RESPONSE OF:

ALLIANZ LIFE INSURANCE COMPANY OF NORTH AMERICA

AND

ALLIANZ LIFE INSURANCE COMPANY OF NEW YORK

TO:

DEPARTMENT OF THE TREASURY

AND

DEPARTMENT OF LABOR

INFORMATION REGARDING

LIFETIME INCOME OPTIONS FOR PARTICIPANTS

AND BENEFICIARIES IN RETIREMENT PLANS

DATED:  SEPTEMBER 9, 2010

    
 

INTRODUCTION

Allianz Life Insurance Company of North America, established in 1896, and its New York‐based

affiliate, Allianz Life Insurance Company of New York (collectively, “Allianz”) submit for

consideration by the Department of The Treasury and the Department of Labor (the

“Agencies”) its response to the August 6, 2010, Response to Certain Issues Relating to Lifetime

Income Options for Participants and Beneficiaries in Retirement Plans (“Response to Certain

Issues”).

Allianz thanks the Agencies for their inquiry into this important issue. Hard‐working U.S.

employees nearing retirement require education and options to ensure a secure future.

Defined contribution participants should have open and informed access to financial products

that protect against market volatility and longevity risk – both during accumulation of their

retirement funds and during distribution (“income”) from those funds.

Allianz believes that plan participants (a) need access to education and guidance on retirement

planning; (b) need the ability to purchase secure retirement products with principal guarantees;

and (c) need to be able to easily convert a portion of their accumulated retirement assets into

guaranteed lifetime income.

Allianz encourages defined contribution plans to make enhanced educational materials

available. These materials should educate consumers about the value of properly designed

lifetime income solutions during the accumulation and income phases. Plan sponsors should

also be encouraged to provide face‐to‐face guidance from a variety of financial professionals.

We recommend permitting and encouraging in‐plan and out‐of‐plan solutions, which will

require reconciling complex tax laws and incentives. Allianz recommends avoiding a generic

default option, and further recommends that the educational requirement include both in‐plan

and out‐of‐plan (“roll over”) solutions.

In a recently conducted consumer study*, Allianz learned that Americans aged 44‐75 believe

there is a retirement crisis (92 percent) in the United States.  Although 61 percent fear outliving

their money more than death, nearly one‐third (31 percent) say they are not clear about what

their expenses will be in retirement, and 36 percent have no idea if their income will last. When

asked how much yearly income is needed in retirement, respondents indicated a median

income of $59,000 per year. Unfortunately, respondents were off by a factor of nearly three

times when estimating how much they’d need to save to create that household income.

* Larson Research and Strategy Consulting, Inc. and DSS Research fielded a nationwide online survey for Allianz

among 3,257 U.S. adults, age 44 to 75. The margin of error for the total sample was approximately +/‐ 1.7%. The

online survey was conducted in the United States between May 6th, 2010 and May 12th, 2010.  In addition to a

representative sample of 1,642 US households, sub‐samples of more affluent households and households who

own annuities were also targeted.  Results were weighted by age, gender, education, race/ethnicity and income

to account for disproportionate sampling of certain populations.   

                                 

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Allianz is uniquely positioned to provide insight with respect to lifetime income options and to

respond to the Response to Certain Issues because of its more than 20‐year history of

developing innovative annuity products that encourage individuals to receive guaranteed

lifetime income rather than lump sum payments. Allianz currently insures more than one

million annuity contract holders and manages account values in excess of $72 billion.   

 

Allianz Life provides life insurance, and fixed and variable annuities in the United States as a

subsidiary of Munich‐based Allianz SE, a global financial services group, which employs nearly

155,000 people worldwide with approximately 75 million customers in 70 countries and €926

billion of third‐party assets under management (as of December 31, 2009). Other North

American affiliates of Allianz SE include the property and casualty insurance company Fireman’s

Fund, and Allianz Global Investors, a network of mutual fund, hedge fund, and asset

management companies that includes the subsidiaries PIMCO, Nicholas‐Applegate Capital

Management and Oppenheimer Capital.

                                 

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1. Certain specific participant concerns affecting the choice of lifetime income

relative to other options (e.g. long‐term viability of product providers, inflation

risk, fees, complexity and lack of death benefits and withdrawal options)

Insurers are regulated and rated to assure financial strength and solvency  

Life insurers are among the most highly regulated and rated entities in the financial services

industry. As consumers contemplate their financial options, they need to be assured by

regulators that the industry generally has a long track record of financial strength and stability.

