduciaries will not be liable for losses resulting from the investment of a participant’s assets in a QDIA, provided that specific requirements are met21”. In this context, the DOL could require plan fiduciaries to consider specific factors and provide additional disclosures to plan participants in connection with selecting and monitoring investment options that hold private equity, real estate, private credit, and other related alternative assets.
With respect to investment vehicles that invest in digital assets, we may see the DOL build on its 2025 Crypto Release and encourage plan fiduciaries to consider these funds through the same lens as other asset classes. Further, we may see the DOL provide a safe harbor to address the unique risks that 401(k) plan fiduciaries face when evaluating, selecting, and monitoring investment vehicles. Alternatively, the DOL may choose to handle guidance relating to investment vehicles that invest in digital assets separately from other asset classes included in the definition of “alternative assets”, especially given the unique risks presented by this asset class (as discussed in the now rescinded 2022 Crypto Release).
What Can We Expect From the SEC?
As noted above, the Executive Order directs the SEC to consult with the DOL and consider ways in which to facilitate greater access to investment by 401(k) plan participants in alternative assets. The Executive Order specifically mentions possible revisions to SEC regulations and guidance relating to accredited investor and qualified purchaser status.
Revisions to SEC regulations and guidance, unlike amendments to the statutes to which the regulations and guidance relate, do not require congressional action and can be adopted by the SEC (in the case of rules) or issued by SEC staff (in the case of guidance). We believe this aspect of the order was intended to facilitate quick changes and to empower SEC Chair Paul Atkins to act more directly in line with the Trump administration's goals in this area.
Earlier this year, Chair Atkins signaled potential changes in how retail investors access private markets and announced plans to revisit the SEC’s 2002 position that requires closed-end funds investing 15% or more of their assets in private funds to impose a $25,000 minimum investment and limit sales to accredited investors, which has restricted retail investor access22. This reflects the significant growth and increased oversight in private markets since 2002, and a desire to align regulation with modern market realities. With the Executive Order’s direction, we expect this plan to gain momentum.
What Can We Expect From the SEC?
As noted above, the Executive Order directs the SEC to consult with the DOL and consider ways in which to facilitate greater access to investment by 401(k) plan participants in alternative assets. The Executive Order specifically mentions possible revisions to SEC regulations and guidance relating to accredited investor and qualified purchaser status.
Revisions to SEC regulations and guidance, unlike amendments to the statutes to which the regulations and guidance relate, do not require congressional action and can be adopted by the SEC (in the case of rules) or issued by SEC staff (in the case of guidance). We believe this aspect of the order was intended to facilitate quick changes and to empower SEC Chair Paul Atkins to act more directly in line with the Trump administration's goals in this area.
Earlier this year, Chair Atkins signaled potential changes in how retail investors access private markets and announced plans to revisit the SEC’s 2002 position that requires closed-end funds investing 15% or more of their assets in private funds to impose a $25,000 minimum investment and limit sales to accredited investors, which has restricted retail investor access22. This reflects the significant growth and increased oversight in private markets since 2002, and a desire to align regulation with modern market realities. With the Executive Order’s direction, we expect this plan to gain momentum.
Aggregate Gross Assets of Private Funds Advised by Either RIAs or ERAs, by Fund Type ($Tn)
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Aggregate Gross Assets of Private Funds Advised by Either RIAs or ERAs, by Fund Type ($Tn)
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After revisiting its position, the SEC could take numerous steps in this area. Among others, we anticipate it could consider rule amendments to lower the income and wealth standards for accredited investors, in addition to lowering the minimum investment requirements for closed-end funds investing in private funds.
More directly responsive to the Executive Order would be rule amendments, or potentially guidance, that directly allow 401(k) plan participants to invest in alternative assets that are currently limited to accredited investors and qualified purchasers. For example, the SEC could take the position that investments by those participants are deemed to be made by accredited investors and qualified purchasers if the plan sponsor is an accredited investor and qualified purchaser (most of which are), like the requirements today for certain trusts and managed accounts.
Whether the SEC would also require plan sponsors in this case to undertake certain diligence or other actions before making that investment available to its 401(k) plan participants is one of many practical questions the SEC will need to address before moving forward in this area.
After revisiting its position, the SEC could take numerous steps in this area. Among others, we anticipate it could consider rule amendments to lower the income and wealth standards for accredited investors, in addition to lowering the minimum investment requirements for closed-end funds investing in private funds.
More directly responsive to the Executive Order would be rule amendments, or potentially guidance, that directly allow 401(k) plan participants to invest in alternative assets that are currently limited to accredited investors and qualified purchasers. For example, the SEC could take the position that investments by those participants are deemed to be made by accredited investors and qualified purchasers if the plan sponsor is an accredited investor and qualified purchaser (most of which are), like the requirements today for certain trusts and managed accounts.
Whether the SEC would also require plan sponsors in this case to undertake certain diligence or other actions before making that investment available to its 401(k) plan participants is one of many practical questions the SEC will need to address before moving forward in this area.
What Does This Mean For You?
The Executive Order does not usher in any immediate regulatory changes, but it has been the subject of significant media coverage, and advocacy groups have taken notice. Despite potential pressure from advocacy groups to issue guidance, it is important to keep in mind that the DOL’s implementation of the Executive Order may involve a lengthy regulatory process—there are quite a few outstanding questions to be addressed by the DOL and the SEC before we see significant changes in this space.
Against this backdrop, we expect private fund sponsors and investment managers to continue to explore avenues for the incorporation of alternative assets into 401(k) plans. We expect to see an increase in partnerships between private funds, investment managers, and traditional 401(k) platform providers. We may also see a greater number of 401(k) plan fiduciaries willing to provide participants with access to alternative assets (including private funds) through managed accounts within 401(k) plans, though we expect this willingness may be tempered until the DOL and/or SEC take action pursuant to the Executive Order. These managed accounts typically require participants to opt-in, thus creating a natural avenue to ensure appropriate disclosures are provided and to mitigate claims from “unknowing” participants.
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