May 3, 2010 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

U.S. Department of Labor 

200 Constitution Avenue N.W. 

Room N5655 

Washington, D.C. 20210 

Attn: Lifetime Income RFI 

Re: Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in 

Retirement Plans [RIN 1210-AB33] 

To Whom It May Concern: 

Thank you for the opportunity to comment in response to the RFI by the Department of Labor and the 

Department of the Treasury regarding lifetime income options in retirement plans. Weber Shandwick 

commends the government’s interest in promoting guaranteed lifetime retirement income options for 

Americans, particularly in light of the recent economic downturn and resulting trends in the retirement 

services industry. In our view, this is a tremendously important issue and one that should be an 

immediate priorityfor both agencies. 

Context for Our Point of View 

As a global public relations firm, Weber Shandwick has advised leading 401(k) plan providers for the past 

decade and has worked extensively in the retirement services space with a specific focus on retirement 

income industry thought leadership initiatives and issues. We also specialize in developing integrated 

communications campaigns that seek to change behavior, and we’ve done this successfully with both 

private sector and government clients in recent years, including the IRS e-file campaign, the Earned 

Income Tax Credit (EITC), the Taxpayer Advocate Service (TAS), the Federal Deposit Insurance 

Corporation (FDIC), Go Direct/Direct Express (U.S. Treasury and Federal Reserve Bank), the United 

States Army and the 2010 Census. 

We were particularly encouraged to see the DOL and Treasury asking for public comment on the 

necessity of participant education and how it should be provided. The importance of financial education 

was further reinforced this week by an excellent op-ed published on The Huffington Post and co-authored 

by U.S. Treasury Secretary Tim Geithner, U.S. Education Secretary Arne Duncan and Senior Advisor and 

Assistant to the President Valerie Jarrett. The piece concluded with the point that we need to provide all 

Americans with the financial education they need “to succeed in this increasingly complex, fast-moving 

economy.” Weber Shandwick’s experience in working at the intersection of retirement and government 

tells us that the best public education campaigns are grounded in research—and that they reach their 

intended audiences with tested messages and through multiple channels. 

Primary Research: A Critical First Step 

Without question, there are differences in the way various demographic groups would view lifetime 

income products and these must be taken into account. Age, education, income levels, race and ethnicity, 

gender and where people live often serve as key factors in determining how individuals prepare for 
retirement. For example, Generation Y looks at retirement much differently than Generation X, and both 

of these generations have different priorities and views than Baby Boomers. 

In order to truly understand these nuances, Weber Shandwick recommends that DOL and Treasury jointly 

undertake a primary research project in order to fully understand these views. We also recommend a 

thorough review of existing financial literacy and financial education programs currently delivered by the 

federal government in order to ensure coordination of efforts, elminate duplication of efforts and maximize 

effectiveness. Both the primary research and relevant existing programs, in our view, should then become 

the foundation for a public education campaign that should reach the intended audience through multiple 

channels, including social media, earned media, partnering organizations, industry influencers, and 

participant materials. The campaign must be measured to determine its effectiveness in achieving the 

desired behavior changes. 

Equip Employers to Be Part of the Solution 

Due to our past work on financial literacy campaigns and the passage of the Pension Protection Act 

(PPA) in 2006, we understand that employers are key to delivering retirement income education and 

changing behaviors and mindsets among their employees. Weber Shandwick represented the Business 

Roundtable on its work with the Pension Coalition, and we know from that experience that a broad array 

of employer stakeholders—the American Benefits Council, The Dow Chemical Company, The Dupont 

Company, The ERISA Industry Committee, Financial Executives International, Ford Motor Company, 

General Motors Corporation, Honeywell, IBM, International Paper, John Deere, Kodak, the U.S. Chamber 

of Commerece and Xerox Corporation—want to be part of the solution. 

 As such, plan sponsors must be adequately supported in their efforts to help workers shift their mindsets 

from retirement savings to retirement income. In many ways, plan sponsors are as challenged by the 

increasingly complex economy as are their participants. They are being asked to wear many hats, to do 

more with less, and to provide retirement benefits to a rapidly diversifying workforce. Given these 

increasing demands, it is Weber Shandwick’s view that any public education campaign undertaken by 

DOL and Treasury should include a plan sponsor component—as well as a plan participant component. 

Extend Access to Americans Without an Employer-Sponsored Plan 

In addition, customized outreach must be done to Americans who may lack access to employersponsored plans, including but not limited to small business owners, women, rural Americans, Hispanics 

and other race and ethnic groups who may need in-language and in-culture communication. The 

government should, in Weber Shandwick’s view, partner with industry organizations to deliver this critical 

education if the employer conduit is missing. These Americans must hear messages about retirement 

income from “trusted voices,” organizations and community leaders who have credibility with them. 

In Weber Shandwick’s view, lifetime income options must, whether offered or mandated, opt-in or opt-out, 

in-plan or out of plan, be accompanied by an integrated communications campaign for their intended 

audiences if they are to truly succeed in bringing about the desired behavior changes we all agree are 

necessary in order to achieve greater retirement security. This is a noble goal, and an achievable one, if 

employers and employees are surrounded with the communication and financial education they need to 

succeed. 

Sincerely, 

Barb Iverson 

President, Financial Services 

Weber Shandwick 

Direct line: 952-346-6176 

biverson@webershandwick.com