As an example, Allianz Life and parent company Allianz SE have received some of the highest

financial strength ratings available from Standard & Poor’s, A.M. Best and Moody’s. Below are

current ratings:

• Standard & Poors – Allianz Life – AA (very strong); Allianz SE – AA (very strong)

• A.M. Best – Allianz Life – A (excellent); Allianz SE – A+ (superior)

• Moody’s – Allianz Life – A2 (Good); Allianz SE – Aa3 (Excellent)

These independent agencies conduct an annual analysis of financial results and evaluate

management objectives and strategies. They review capital adequacy, product diversification

and numerous other factors bearing on the long‐term strength of the company.  Moreover,

Allianz Life retains the financial backing of one of the largest financial enterprises in the world in

Allianz SE. During both the Great Depression and the economic crisis of 2008‐2009, Allianz Life

met all of its claims‐paying obligations to customers.

Allianz and other firms are innovating and designing products that address inflation risk,

interest rate risk and other market risks  

Allianz offers consumers a number of fixed index, fixed and variable annuities. Our fixed index

and fixed annuity products are designed to help our clients reach their retirement goals. They

offer tax deferral, the opportunity for guaranteed interest or market indexed growth and the

protection of guaranteed lifetime income. Allianz also offers variable annuities that provide a

variety of income and death benefits designed to help meet our clients’ financial goals and

retirement needs. Our variable annuities provide market participation along with benefits that

help provide a level of protection for their investment and their beneficiaries.

Fixed annuities are long‐term products built for protection, during both accumulation and

income distribution phases, which reduces the effect of volatility.  And variable annuities,

through various guaranteed benefit riders, can also offer levels of protection during

accumulation and/or income distribution.  In selecting among these products, purchasers are

inherently making trade‐offs between liquidity and growth potential. 

                                 

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Inflation risk will continue to be a concern that retirees and pre‐retirees must consider in their

retirement planning. Allianz’ Reclaiming the Future study indicated that more than 70 percent

of pre‐retirees consider inflation/tax increases to be extremely important when planning for

retirement. At an inflation rate of 3 percent compounded over 20 years, a level retirement

income is estimated to lose nearly half of its purchasing power. Allianz has a history of

developing products that address these concerns, including our annual payment increase

feature and inflation‐oriented solutions.   

Annuity products are also designed to address other market risks, specifically volatility. In the

case of defined contribution plans, the volatility risk is not fully understood by consumers and

can have a significant effect on the lump sum that a participant has available to convert into a

lifetime income stream. An annuity has the ability to guard against a portion of the volatility risk

inherent in market participation, while still providing opportunity for growth potential.

Essentially, an annuity protects against downside risk while offering upside potential,

something that today’s plan participants need to have as an option for their retirement.

Annuities are becoming increasingly flexible and offer multiple withdrawal options

Annuity products continue to evolve and offer increased flexibility for consumers. Some of the

newer generations of products utilize more of an “a la carte” approach and/or allow consumers

to attach riders with certain benefits, specifically lifetime income riders.  Most annuities allow

the contract owner to withdraw a limited portion of the value of the annuity, such as 10

percent, each year free of any surrender charge. Many annuities also include additional liquidity

options in the event of death, or if the purchaser enters a nursing or assisted living facility.  

Further, modern annuity design has made significant strides in providing for flexible asset

payout streams.  

Because Allianz is the leading provider of fixed index annuities, we will be focusing our

comments on this product solution.

Product design should provide options to consumers – options should not be reduced for

simplicity alone as consumers need the benefits these options provide  

Consumers tell us that they want choices; different benefits are a fit for different individuals

based on a wide variety of personal needs. Individuals currently have access to many different

variations of annuities that provide guaranteed lifetime income. There are those designed to be

used with other investment options outside the annuity itself. There are options designed for

future guaranteed retirement income, allowing consumers to have guaranteed growth in their

income guarantee while they have not started income distribution. Some provide greater

benefits the longer the consumer waits to take income distribution, but do not make deferral

mandatory. This level of choice in annuity products is important because it allows the product

to be flexible to change with the client through their various life stages.

                                 

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Old perceptions and myths linger on annuities

Allianz recently investigated Americans’ perceptions of annuities and found that old views and

myths still linger about the products. The Allianz Reclaiming the Future study, which surveyed

3,200 Americans aged 44‐75 in May 2010, found that 54 percent of people surveyed express

distaste for the word annuity – even after describing an annuity‐like product as their ideal

financial vehicle. Meanwhile, an overwhelming 80 percent preferred a hypothetical product

with four percent return and a guarantee against losing value over a hypothetical product with

an eight percent return and subject to market risk.  These survey results demonstrate the need

for education about annuities and their place in retirement planning.

