In Lifetime Income, ERISA’s statute of limitations may serve to provide the basis for a workable standard when dealing with the long term financial risk posed to fiduciary by insurer insolvency following the purchase of an annuity.
Continue Reading Lifetime Income: Using the Statute Of Limitations to Minimize Insurer Insolvency Risk
We have been extensively researching, writing on and developing the concept of providing lifetime income from defined contribution plans for some 15 years. The work has resulted in a patent; several major independantly published research papers; the outlining of some of the important concepts which underline the proposed QLAC regs and its key revenue ruling; and the development of more than one retirement product. If you look closely, you’ll see that that many of the major whitepapers published on lifetime income are well based on this extensive work we have published. Some of the work really is groundbreaking; for example, we propose a useful fiduciary process which can be used by fiduciaries in the purchase of annuities, in our NYU paper.
This blog has carried much of that material for the past 5 years, since February, 2009. We’ve now compiled those pieces here for use by employers, vendors, actuaries, advisers and attorneys who may be struggling to support lifetime income in defined contribution plans.Continue Reading A Useful Compendium of Lifetime Income Guidance for Defined Contribution Plans
A more complete and up to date description of how lifetime income can work in a DC plan is in order. Evan Giller (newly Of Counsel with Boutwell and Faye) and I put together the attached piece entitled “Regulatory and Fiduciary Framework for Providing Lifetime Income from Defined Contribution Plans.” It is originally appearing in the New York University Review of Employee Benefits and Executive Compensation – 2013. Published by LexisNexis Matthew Bender. Copyright 2013 New York University.” In the paper, we’ve drawn upon our long experience with retirement plan annuities, mixing it well with all of these new developments.
Continue Reading A Regulatory and Fiduciary Framework for Providing Lifetime Income from Defined Contribution Plans
The seemingly obscure issue of when a payment from an annuity contract purchased under a Defined Contribution plan is considered to be a "payment from an annuity" is actually one of the most pressing tax issues that needs to be resolved in the area of DC annuitization. Resolution of this issue determines when spousal consent
BNA’s Tax Management Advisory Board published memorandum as an “Advisory Board Analysis” last week, “Income Guarantees in Defined Contribution Plans.” It speaks in some detail of the technical issues confronting the provisions of annuities through a defined contribution plan.
Continue Reading BNA’s “Insurance Guarantees In Defined Contribution Plans” Published
EBSA and the IRS issued their long promised Request For Information on annuities-or, should I say, as promised by the EBSA. We had not expected this particular piece to be a joint effort. It shows that Phyllis’s and Mark’s agenda is getting policy effectively done, not engaging in damning bureaucratic turf warfare. Hmm. With this
Annuitization from DC plans suffers from the lack of clarity on a number of key technical rules, which need to be resolved before such annuities can be widely implemented. The IRS has taken a major step in its issuance of PLR200951039, a complex PLR which- for the first time-defines what an annuity really is