From: Scott Leverenz [mailto:sl@growingmymoney.com] 

Sent: Wednesday, February 17, 2010 8:23 PM 

To: e-ORI@dol.gov. 

Subject: RIN 1210-AB33 

I would like to comment on RIN 1210-AB33, Request for Information Regarding Lifetime Income 

Options for Participants and Beneficiaries in Retirement Plans. 

This will be a short version and to the point. 

I would suggest that the lifetime income options will not work well because: 

1. The guarantees are too complex for most people to understand well. 

 2. People will hear the word “guarantee” and purchase it. It has an extra charge and will be a 

waste of money in most cases. 

 3. Most of these options only allow 5% of the guarantee value out per year. Most people will 

exceed this percentage and reduce if not void the guarantee altogether. 

 

An example: An individual has a guarantee balance of 100,000.00. They are only allowed out 

$5,000.00 per year. They take $10,000.00. The “guarantee” is damaged and they will not 

receive the full guarantee. 

 4. Most people are not well versed on creating a financial plan and will put too much money in 

these guarantees and as per the example in number 3 above, will violate the guarantee and 

never use it. 

 5. People will put too much money in these products and not be well diversified. 

6. They may not be portable if someone moves companies and wants to roll over their 

retirement plan to another company plan or an IRA which offers better types of products. If 

one moved their retirement plan, the guarantee would be lost. Again, paying for something 

and getting nothing for it. 

 7. There is a large variety of lifetime guarantee products available on an individual basis. 

These products are better purchased through a knowledgeable financial planner who can guide 

them so they do not make mistakes. 

In a nutshell: These “guarantees” will be purchased at an extra cost and never used. There is no 

value here. The only people winning here will be the companies that are collecting the fees and 

not offering any benefits. 

 There are many types of products with guarantees available to the public. They are complex 

and need to be understood. It is best that the plan participants of 401-ks continue to have the 

bulk of their money available for a rollover. It really may be best if more people seek out good 

individual financial planners for this type of investment so the guarantees they purchase can 

actually be used. These types products should be balanced with other types of investment 

products and a good financial PLAN should be created. The nature of mass marketing in 

retirement plans simply does not lend itself well to these types of products. 
Best regards, 

Scott T. Leverenz, CRPC* 

The Financial Resource Group 

2nd Floor – Room 201 

3340 Annapolis Lane N, Suite B 

Plymouth, MN 55447 

Phone: (952)-544-3614 

Fax: (763)-231-7891 

 

*Registered Representative. Securities offered through Cambridge Investment Research, Inc., a Broker/Dealer, 

Member FINRA/SIPC. Investment Advisory Services offered through Cambridge Investment Research Advisors, Inc., 

Financial Planning Services offered through Securus Wealth Management, LLC, both Registered Investment Advisors. 

Cambridge, Securus and The Financial Resource Group are not affiliated. MN License 51267 

We cannot accept trade orders through e-mail. Important letters, e-mail or fax messages should be confirmed by 

calling 952-843-0076. This e-mail service may not be monitored every day or after normal business hours.