Much of this bias is based on legacy information that is decades old. Fifty‐three percent first

formed their opinion of annuities 10‐20 or more years ago, and 64 percent of those

respondents haven’t researched annuities since that time. Thus, many myths and

misconceptions continue to plague these products today. In fact, only 27 percent knew of

innovations made with annuities during the past 5‐10 years, and even fewer (23 percent)

realize that variable annuities allow contract holders to participate in market gains.

Our research has shown that when people understand annuities, they’re extremely satisfied

with them. According to the study, 76 percent of annuity owners are “very happy” with their

purchase. More than half of owners like the product because it’s a safe, long‐term investment

vehicle (57 percent), a great way to supplement their retirement income (56 percent), and an

effective tool to get tax‐deferred growth potential (56 percent). In fact, consumers ranked

annuities second‐highest (50 percent) in satisfaction among all financial instruments, beating

out mutual funds at 38 percent, stocks at 36 percent, U.S. savings bonds at 35 percent and CDs

at 25 percent.

This survey also showed that more Americans are now seeking safety and guarantees over

growth. When asked what features they find most important in a financial product, the top

feature was “the ability to create a stable, predictable standard of living throughout

retirement” followed by the “ability to provide a guaranteed income stream for life.” Similarly,

when asked to choose between putting money into an annuity‐like solution (moderate growth

opportunity, monthly income, but limited access to the lump sum) versus a similar instrument

that provides total access but risks running out of money, 56 percent chose the annuity‐like

solution.

These results demonstrate that more education is needed about annuities because perceptions

need to change if consumers are to access guaranteed income and create a more stable

retirement. The 401(k) industry successfully educated consumers about mutual funds to save

for retirement; now government and the industry need the same type of concerted education

effort on annuities and how they can help Americans when they are in retirement.

The industry must do a better job of simplifying product language  

As the Allianz survey results show, consumers are eager to learn more about the benefits that

annuities can provide. By simplifying some of the terminology, regulators and the industry can

                                 

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help to make the products better understood and accepted by mainstream consumers. In

addition, because people’s opinions of annuities were formed 10‐20 years ago, myths about

annuities need to be dispelled and annuity innovations explained to better showcase the ease

with which annuities can help consumers to meet their retirement needs.  

2. Information useful to making choices on spending down retirement  

Various income options provide flexibility to meet consumers’ needs in retirement through

either scheduled payments, payments that last your lifetime or a lump sum. Defined

contribution plans have long held an accumulation‐oriented focus on planning and advice.

Because of this, there has also traditionally been a bias against the very products (annuities)

that can best address longevity and volatility risk, which are two of the most important risks

participants will face in spending down in retirement.  

Traditional defined contribution plan participants have access to an abundance of well‐meaning

but often misguided information about how to plan for income in retirement. These materials

often compare annuities with investment products on the basis of rate of return (growth

potential), and do not sufficiently address the risks associated with longevity or mortality. In

addition, these materials often fail to adequately describe the features and benefits of both in‐

plan and out‐of‐plan annuities.  Inadequate information is one of the root causes for individuals

failing to adequately and appropriately plan for income needs in retirement.

Annuities and lifetime income products are often mistakenly compared to “equity

investments.” This comparison is not appropriate as each serve different purposes. Annuities

are designed to minimize volatility by providing guarantees;1 equity investments are designed

to maximize growth potential and liquidity.  Researchers have, in fact, observed that because

retirement income products such as fixed index annuities “have not been designed to compete

with equity mutual funds or exchange traded funds,” it would be improper to compare one

against the other. 2  

More education is needed for participants to truly understand longevity risk and the tradeoffs

between liquidity, growth and protection. There remains a tension between consumer

objectives of full liquidity (i.e. full control over the account value) and structured product

income guarantees (which typically offer reduced or no control over account value).  

Experience shows that consumers regularly choose liquidity over income, which is often not the

most appropriate choice in their circumstances. Liquidity can be costly both in terms of financial

resources for long periods of time and in unintentionally allowing participants access to funds

 

1 Research published in the fall of 2009 indicates that for the five‐year period from 2003 – 2008, the S&P 500

average return was 3.18%, where representative fixed index annuity return for the same period was 6.05%. This

shows the value of product guarantees and floors in a rapidly declining market. Marrion J., VanderPal G., Babbel

D., Real World Indexed Annuity Returns, Wharton Financial Institutions Center, October 5, 2009.

2 Id.

                                 

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that they may spend down faster than is prudent. Once consumers receive education and then

understand the tradeoffs, the guaranteed income option becomes more attractive.

Allianz recommends participants work with a trusted financial professional in an open format

and not limited to a small number of professionals selected by their employer.   

