From: Boutwell, Ryan [mailto:Ryan.Boutwell@associatedfinancialgroup.com] 

Sent: Tuesday, February 02, 2010 9:47 AM 

To: EBSA, E-ORI - EBSA 

Subject: RIN 1210-AB33

I would like to offer my opinion regarding the discussion of Lifetime Annuities being offered within

company qualified plans.  I am a consultant in the qualified plan industry and have worked with hundreds

of business retirement plans over the last 10 years.  I do not believe requiring plans to have an annuity

feature is a good idea.  The retirement plan industry is already grappling with the fee disclosure issue and

I tend to find small plans are already burdened with onerous compliance rules.  Adding a requirement of

an annuity feature is going to add more cost inside these plans that are already expensive to administer

and invest in.  It might benefit some of the insurance/annuity providers of retirement plans, but it will

definitely be a burden to the pure mutual fund/open architecture recordkeeping programs.  These

programs are often the most cost competitive for small business plans.  In an industry that is already

under a lot of fee scrutiny adding in another possibly expensive layer of requirements to have a

mandatory annuity feature is not a constructive move in my opinion.  Especially considering that annuity

products are already available to former plan participants on the open market away from their employer.

  

If you ask me, the retirement plan industry does not need more requirements to meet, it needs less and

from a participant stand point, participants need more education.  I have met with thousands of business

retirement plan participants over the last 10 years, most of them are looking for simplification and good

solid financial advice.  An annuity can be an appropriate investment vehicle for some employees, but it is

not a one size fits all solution and at the end of the day it comes back to education to the participant.  A

better educated participant will make better choices and this will benefit everyone from the Small

Business that offers a plan to the participant, to the Vendors that work in this industry.  If you are looking

to make changes to retirement plans don’t do it by mandating new features that may be right for some,

but not others, do it by promoting education within the workforce.

  

  

Ryan Boutwell, CEBS

Retirement Plan Consultant

Associated Financial Group 

Employee Benefits. Insurance. HR Solutions. 

Phone (952) 945-0200 

Cell (612) 702-0917 

Fax (952) 945-9477 

Securities offered through

LPL Financial Services

Member FINRA/SIPC

http://www.associatedfinancialgroup.com

  

  

*********************** NOTICE*********************** 

This e-mail and attachment(s) may contain information that is 

privileged, confidential, and/or exempt from disclosure under 

applicable law. If the reader of this message is not the intended 

recipient, you are hereby notified that any dissemination, 

distribution, or copy of this message is strictly prohibited. If 
received in error, please notify the sender immediately and 

delete/destroy the message and any copies thereof. Although 

Associated Financial Group and/or its affiliates attempt to prevent 

the passage of viruses via e-mail and attachments thereto, Associated 

does not guarantee that either are virus-free, and accepts no 

liability for any damage sustained as a result of any such viruses. 

Any federal tax advice contained in this communication (including 

any attachments) is not intended or written to be used or referred 

to in the promoting, marketing, or recommending of any entity, 

investment plan or agreement, nor is such advice intended or written 

to be used, and cannot be used, by a taxpayer for the purpose of 

avoiding penalties under the Internal Revenue Tax Code.