The Insured Retirement Institute told the Internal Revenue Service in a letter that it agrees with its proposed regulation regarding longevity annuity contracts because it believes retirement security and annuities and other guaranteed lifetime income products are important. But it does have a few problems with the proposed rule changes.

The IRS and the Department of the Treasury began looking into the possibilities of offering lifetime income products in defined contribution plans at the beginning of 2010. A request for information was submitted to the Federal Register, including questions relating to how the required minimum distribution rules affect defined contribution plan sponsors' and participants' interests in the offering and use of lifetime income.

In particular, it asked whether there were changes to the rules that could or should be considered to encourage arrangements under which participants can purchase deferred annuities that begin at an advanced age.