From: Rick Morehouse [mailto:Rick.Morehouse@RaymondJames.com] 

Sent: Tuesday, July 21, 2015 12:46 PM

To: EBSA, E-ORI - EBSA

Cc: Matthew Watts; Scott Stolz; Vanessa Marcos

Subject: RIN 1210-AB32

It is my understanding that you are interested in real life examples of uses of annuities in IRAs. I can use 

myself as an example of the value of an annuity in retirement income planning. I have rolled over funds 

from my 401k to my IRA specifically to purchase a variable and a fixed indexed annuity with guaranteed 

withdrawal riders. Why? I remember 2008. I am within a few years of retirement and don’t want to 

experience a market correction that could dramatically affect my retirement income. A market 

correction at the wrong time could decimate my retirement plans. The expenses I pay on my annuities 

is the same my clients pay. Why would I pay the additional fees? Because of the additional benefits. I 

use the analogy that I could buy liability insurance only on my vehicle rather than pay the additional 

expense of collision insurance, but the risk is too great. If I should wreck my car the additional expense 

of collision insurance is worth the benefit of the insurance company replacing my vehicle. And the risk 

of my retirement income plan blowing up would have a much greater negative economic effect than the 

loss of a single vehicle. From the perspective of me making so much more on the variable annuity, the 

commission paid on the variable annuity is actually less than many mutual funds. Whether I invest in 

mutual funds, variable annuities, or CDs, there is a cost. The DOL wouldn’t expect a doctor, lawyer, or 

CPA to work for free. Why shouldn’t an advisor get paid for their services and expertise? A large part of 

our job is educating the client on the investments and help them determine what financial product is 

best for them. Built into the service provided to the client is integrity. We already do what we feel is in 

the clients best interest. Just because there is a financial product out there that would pay me more 

doesn’t mean that’s the automatic choice I’ll make. We have a moral and a fiduciary responsibility to 

the client.

I know you interested in client real life examples. Yes, I have them...as most advisors do. Last week I 

met with a widow that received a death benefit of about 50% more than the account value at her 

husband’s death. I’d say the additional cost was worth it to her It still served her well. Two weeks 

before that I met with a widow whose husband had guaranteed her retirement income for the rest of 

her life by owning annuities with Guaranteed Minimum Income Benefit and Guaranteed Minimum 

Withdrawal Benefit riders. She would not have had the level of retirement income she currently enjoys 

had it not been for his thoughtful purchase of those annuities. It was a viable investment for the client’s 

purpose. Those stories go on and on. I wouldn’t disclose my clients names as financial information is 

about as personal as you get. I would be happy to have my name and story disclosed, and I’d hope the 

DOL wouldn’t view it as “one of those self-serving Financial Advisors” saying anything to take advantage 

of the client...even though the client is me. I will happily provide more input when I can, but I am 

protective of my clients and their privacy.

Thank you for your time in reading this correspondence.

Rick

Rick A. Morehouse, CPA, CFP

Financial Advisor, RJFS

Platte Valley Investment Center, Inc.

1212 Circle Drive
P.O. Box 2308

Scottsbluff, NE 69363-2308

308-635-7766 Ext. 9208

308-633-9208 Direct Line

308- 633-9539 (fax)

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