Comment on FR Doc # 2012-02340

COMMENT REGARDING THE INTERNAL REVENUE SERVICE’S PROPOSED REGULATIONS (REG-115809-11) (February 3, 2012) CONCERNING LONGEVITY ANNUITY CONTRACTS We appreciate this opportunity to comment on the proposed regulations relating to the purchase of longevity annuity contracts under tax-qualified defined contribution plans under the Internal Revenue Code. We believe that your proposed rules demonstrate your responsiveness to suggestions received in connection with your Request for Information on February 2, 2010, regarding lifetime income options for participants and beneficiaries in retirement plans (75 FR 5253) (the RFI). We hope you will receive this comment in the same spirit of willingness to consider alternatives to achieve better retirement outcomes for America’s workers. In the RFI, we note that you did not limit your inquiry to insurance products. Instead, you deliberately cast as wide a net as possible. We respectfully suggest that you modify the proposed regulations in a similar manner, and include other mechanisms and approaches which achieve the same goals, for the reasons stated in the file attached. Additionally, we respectfully request to testify at the public hearing scheduled for June 1, 2012. Sincerely, Wendy Morihisa