Comment on FR Doc # 2012-02340

Internal Revenue Service CC:PA:LPD:PR (Reg-115809-11) Room 5203 P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044 Re: Comments on Longevity Annuity Contract Regulations Ladies and Gentlemen: The ERISA Industry Committee (“ERIC”) is pleased to submit the attached comments on the proposed regulations related to qualifying longevity annuity contracts (“QLACs”). The proposed regulations were published in the Federal Register on February 3, 2012. ERIC is a nonprofit association committed to the advancement of the employee retirement, health, incentive, and welfare benefit plans of America’s largest employers. ERIC’s members provide comprehensive retirement, health care, and other economic security benefits directly to tens of millions of active and retired workers and their families. ERIC has a strong interest in proposals affecting its members’ ability to deliver effective and secure retirement benefits. ERIC appreciates the opportunity to submit these comments. If we can be of further assistance, please let us know. Sincerely, Mark J. Ugoretz President & CEO Kathryn Ricard Senior Vice President, Retirement Policy The ERISA Industry Committee 1400 L Street, N.W., Suite 350 Washington, DC 20005 (202) 789-1400