Both of these agencies (Treasury and DOL) continue to attempt to support this process, using their existing regulatory authority. Though there are a number of things which probably need legislative action in order to really make guaranteed lifetime income readily available, there are still a few things regulators may want to consider doing to help it all along
Continue Reading Suggestions for Regulatory Next Steps to Accommodate DC Annuities
QLAC
BNA’s “First Steps to Modernizing DC Annuitization: QLACs and Revenue Ruling 2012-3”
For those of you who do not subscribe to BNA, BNA published as an "Insight" an article I wrote on QLAC and Rev Rul 2012-3 (yes, my author agreement permits me to post it here, with attribution). Look for Paul Hamburger’s upcoming related article, delving into a number of technical and policy issues they raise…
QLAC and the Fiduciary Standard in the Commercial Pooling of Interest
The Treasury’s issuance of proposed regulations introducing the "Qualified Longevity Annuity Contract" is a substantial step in the efforts to better provide plan participants the ability to use their defined contribution balances to plan for retirement security. One of the QLAC’s most useful effects is that it gives us a "base," a laboratory of sorts…
How DC Annuitization Works; Using the QLAC
I have spent much of my career studying and practicing in the law of annuities as it applies to retirement plans-starting even prior to my long stint with an insurance holding company, when the Master Trust of the Fortune 100 company for which I was in-house ERISA counsel formulated its own synthetic, pooled GIC for…
Treasury and IRS Successfully Lay the Base For Lifetime Income: The “2012-3 Annuity” and The QLAC
Treasury nailed it (or, as our eldest son is fond of saying, they just "friggin’" nailed it).