American Agriculture Movement 

American Agri-Women 

American Corn Growers 

Association 

American Council of Life Insurers 

American Homeowners Grassroots 

Alliance 

American Small Business Coalition 

Association for Advanced Life 

Underwriting 

Black Women Enterprises 

Business and Professional 

Women/USA 

Citizens Against Government 

Waste 

Committee of Annuity Insurers 

Federation of Southern 

Cooperatives 

Financial Services Roundtable 

Hispanic Alliance for Progress 

Institute (HAPI) 

Hispanic Business Roundtable 

Hispanics Impacting Public Policy 

Intertribal Agriculture Council 

The Latino Coalition 

National Association for Female 

Executives 

National Association for Variable 

Annuities 

National Association of Farmer 

Elected Committees 

National Association of 

Hispanic/Latino Farmers and 

Ranchers 

National Association of 

Independent Life Brokerage 

Agencies 

National Association of Insurance 

and Financial Advisors 

National Association of Small 

Disadvantaged Businesses 

National Caucus and Center 

on Black Aged 

National Community Pharmacists 

Association 

National Consumers League 

National Taxpayers Union 

Oklahoma Farmers Union 

Small Business and 

Entrepreneurship Council 

Soybean Producers of America 

U.S. Chamber of Commerce 

Women Entrepreneurs, Inc. 

Women Impacting Public Policy 

Women in Need Industries 

Women’s Institute for a Secure 

Retirement 

Women Involved in Farm 

Economics 

April 16, 2010 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

Room N–5655 

U.S. Department of Labor, 

200 Constitution Avenue, NW 

Washington, DC 20210, 

Attention: Lifetime Income RFI 

Re: Request for Information RIN 1210–AB33 

Americans for Secure Retirement is pleased to submit this comment letter in 

response to the Request for Information on lifetime income arrangements (RIN 

1210–AB33) (the “RFI”). We commend the Obama Administration and the 

Departments of Treasury and Labor (the “Agencies”) for turning their attention to 

the promotion of guaranteed lifetime income for Americans. Given the 

increasingly difficult retirement challenge facing Americans, we strongly support 

encouraging and providing incentives for Americans to secure a steady stream of 

guaranteed income in retirement. 

Americans for Secure Retirement (“ASR”) is a broad-based coalition of more than 

70 member and affiliate organizations committed to raising awareness of the 

increasing challenges Americans face in having a financially secure retirement. In 

particular, ASR often focuses on those Americans with little or no access to 

employer sponsored plans. Our coalition includes organizations that advocate for 

Hispanics, women, small business, farmers and others, all united in an effort to 

ensure that all Americans have access to guaranteed streams of retirement 

income that cannot be outlived. 

As the Agencies recognized in the RFI, the United States is facing a looming 

retirement crisis. People are living longer, and traditional sources of guaranteed 

retirement income, like pensions and Social Security, cover less and less of what 

they need in retirement. At the same time, fewer Americans workers have access 

to any kind of employer-sponsored retirement plan. For those whose employers 

do offer a retirement plan, defined contribution plans, such as 401(k)s, have 

become far more common than defined benefit plans. Making matters worse, the 

recent stock market declines have driven the average balances in 401(k) plans 

down to about $60,000. In fact, workers aged 45-54 who have been making 

contributions to a 401(k) plan for at least 20 years saw the value of their 

retirement fund decrease by nearly 30 percent in 2008.1

 

1

 Employee Benefit Research Institute, 401(k) Balances and Changes Due to Market Volatility – 

Data. January 20, 2009, 

(http://www.ebri.org/pdf/jan%2020,%202009%20update%20full%20universe.pdf) 
As a result, the opportunity for many Americans to enjoy a financially successful 

retirement increasingly depends on their ability to manage their retirement savings 

in such a way that they can achieve a steady stream of income for 20 to 30 years 

of retirement. 

This is a very steep mountain to climb, especially for middle income Americans. A 

study recently commissioned by ASR and prepared by Ernst & Young found that 

three out of five Americans entering retirement at age 65 can expect to outlive 

their financial assets. To avoid outliving their savings, the report indicated that 

Americans retiring today with no guaranteed source of income beyond Social 

Security will have to reduce their standard of living by an average of 32 percent. 

Americans who are seven years away from retirement will most likely have to 

reduce their standard of living by an average of 45 percent. This study also found 

that those with guaranteed retirement income beyond Social Security, such as 

lifetime annuities, are much better prepared for retirement than those without. 2

 

Similarly, a recent Gallup Poll found that annuity owners felt much more secure 

and prepared for their retirement because of the stream of income received from 

this retirement vehicle. 3

 

The challenge is even greater for particular segments of the American population, 

including women, Hispanic Americans, small business owners and those who 

work in the agricultural sector. In general, these groups lack access to traditional 

employer-sponsored retirement plans. They may also be affected by unique 

factors that limit their opportunities to build up and manage their retirement 

assets, including income disparities, unpredictable income based on commodity 

prices, limited access to traditional savings vehicles and, for women, longer life 

expectancy. Consider the following: 

