The DOL has previously estimated that final rule’s greater clarity will provide $447.1 million in annual cost savings and an additional $48.7 million in annual cost savings attributable to reduced litigation. We have not assessed the DOL’s analysis of these cost savings, but we mention it here because if the DOL withdraws the final rule, then these cost savings will be lost. They therefore should be added to the DOL’s economic impact analysis of withdrawing the final rule. However, since this estimate was used by the DOL to argue in favor of the final rule, it should be accepted with a grain of salt until independent estimates are provided.