-----Original Message----- 

From: Dillon Pyron [mailto:dmpyron@austin.rr.com] 

Sent: Tuesday, May 04, 2010 4:45 PM 

To: EBSA, E-ORI - EBSA 

Subject: RIN 1210–AB33 

Regarding this request, certain workers are capable of making 

investment decisions that produce returns greater than "market". The 

question raised here indicate an interest in taking the ability away 

from these individuals, penalizing them for the inability of others to 

make wise investment decisions or their unwillingness to invest in 

their retirement at all. This is currently being addressed by many 

employers in the form of "default contribution elections" and "default 

investment decisions". 

The major failings in defined benefit plans are the unwillingness or 

inability of employers to contribute sufficiently to the plans and the 

failure to make sufficiently "aggressive" 

investments. Aggressive does not mean risky but rather investments 

that might produce income in excess of inflation. With current 

interest rates at or below 1%, many of these plans are unable to make 

enough money to cover their own expenses. 

Defined contribution plans offer their own risks. Incorrect investment 

decisions can result in lost value. But prudent investments can reduce 

the risk, although these same decisions may also reduce the gain 

(nothing ventured, nothing gained). However, the wise investor can 

recognize certain events as likely to occur and change philosophies in 

time. Not "market timing", which is definitely a risky policy, but 

saying "hmm, it looks like we've gone over the top and are headed down. 

We've lost 10% in the last 2 months." Or "looks like we've bounced for 

keeps. The markets have made a steady climb over the last 4 months". 

Many people have been burned over the last 5 years because they choose 

to buy on credit instead of save. In addition, many people elected to 

make long term decisions based on a short term environment. In early 

2007 many people were already proclaiming the imminent real estate 

implosion. 

If an individual elects to let the government make investment 

decisions, I believe that should be done. But if an individual chooses 

to make her/his own decisions, that also should be available. 

I do not believe the government is capable of making accurate decisions 

on issues such as return or anticipated life expectance. Enough so 

that a truly adequate benefit can be provided to allow the individual 

to live in a "life style to which I have become accustomed". 

Finally, I am concerned about the ability of Congress to preserve these 

investments, much as has been done with Social Security. Our biennial 

reports show pay outs that I don't believe to be realistic. They seem 

to anticipate income from investments that is not likely to be there. 

The only way this amount can be paid is if the amounts "borrowed" are 

returned to the trusts, which is not likely to happen without 
significant borrowing. Borrowing that will increase inflation and 

lower the true spending value of the Social Security pay out. 

The questions proposed here indicate an interest in plan that would 

reduce my ability to adequately cover future expenses. A guaranteed 

payment of, as a simple example, $1000 per month might, in ten years, 

only be the equivalent of $750. Many investment advisors suggest 

expenses of between 65 and 75% of current expenses be anticipated. 

However, some advisors then correct this for anticipated inflation. 

But a life time annuity can not correct for this. If the above example 

covered at the 75% rate, this would only amount to about 56% of 

expenses. 

Respectfully, 

Dillon Pyron, RT(R) 

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