Description: The Total Career Benchmark Model, consistent with Retirement 20/20 principles, focuses on reconstructing and maintaining a consistent and reasonable sharing of risks and rewards amongst the four stakeholders: Individuals, Society, Employers and the Markets. Modern technology provides the necessary tools. A series of benchmarks are used for tax limits, target pensions, accrual to date etc. The self adjusting, consistent benchmarks under the TCB Model, means that all stakeholders speak the same language. Individuals and Employers can easily compare what they have to what they need – and more importantly can see how to accrue what is needed. An individual’s ability to tax shelter income over a career is not dependent on the design of any employer pension plan. All funds allocated to an individual remain the individual’s and are not used to subsidize another person – except for the inherent risk sharing of an annuity – by hidden transfers of value.

Description: The article endorses broader use of lifetime income in DC plans. It explains why the use of DB plans will continue to decline. The article points out that plans sponsors will not willingly take on additional ERISA fiduciary exposure. The article endorses three regulatory reforms that would increase the use of lifetime income in DC plans. 1. A robust annuity issuer safe harbor that would free employers from fiduciary exposure for putting an annuity provider on the DC platform. 2. A requirement that a plan offer a lifetime income option to qualify for the 404(c) safe harbor. 3. A revision to 404(c) to allow plan sponsors to allocate part or all of the employer match to lifetime income.

Description: This paper responds to the comments on the Total Career Benchmark Model, consistent with Retirement 20/20 principles, focuses on reconstructing and maintaining a consistent and reasonable sharing of risks and rewards amongst the four stakeholders: Individuals, Society, Employers and the Markets. Modern technology provides the necessary tools. A series of benchmarks are used for tax limits, target pensions, accrual to date etc. The self adjusting, consistent benchmarks under the TCB Model, means that all stakeholders speak the same language. Individuals and Employers can easily compare what they have to what they need – and more importantly can see how to accrue what is needed. An individual’s ability to tax shelter income over a career is not dependent on the design of any employer pension plan. All funds allocated to an individual remain the individual’s and are not used to subsidize another person – except for the inherent risk sharing of an annuity – by hidden transfers of value.