This article continues the discussion of the DOL’s Performance Benchmark factor by reviewing the first example of the application of that factor. As background, the DOL’s proposed regulation on selecting investments, including alternative assets, 2026-06178.pdf, identifies six factors that should be considered in the process of selecting any investments for participant-directed plans, such as 401(k) plans and private sector 403(b) plans. The six factors are: Performance, Fees, Liquidity, Valuation, Performance Benchmark, and Complexity. The proposal describes each of those factors and provides 20 examples of their application. In earlier posts, I covered three of the factors—Performance, Fees and Complexity, and their examples. My last post, Alternative Assets (18), discussed the Performance Benchmark factor.  Here is the DOL’s first example of the application of that factor: (1) Example. Benchmark; Misalignment of strategies— (i) Facts. A participant-directed individual account plan offers a designated investment alternative that is a target date fund with an investment strategy and long-term objective of investing in different asset classes with varying degrees of risk, and which gradually becomes more conservative over time by adjusting the mix of asset classes. To compare the risk-adjusted expected returns of the target date fund to a meaningful benchmark, the named fiduciary