Walter Welsh 

Executive Vice President, Taxes & Retirement Security 

(202) 624-2157 t (866) 953-4149 f 

walterwelsh@acli.com 

James Szostek 

Vice President, Taxes & Retirement Security 

(202) 624-2378 t (866) 953-4149 f 

jimszostek@acli.com 

Shannon Salinas 

Counsel, Taxes and Retirement Security 

(202) 624-2028 t (866) 953-4149 f 

shannonsalinas@acli.com 

Mailed Electronically

August 16, 2010 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

Attn: Lifetime Income Joint Hearing, Room N-5655 

U.S. Department of Labor 

200 Constitution Avenue, NW 

Washington, DC 20210 

Subject: Request to Testify at Lifetime Income Joint Hearing 

Dear Sir or Madam: 

The American Council of Life Insurers* (“ACLI”) respectfully requests an opportunity 

to testify at the joint hearing of the Department of Labor and the Department of the 

Treasury on certain issues relating to lifetime income options for participants and 

beneficiaries in retirement plans. 

ACLI member companies offer insurance contracts and other investment products 

and services to qualified retirement plans, including defined benefit pension and 

401(k) arrangements, and to individuals through individual retirement arrangements 

(IRAs) or on a non-qualified basis. ACLI member companies also are employer 

sponsors of retirement plans for their own employees. 

The life insurance industry provides protection for individuals and families against 

the risk of adverse financial consequences due to premature death, long-term care 

needs, disability, and outliving one’s financial assets or living at a substantially 

 

* The ACLI represents more than 300 legal reserve life insurer and fraternal benefit society member 

companies operating in the United States. These member companies represent over 90% of the 

assets and premiums of the U.S. life insurance and annuity industry. 

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reduced standard of living. ACLI members have many years of experience providing 

lifetime income through the only financial product that may offer a guaranty for life, 

the annuity. 

As we discussed in our response to the request for information, the principal 

obstacles to greater use of the annuity to provide guaranteed lifetime income is a 

lack of understanding on the part of plan sponsors and participants about the 

benefits and operation of the annuity and some uncertainties about the fiduciary 

duties of the sponsor in selecting and administering an annuity. We support efforts 

to make it easier for plan sponsors to provide information and education about 

annuities including the illustration of an individual account balance as lifetime 

income. Our testimony will focus on these two key areas: (1) on education, including 

information to help participants make choices regarding management and spend 

down of retirement benefits and the disclosure of account balances as monthly 

income streams, we plan to discuss survey data on point as well as key elements for 

the development of such disclosure (approximately 5 minutes); and (2) on fiduciary 

safe harbor for selection of lifetime income issuer or product, we plan to discuss 

fiduciary concerns and how these could be addressed by the Department of Labor 

(approximately 5 minutes). 

We plan to address our observations regarding the lifetime income marketplace, 

including product innovations, and steps the Department of Labor could take to 

further education regarding lifetime income to assist participants and beneficiaries in 

making informed decisions regarding their distribution choices. 

ACLI would appreciate an opportunity to testify. We believe our testimony would be 

of value to you. We thank you for your consideration of this request. 

Sincerely yours, 

Walter C. Welsh James H. Szostek 

Executive Vice President, Vice President, 

Taxes & Retirement Security Taxes & Retirement Security 

 

Shannon Salinas 

Counsel, 

Taxes & Retirement Security