Letter to DOL on Lifetime Income Interim Final Rule

Office of Regulations and Interpretations
Employee Benefits Security Administration
Room N-5655
U.S. Department of Labor
200 Constitution Avenue, NW
Washington, DC 20210

Ladies and Gentlemen:

The American Bankers Association (ABA) appreciates the opportunity to provide comments to the Department of Labor (Department) on an interim final rule that would require certain information to be provided on pension benefit statements of defined contribution plans as mandated by the recently amended section 105 of the Employee Retirement Income Security Act of 1974 (ERISA). Specifically, the interim final rule would require plan administrators of defined contribution plans to express on the plan’s pension benefit statement at least annually the current account balance of the plan participant or beneficiary (retirement investor) both as (i) a single life annuity income stream, and (ii) a qualified joint and survivor annuity income stream. Both of these dollar amount figures will appear on the pension benefit statement together with a series of disclosures that, among other things, are intended to inform the retirement investor the basis upon which the amounts were determined. The interim final rule is open to public comment, after which the Department intends to issue a finalized regulation (final rule) that would supersede the interim final rule.

We commend the Department for its timely efforts to implement section 203 of the SECURE Act governing lifetime income illustrations. The final rule will assist retirement investors in better understanding how the funds that they currently have saved will translate into a monthly lifetime income stream at retirement. We therefore support the Department’s implementing regulation on lifetime income illustrations, with recommendations for additional modifications as described below that are intended to improve regulatory functionality and achieve compliance certainty.

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