comment letter on lifetime income RFI

May 3, 2010 Office of Regulations and Interpretations Employee Benefits Security Administration Room N-5655 U.S. Department of Labor 200 Constitution Avenue, NW Washington, DC 20210 Attention: Lifetime Income RFI Re: Request for Information – Lifetime Income (RIN 1210-AB33) Dear Sir or Madam: The American Benefits Council (Council) appreciates the opportunity to provide information and comment to the Department of Labor (DOL) and Department of Treasury (Treasury) on their Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans (RFI). The Council is a public policy organization representing principally Fortune 500 companies and other organizations that assist employers of all sizes in providing benefits to employees. Collectively, the Council’s members either sponsor directly or provide services to retirement and health plans that cover more than 100 million Americans. First and foremost we would like to thank Treasury and the DOL for initiating this project, which we understand will be the first phase of a new regulatory focus on the distribution phase of retirement planning. The Council agrees that the retirement security of millions of baby boomers and future generations depends not only on their ability to accumulate sufficient assets/resources for retirement but also on how those resources are utilized to provide retirement income. In fact, the Council believes ...