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The Initiative on Financial 

Security at the Aspen Institute is 

a leading policy program focused 

on bold solutions to help all 

Americans at every stage of life 

to save, invest, and own.

Pamela Perun, Policy Director of the Initiative on Financial Security at the Aspen 

Institute, requests an opportunity to testify at the Hearing on Certain Issues Related 

to Lifetime Income Options for Participants and Beneficiaries in Retirement Plans 

on the topic of a Fiduciary Safe Harbor for Selection of Lifetime Income Issuer or 

Product. She proposes to testify on the following issues: 1) legal history of fiduciary 

standards regarding annuity options (4 minutes); 2) rationales for different fiduciary 

standards for defined contribution and defined benefit plans (3 minutes); and 3) 

policy alternatives to secure the promise of annuities purchased through defined 

contribution plans (3 minutes).

The Aspen Institute Initiative on Financial Security is a leading policy program 

dedicated to helping bring about the policies and financial products that enable all 

Americans to save, invest, and own. Its signature policy agenda is articulated in Savings 

for Life: A Pathway to Financial Security for all Americans, which argues for a lifespan 

approach to saving, including annuities for later life financial security. Pamela Perun, 

a pension lawyer and developmental psychologist, works intensively on the legal 

and economic issues underlying financial security throughout life and has a special 

interest in retirement income policy issues in defined contribution plans. She is the 

author of “Putting Annuities Back into Savings Plans” which appeared in Employee 

Pensions: Policies, Problems and Possibilities, edited T. Ghilarducci and C. Weller (2007).

Pamela Perun has also researched pension plans integrated with Social Security for 

the Boston College Center for Retirement Research and the potential effects of Social 

Security reform on the private pension system for AARP. For the Urban Institute, 

she has written about phased retirement programs, personal accounts under Social 

Security, contribution limits to savings plans, trends in stock-based compensation, 

and universal savings accounts. She edits the Employee Benefits, Compensation 

and Pension Journal for the Social Science Research Network. Ms. Perun practiced 

employee benefits law in Boston and Washington, D.C., and has held research 

appointments at Duke University, Wellesley College and Harvard University Medical 

School. She received a J.D. from the University of California at Berkeley, a Ph.D. in 

Human Development from the University of Chicago, and a B.A. from Wellesley 

College. She is a member of the Massachusetts, District of Columbia and California 

Bar Associations.

Request to Testify to Employee Benefits Security Administration

from the Aspen Institute Initiative on Financial Security

August 16, 2010

Hearing on Certain Issues Relating to Lifetime Income Optio

Participants and Beneficiaries in Retirement