In May, the Department of Labor’s (DOL’s) Employee Benefits Security Administration (EBSA) issued an advance notice of proposed rulemaking about lifetime income illustrations given to participants in DC plans to provide an opportunity for stakeholders to provide early input into the development of regulations (see “DOL Seeks Comments About Lifetime Income Data”). The notice provided a comment period deadline of July 8; the organizations requested an extension to August 7.
In a letter to the EBSA, the organizations noted that the agencies request includes approximately 27 technical and complex questions, many of which are time consuming to answer. “For example, the Department’s request for comments on the costs (and benefits) of including the illustration described in the Notice and how such costs might be reduced necessarily involves a complex and time consuming analysis. The illustrations under consideration will require software reprogramming and modeling changes. Consequently, the information requested by the Department requires input from information technology professionals and other experts, including internal and potentially outside experts. A comment period of 60 days simply does not present sufficient time to complete such an analysis,” the letter said.
The organizationsalso contended that the differing views of stakeholders they represent and the fact July 8 is the first Monday following the July 4 holiday also complicates efforts to respond to the notice.
The organizations include the American Bankers Association, American Society of Pension Professionals & Actuaries (ASPPA), Defined Contribution Institutional Investment Association (DCIIA), Financial Services Roundtable, the Investment Company institute (ICI), National Association of Insurance and Financial Advisors (NAIFA), Plan Sponsor Council of America (PSCA), Small Business Council of America and The Spark Institute.The letter is here.