Individuals should be provided access to many different variations of annuities which provide

lifetime income guarantees.  In the general market, consumers have the opportunity to make

their annuity selection based on the three factors of volatility, liquidity and growth potential.  In

most cases, they have financial professionals who help them to make informed choices about

which annuity is best for their individual circumstances.  Judging by their annuity choices,

consumers have clearly voted in favor of a balance of growth potential with liquidity and a level

of guaranteed income versus a pure income guarantee.  

A small number of defined contribution plans offer annuities, and most have very low election

rates.  Allianz believes this may stem from participants’ lack of understanding of the balance

that must be struck among the three factors of volatility, liquidity and growth potential. It is

likely that, similar to the individual market, the guidance of well‐informed financial

professionals can make the difference.  At the very least, there needs to be education in a

format that helps plan participants understand their own priorities when it comes to providing

for their retirement financial needs. Plan sponsors can play an important role in assisting

participants by not only offering annuity options, but also by giving them access to trusted

financial professionals who can help them make informed choices. It is also important that

sponsors create open formats and not limit the number of professionals to a small number

selected only by the employer. Participants need to have access to professional options that are

appropriate to their own financial circumstances as they seek guidance.

Annuities are not the entire solution but should be a part of a well‐balanced portfolio, giving

participants a baseline of protected assets and guaranteed income.  

To be clear, Allianz does not believe that annuities are the entire solution for participants.

Instead, they should be considered as a part of a well‐balanced portfolio. In many ways, the

annuity offers the baseline of consistent, secure and guaranteed income on which a participant

can rely throughout employment and then retirement. It may be completely appropriate for

participants, based on the advice of a trusted financial professional, to continue to hold a

portion of their assets in stocks, bonds, mutual funds and other investment options in

retirement. However, given the critical nature of retirement planning, and the relative lack of

financial sophistication of many employees, it is essential that participants apply a significant

portion of their retirement money to products with principal and payout guarantees.  

Allianz survey results suggest consumers need and want help

According to the Allianz study Reclaiming the Future referenced above, three‐quarters of

respondents currently work with or are receptive to working with a financial professional. This

suggests that people are eager to take a more active role in their planning to ensure they have

adequate retirement income for the future. Even more encouraging, consumers are now

                                 

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focusing more on protection of their retirement assets rather than purely growth investing

goals such as high rate of return.  

Allianz recommends increasing education on options  

Planning in defined contribution plans often tends to focus primarily on accumulation versus

income strategies. As they plan for retirement, participants need to understand how to build

their defined‐contribution assets, and then efficiently convert a portion of those assets into a

guaranteed stream of lifetime income. To bridge the gap between the accumulation and

guaranteed income phases of retirement planning, participants need effective education about

the risks they will face while employed and when in retirement. They also need products that

are designed to specifically provide longevity risk protection. Annuities should fulfill the core

position in such financial planning approaches. By design, annuities are insurance products that

can guarantee a lifetime stream of retirement income. Annuities are the only product that can

provide this guarantee.

3. Value of lifetime stream of income vs. a lump sum distribution (specific

questions about structure of benefits, how they are depicted on statements,

contribution rates, rates of return, interest rates used for conversion, mortality

rates, actuarial equivalents of an account balance in form of lifetime monthly

benefit, computer models and costs)

A problem for plan sponsors is that the typical participant  is not sufficiently financially

sophisticated to understand the implications of taking a lump sum and then personally

managing the money in a drawdown that may last 20‐30 years. The reason annuities are useful

is that they help provide an income stream that is based on pooled risk (something only life

insurers are able to do) whereas a lump sum simply cannot pool risk. Participants need to be

educated so they can understand what pooling of risk means when investing assets through a

life insurer, which has the ability to protect against loss of principal and provide guaranteed

income for life.

Income streams can be paid to an employee even after incapacitation; lump sum means an

employee’s assets might not be managed after incapacitation  

The Agencies need to consider that representations made during plan enrollment and at

distribution, which may sway a participant’s decision‐making, are only a snapshot at a certain

point in time. As people age, the ability for a consumer to make wise personal financial choices

diminishes. It is often the case that a consumer does not fully appreciate or anticipate their own

future inability to make good choices for themselves (or their spouses) due to physical

incapacitation. Therefore, a choice to take a lump sum payment at the age of 65, with a belief

one can manage his or her money effectively at age 85 or 90, factors into the type of offerings a

plan should provide. Plan sponsors need to understand and anticipate the potential over‐

confidence young retirees may have in their long‐term ability to manage their lump sum. An

annuity‐based solution for a portion of one’s portfolio takes away some of the risk of

mismanagement of assets due to incapacitation.

