From: Worden, Brooke (MIN-WSW) [mailto:bworden@webershandwick.com] 

Sent: Sunday, August 15, 2010 12:15 AM 

To: EBSA, E-ORI - EBSA 

Subject: Request to Speak at Joint Public Hearing on Lifetime Income Options

Filed Electronically 

 

August 14, 2010 

 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

U.S. Department of Labor 

200 Constitution Ave., N.W. 

Washington, D.C., 20210 

 

Re: Request to Speak at Joint Public Hearing on Issues Relating to Lifetime Income 

Options for Workers in Employer-Sponsored Retirement Plans

 

Ladies and Gentlemen: 

 

Please consider the following request to testify at the upcoming joint public hearing on issues 

relating to lifetime income options for workers in employer-sponsored plans. If selected to speak, 

the majority of my remarks would focus on issues related to information to help participants 

make choices on the management and spend down of retirement benefits. On May 3, 2010, my 

firm, Weber Shandwick, submitted a public comment to the Request for Information (RFI) 

Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans [RIN 

1210-AB33]. Please consider the following proposed outline for my remarks for the hearing 

scheduled for September 14, 2010 and if necessary, on September 15, 2010. 

 

• Introductory Remarks 

o Commendation to the U.S. Department of Labor's Employee Benefits 

Security Administration (EBSA) and the Department of the Treasury for 

convening this critically important dialogue 

o Brief introduction of Weber Shandwick and my work in the retirement services 

industry, the federal government sector and financial literacy over the past 

decade (my qualifications to be a witness) 

• Overview of the Retirement Services Industry Landscape 

o Context from my work with the Business Roundtable and Pension Coalition on 

the Pension Protection Act (PPA) in 2006 as described in my recent opinion piece 

on www.plansponsor.com dated August 2, 2010, in observance of the four-year 

anniversary of the PPA's passage and an analysis of how the industry has 

changed in those four years 

o An industry under pressure prior, even prior to the financial crisis in 2008. (an 

aging population, a market hungry for innovative solutions, etc.) The financial 

crisis amplified these pressures. 

o Since 2008, the concept of retirement in America has changed and new 

educational initiatives are needed to address items not previously anticipated. 

• New Educational Initiatives Are Needed to Change the Mindset: Retirement Savings vs. 

Retirement Income 
o Accumulation vs. decumulation 

o Saving not just to retirement, but through retirement 

• The Role of the Plan Sponsor 

o Employers are a key channel for delivering retirement income education 

o Today's plan sponsors wear many hats and face increasing pressures--to do 

more with less, to answer more participant questions, etc. 

o Plan sponsors have been slow to adopt retirement income solutions, and greater 

education and support for them is likely to speed adoption. 

o In the new economic reality, plan sponsors must be better equipped and 

educated to be part of the solution to the challenge of achieving retirement 

security for all. 

• The Role of the Plan Participant 

o Today's workforce is increasingly diverse and new educational initiatives are 

needed to address their changing needs. 

o The financial crisis has sparked a growing demand for transparency and 

information on demand. 

o Communicating in the new reality (post-2008) means plan participants need to 

be surrounded with retirement income education from multiple sources--their 

plan sponsors, the government, social media, earned media coverage, trusted 

organizations, industry influencers and participant materials. 

• Specific Recommendations 

o Conduct a thorough review of existing financial literacy and financial education 

programs currently delivered by the federal government in order to identify new 

and emerging needs, ensure coordination of efforts, and maximize efficiency and 

effectiveness. The Department of Labor is to be commended for its "Saving 

Matters" Retirement Savings Education campaign, and specifically its "Taking the 

Mystery Out of Retirement Planning" publication. This review would seek to 

answer the question: are there additional needs? 

o Conduct a primary research project to develop a current understanding of the 

way various demographic groups view lifetime income products. Consider age, 

education, income levels, race and ethnicity, gender and geography. 

o Based on these two inputs, the review of existing financial literacy and financial 

education programs and the primary research, develop a plan of action. 

• Additional Considerations Related to Those Without Access to an Employer-Sponsored 

Plan (These may or may not be within the scope of the hearing, and I look forward to 

the Department's feedback as to whether or not they should be included.) 

o Senator Bingaman recently introduced a bill proposing the creation of an 

Automatic IRA program for employees of employers without a sponsored plan. If 

adopted, the Automatic IRA program should include an educational initiative for 

employers and employees. 

o Specific populations lacking access to employer-sponsored plans in larger 

numbers have unique educational needs, and those needs must be considered. 

These groups include, but are not limited to small business owners, the selfemployed, women, those living in rural areas, the geographically remote, 

Hispanics and other race and ethnic audiences. These audiences need to hear 

about retirement income from "trusted voices," organizations and community 

leaders who have credibility with them. 

• Conclusion 

o Thank you for the opportunity to testify before you today. 

o The retirement security issue is of tremendous importance, and the U.S. 

Department of Labor's Employee Benefits Security Administration (EBSA) and the 

Department of the Treasury is to be commended for facilitating this critically 

important discussion. 
 

As my request to testify is reviewed, I would like to express my thanks for your consideration. 

The retirement security issue is one I care passionately about, and one my firm, 

Weber Shandwick cares passionately about, and I would greatly appreciate the opportunity to 

continue to participate in the dialogue. 

 

Sincerely, 

 

Brooke Worden, APR 

Vice President, Financial Services 

Weber Shandwick