April 21, 2010 

U.S. Dept. of Labor 

Re: RIN 1210-AB33 

The following is my response as a participant to the proposed government confiscation of 

IRA/401-K funds. I am COMPLETELY OPPOSED to what amounts to federal 

government larceny of our private retirement funds. I am entirely capable of managing 

my own portfolio, and I’m much smarter than the government in handling my own 

affairs. The mess that government has made of Social Security tells us all that they have 

zero fiscal responsibility and little to no business handling money whatsoever. You 

people want to take the power and choice away from the individual, when you can’t even 

balance your own budget or live within your own means. 

Here are my responses to your itemized questions. 

1. Obviously the advantage is to ostensibly keep income flowing to the recipient and 

beneficiary with lower risk. However this eliminates the possibility of the investor being 

rewarded in the market for taking risks. So if you want to discourage market investment 

and risk taking, mandating lifetime payments is your ideal. The uneducated think you’re 

doing them a favor. I know better. 

2. Predictably, you fail to list what is probably the biggest factor for many people. That 

is fear that the government will change the rules and in the long run, people will see little 

to nothing of their money. Oh wait, that’s just what you’re proposing to do, isn’t it.... 

3. Not that it’s any of your business, but my portfolio DOES contain a certain percentage 

that’s in an annuity. 

4. Again, not that it’s any of your business but the annuity can be dissolved tomorrow or 

pays out after ten years. 

5. All our employees have the choice to invest in lifetime income. Employer 

contributions go to whatever portfolio structure the employee chooses. It’s called 

freedom. 

6. Not applicable. 

7. Longevity is the main cost of providing lifetime income benefits. 

8. The obvious advantage is that for in-plan programs, the participants are able to 

capitalize on investments related to the private sector as opposed to being at the mercy of 

the fickle and untrustworthy government. (Reference answer #2.) 

9. For us there are neither advantages nor disadvantages. The product is there for 

employees to avail themselves to, if they choose. 

10. “Presenting or framing”.....what a prime example of government subterfuge. Look, 

people aren’t stupid, they can figure out if they want to invest in a lower risk – lower 
U.S. Dept. of Labor 

Re: RIN 1210-AB33 

reward lifetime income plan with its advantages AND disadvantages or not. Leave them

and their money alone!

11. I do not need to have my behavior “mitigated”. You people sound like used car 

salesmen or carnival barkers, I’m not sure which. I am certain of two things. Number 

one, if you have a dress up a program in order to sell it, it probably stinks to begin with. 

And number two, the government is not to be trusted. 

 

12. They should determine their level of participation (if any) based on their OWN 

INDIVIDUAL NEEDS, DESIRES AND OBJECTIVES. 

13. No. And No. Government regulation almost always oppresses freedom and 

initiative. There are few advantages to government requirement and regulation, 

particularly not in this instance of proposed retirement savings confiscation. 

14. We have no impediments. We let the employees decide what’s best for them. You 

should too. 

15. Obviously the disadvantage is that certain co-mingled products may not be desired or 

valued by some participants who’d end up paying for them anyway. Are you being 

purposely obtuse in asking this question? 

16. “Demographic groups”, eh? You mean old vs. young? Black vs. white? Have you 

run this past the NAACP, NOW or AARP? Where have you put your political 

correctness?? Sounds like discrimination to me.... 

Leave it the same. 

17. Prospective participants need to know risk-rewards, length of annuity, any early 

withdrawal penalties, how much they might be losing over time from not being in higher 

risk-reward plans, administrative fees and ESPECIALLY viability and character of 

the program provider. For instance, the federal government has a long history of 

reneging on its commitments, shows poor fiscal judgment and often shifts blame to the 

private sector in order to absolve itself of any of the responsibility of the resultant 

financial crisis due to the abject failure of its own poor policies and regulations. I would 

never buy a product from them. 

Plan details as outlined above should be offered annually, explained by either the HR 

Dept or portfolio manager. 

18. No, as I’ve said before, people are smart enough to figure this out. Government does 

not need to mandate that business spend a certain amount on explaining benefits. After 

all, the government itself doesn’t explain itself to the public, at least not convincingly. 

19. Stop trying to infantilize the public. I have no legal concerns because our employees 

understand that nothing is certain and there are risks with all investment, INCLUDING 

lifetime benefit plans. 
U.S. Dept. of Labor 

Re: RIN 1210-AB33 

20. There should be no regulations or mandated offering of these products. Stop being 

communists. If people don’t like the benefits in a particular plan, they are free to seek 

employment elsewhere. 

21. If you are suggesting that the benefit statement shows a hypothetical lifetime income 

stream, then NO! The cost to business for that is unnecessary and you are once again 

trying to not-so-subtly foist a decision on people about a product they may or may not 

want. That is NOT your job. 

22. Skipped, because I said no on 21. 

23. Skipped because I said no on 21. 

24. Again no. Even your own question admits that the ratio would be based on 

assumptions and hypothesis. Obviously the costs to business of incorporating all this 

additional projection and information on the benefits statement are of no concern to you. 

But they should be. I know you don’t like it, but government cannot exist without 

business. You might want to reflect on that. 

25. This is left up to the individual’s decision. And no, government should stay out of it. 

26. Absolutely NOT. 

27. No further guidance is needed. 

28. No rule changes are necessary. 

29. Overall, I believe that people should make their decisions and live with them. And I 

do not believe government should change the rules in the middle of the plan Would you 

allow the participant the option to roll their previous lump sum payout back into their 

former employers overall 401-K/IRA plan as well? If yes, then that could possibly be 

looked at because thatt allows maximum choices and freedom of decision to the 

participant as long as the employer is not expected to incur any costs whatsoever related 

to the initiation or maintenance of this action. If your answer is no, then I’d believe it to 

be a bad idea as the government is then simply trying to push it’s lifetime product agenda 

again. 

30 to 37. I am not knowledgeable about fiduciaries usage of the government’s 

regulation in selecting annuity providers. I am not able to answer these questions. 

38. Well, this is what you are banking on, now isn’t it? That low earners and low 

contributors will see your government retirement account as “safe” and “reliable”. When 

doing business with you is anything but that. 

39. 50% elected to annuity at least some of their retirement assets. 

I will watch with interest as to whether this actually gets posted at the website. 
U.S. Dept. of Labor 

Re: RIN 1210-AB33 

Daryl Price 

US Citizen