                                 

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Plan sponsor, trade associations and educational institutions can play a role to support direct‐

to‐consumer education

Plan sponsors have been successful in their education efforts around appropriate accumulation

behaviors inside a defined contribution plan. Their new imperative will be to educate

participants about the importance of lifetime streams of income, longevity risk and the dangers

that incapacitation may have on one’s ability to manage down assets in retirement. Employees

need to have institutions protecting their interests and giving them broad guidance. Plan

sponsors can play a role, with cooperation from financial services trade organizations and

educational institutions, to help plan participants make the best decisions for themselves as

they enter retirement.

4. Fiduciary safe harbor for selection of lifetime income issuer or product

Plan sponsors and professionals to DC plans should have safe harbor provisions extended for

use of annuities both in‐plan and out‐of‐plan. Insurers are highly regulated and well capitalized.

Lifetime income is an important part of retirement planning, and insurers are best suited to

pool risk and provide guaranteed solutions for plan participants. Plan sponsors and

professionals should have the ability to offer – and feel safe about offering – annuity options

because they are the only product that can provide guaranteed income for life.

Education is the best tool to assure participants understand their options and appropriately

dedicate a portion of their savings to annuities as a part of their retirement planning.  Allianz is

prepared to assist regulators, consumers and plan sponsors with determining the best options

to support asset protection and guaranteed income for life for plan participants.

5. Alternative designs of in‐plan and distribution lifetime income options

As mentioned above, annuities should be an option in‐plan and at distribution as a roll‐over

option. At roll‐over, a good plan would set up a variety of annuity options from multiple annuity

issuers so participants have choice. At least two to three annuity issuers are required because

all annuities are not alike.  

Allianz recommends that the Agencies consider adopting rules that encourage defined

contribution plans to make enhanced educational materials available. These materials should

educate consumers about the value of properly designed lifetime income solutions during the

accumulation and distribution phase.  Plan sponsors should also be encouraged to provide face‐

to‐face guidance from a variety of financial professionals.  The rules should permit and

encourage in‐plan and out‐of‐plan solutions. Doing so requires reconciling complex tax laws and

incentive schemes. However, Allianz recommends avoiding a generic annuity option, and we

further recommend that the educational requirement include both in‐plan and out‐ of‐plan

(“roll over”) solutions.

Out‐of‐plan options do not require a plan sponsor to select a single annuity provider, nor do

they limit participants’ choices to the products offered by a single annuity provider. They also

allow individuals to receive individualized education and facilitate the recommendation and

                                 

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selection of an annuity based on the participant's individual financial situation and retirement

income needs. Out‐of‐plan annuities are portable because the benefits stay with the employee

when the employee changes jobs or when plan sponsors move to a different administration

platform. They are, in effect, an open‐architecture selection opportunity for consumers,

allowing individuals to choose the annuity provider and annuity product that meet their needs.

Allianz believes that plan participants need access to education and guidance on retirement

planning and need to be able to easily convert a portion of their accumulated retirement assets

into guaranteed lifetime income.

Conclusion

Employees who have worked hard and have planned for retirement should not be abandoned

at the point of retirement by a financial culture that has chosen to over‐emphasize retirement

accumulation to the virtual exclusion of retirement income planning.  Defined contribution

participants should have open and informed access to financial products that protect against

market volatility and longevity risk – both when they are accumulating their retirement funds

and at any point when they are taking distributions from those funds. Allianz believes it is

critical that participants in defined contribution plans be educated about receiving plan

distributions in the form of an income stream, rather than solely as a lump sum distribution.  

Plan participants should not be in a position where living a long life is undesirable.  

Working with the financial services industry and consumer advocacy groups, the Agencies

should create a mandatory list of financial principles, written in everyday language, to which

every plan participant must have access at all times during their participation in the plan.  This

mandated list should include principles to help the consumer understand how to accumulate as

well as convert their accumulated benefits into some form of guaranteed lifetime income.

Allianz also believes that consumers should have access to a wide variety of annuities in order

to have the opportunity to select an option based on their individual needs. Allianz submits that

the option of selecting an out‐of‐plan annuity provides investors with access to a wider choice

of options and other benefits not currently available with in‐plan options. Therefore, Allianz

submits that the Agencies should avoid making policy decisions that could have the effect of

limiting access to consumer choice among insurance providers and guaranteed lifetime income

solutions or favoring the use of in‐plan options to the detriment of out‐of plan options.

Allianz is prepared to assist regulators, consumers and plan sponsors with determining the best

options to support asset protection and guaranteed income for life for plan participants.

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