- Women. Women face unique retirement challenges over their male 

counterparts. On average, women have fewer full-time working years than 

men and have median annual earnings that are about $10,000 less than 

those of working men. Women typically live longer than men and are likely 

to spend some of their retirement years alone due to widowhood or 

divorce. These disparities lead to lower savings and retirement income 

and smaller payouts from Social Security, ultimately resulting in a greater 

risk of poverty in retirement.4

- Hispanic Americans. While Hispanics work in all sectors of the economy, 

they are more heavily concentrated in jobs that lack traditional retirement 

options and typically earn a lower income, affecting their ability to save for 

retirement. For example, a recent study conducted by The Hispanic 

Institute and ASR reported that only 25.6 percent of Hispanics are covered 

by pension plans, compared to 42.5 percent of whites and 40 percent of 

 

2

 Americans for Secure Retirement: Updated Retirement Vulnerability Analysis: The likelihood of 

outliving their financial assets, by Ernst & Young LLP, June 2009; 

(http://paycheckforlife.org/userfiles/file/Updated%20Retirement%20Vulnerability%20Analysis_2009

_FINAL.pdf ) 

3

 The Committee of Annuity Insurers, 2009 Survey of Owners of Non-Qualified Annuity Contracts; by 

The Gallup Organization and Matthew Greenwald and Associates; (http://annuityinsurers.org/pdfs/09.17.09.atta.Final2009GallupSurvey.pdf) 

4

 Americans For Secure Retirement: The Female Factor, 2008; by Cindy Hounsell, WISER 

(Women’s Institute for a Secure Retirement); (http://paycheckforlife.org/uploads/ASRwhite_paper_FINAL.pdf) 
African-Americans. Recent trends indicate that Hispanics have actually 

become less prepared for retirement over the past few years.5

 

- Small Business. Small business owners face unique challenges that put 

them at risk of falling short in retirement. Many small business owners 

reinvest significant portions of their income into their businesses, and 

therefore cannot afford the cost of establishing and maintaining traditional 

defined benefit or defined contribution plans for themselves and their 

employees. These entrepreneurs often expect to use the proceeds from 

the future the sale of their business to finance their retirement. 

- Rural and Farming Communities. America’s rural and farming 

communities are influenced by factors that make obtaining a secure 

retirement uniquely difficult. Farmers are less likely to be covered by 

traditional pensions, forcing them to rely on Social Security at a much 

greater rate than those in other sectors at a time when Social Security on 

average only covers two-thirds of retirement needs. In addition, there is 

extreme variability in farm income due to largely uncontrollable fluctuations 

in commodity prices, weather, and macroeconomic policies making it more 

difficult for farmers to adequately plan and save for retirement. 6

To address these challenges, Americans for Secure Retirement strongly supports 

providing incentives that make secure retirement vehicles such as annuities more 

accessible and affordable. Annuities are the only product that can provide 

Americans with a guaranteed stream of lifetime income through retirement - a 

“paycheck for life” – to ensure that they will not outlive their income. To that end, 

we urge the Agencies to develop rules that will remove obstacles and provide 

incentives to encourage employers to provide their employees with the option to 

annuitize all or a portion of their defined contribution retirement accounts, and to 

encourage employees to take advantage of such options. In addition, the 

Agencies should develop rules to provide similar incentives for the large number 

of Americans whose retirement savings are held outside of employer plans, such 

as in individual retirement accounts and annuities. The need for guaranteed 

lifetime income vehicles to help manage retirement savings is not limited to 

participants in employer based retirement programs. Americans for Secure 

Retirement stands ready to assist the Agencies in developing or refining 

rulemaking proposals. 

We appreciate the opportunity to provide our input in this process. 

Sincerely, 

 

5

 Hispanics And Retirement: By The Hispanic Institute, For Americans For Secure Retirement 

2009, (http://paycheckforlife.org/uploads/white-paper-hispanics-and-retirement-english.pdf) 

6

 Lifetime Income Crucial to Farmer’s Retirement Security,” American Corn Growers Association 

and Americans for Secure Retirement, 

(http://paycheckforlife.org/uploads/Ag_Issue_Brief_FINAL.PDF) 
 

Brent Wilkes Barbara Kasoff 

Executive Director President 

League of United Latin American Women Impacting Public Policy 

Citizens (LULAC) 

 Hector Barreto Rudy Arredondo 

Chairman President and CEO 

Latino Coalition National Latino Farmers and 

Ranchers Trade Association 

Debbie Frett Duane Parde 

CEO President 

Business and Professional National Taxpayers Union 

Women’s Foundation 

 

 

 Steve Bartlett Ricardo Aponte Parsi 

President and CEO President of AIHE 

The Financial Services Roundtable 

 
Tammy Basel 

President 

WIFE (Women Involved in Farm Economics) 

    

Bruce Hahn Leeanna Roman 

President President/Founder 

American Homeowners Grassroots Hispanics Impacting Public Policy 

Alliance and the (HIPP) 

American Homeowners Foundation 

 

Harvey Joe Sanner Karen Kerrigan 

American Agriculture President & CEO 

Movement of Arkansas Small Business & Entrepreneurship 

Council 

 Henry T. Wilfong Jr. Marsha Firestone 

Chairman President 

National Association of Small Women President’s Organization 

Disadvantaged Businesses