August 16, 2010 

U.S. Department of Labor 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

N-5655 

200 Constitution Avenue, NW 

Washington, DC 20210 

Submitted via email to E-ORI@dol.gov 

Re: Written request to present oral comments at the Sept. 14th/15th retirement lifetime 

income hearing 

Dear Sir or Madam, 

Natixis Global Asset Management (NGAM) respectfully requests the opportunity to 

testify at the Department of Labor and the Department of the Treasury’s joint hearing to 

consider specific issues relating to options that provide a lifetime stream of income after 

retirement for plan participants and beneficiaries. 

As one of the 20 largest asset managers in the world1

 and as a well-known provider of a 

number of retirement products and services, NGAM would be honored to offer our 

perspective on this important issue. Our testimony would be based on the viability of 

mutual funds as effective vehicles for addressing key concerns of investors about 

lifetime income products. 

Testimony Outline: 

#1. Certain Specific Participant Concerns Affecting the Choice of Lifetime Income 

Relative to Other Options (5 minutes)

Retirement income planning is a complex mixture of optimization of yield, capital 

appreciation and risk management. The selection of mutual funds as a method to 

provide lifetime income would address concerns including: 

o Risk Management 

o Mitigating longevity risk 

o Inflation-adjustment 

o Liquidity and withdrawal options 

o Portability 

 

1

 Assets under management total $651 billion s of June 30, 2010. 
o Minimizing complexity 

# 2. Information to Help Participants Make Choices Regarding Management and Spend 

Down of Retirement Benefits (5 minutes) 

Mutual funds have a 70 year track record and offer: 

o Easy access to information through a variety of vehicles 

o Transparency - Mutual funds provide information about holdings on a 

regular, periodic basis 

o Lower fees – Costs are fully disclosed at sale and on ongoing basis 

o Governance – An independent board stands as watchdog for shareholder 

interest 

As Senior Vice President, Retirement Strategy for Natixis Global Associates, the 

distribution arm of NGAM, I am grateful for this opportunity to present oral comments for 

the record. I am responsible for the development and execution of retirement initiatives, 

including new retirement solutions, marketing activities and educational programs. A 

more detailed biography follows. 

Natixis Global Asset Management appreciates your consideration of our request to 

testify. The task of improving the country’s retirement savings system is a major national 

concern of immense proportions. We believe that we can provide valuable information 

regarding the viability of employing mutual funds in the development and administration 

of retirement plan models that can provide a predictable income stream in retirement. 

Please do not hesitate to contact me at 617-449-2581 if you have further questions. 

Sincerely, 

Tracey E. Flaherty 

Senior Vice President, Retirement Strategy 

Natixis Global Associates 

399 Boylston Street 

Boston, MA. 02116 

Tracey.flaherty@ga.natixis.com