Annuity Insurers Propose Updates to Lists of Required Modifications

August 12, 2020

Carol Weiser
Benefits Tax Counsel
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Catherine Jones
Acting Director, EP
Internal Revenue Service
999 N. Capitol Street, NE
Washington, DC 20002

Re: Proposed Updates to LRMs for Individual Retirement Annuities Dear Ms. Weiser and Ms. Jones:

We are writing to follow up our recent request on behalf of the Committee of Annuity Insurers (the “Committee”) for the prompt publication of updated Lists of Required Modifications (“LRMs”). Specifically, in our letter regarding the Priority Guidance Plan dated July 22, 2020, the Committee requested updated LRMs for annuity contracts that are issued as traditional, Roth, and SIMPLE IRAs, reflecting amendments that the SECURE Act made to various Code provisions affecting such arrangements.

To that end, we have attached for your consideration drafts of such updated LRMs for traditional and Roth individual retirement annuities. The attached drafts are redlined against the sections of the most recent LRMs (dated 6/2010) for traditional and Roth IRAs addressing annuity contracts. The drafts do not address the sections of the LRMs applicable to individual retirement accounts, although we believe that similar changes to those sections are warranted. The attached drafts also include several comments in the margins to provide background and to help explain the updates we are suggesting. Finally, we have attached a list of the Committee's member companies.

* * * * *

We appreciate your consideration of our suggested updates to the LRMs for traditional and Roth IRAs. We would be happy to discuss with you any aspect of our proposed updates. In that regard, if you have any questions or if we can be of any assistance, please contact either of the undersigned by phone at 202-347-2230 or by e-mail at the addresses indicated below.

Sincerely,

Bryan W. Keene
bwkeene@davis-harman.com

Mark E. Griffin
megriffin@davis-harman.com

Counsel to the Committee of Annuity Insurers
www.annuity-insurers.org
Washington, DC

Attachments:
List of member companies
Proposed Updates to LRMs for Traditional Individual Retirement Annuities
Proposed Updates to LRMs for Roth Individual Retirement Annuities

cc:
William Evans, Treasury Department
Harlan Weller, Treasury Department
Stephen Tackney, IRS

AIG Life & Retirement, Los Angeles, CA
Allianz Life Insurance Company, Minneapolis, MN
Allstate Financial, Northbrook, IL
Ameriprise Financial, Minneapolis, MN
Athene USA, Des Moines, IA
Brighthouse Financial, Inc., Charlotte, NC
Equitable, New York, NY
Fidelity Investments Life Insurance Company, Boston, MA
Genworth Financial, Richmond, VA
Global Atlantic Financial Group, Southborough, MA
Great American Life Insurance Co., Cincinnati, OH
Guardian Insurance & Annuity Co., Inc., New York, NY
Jackson National Life Insurance Company, Lansing, MI
John Hancock Life Insurance Company, Boston, MA
Lincoln Financial Group, Fort Wayne, IN
Massachusetts Mutual Life Insurance Company, Springfield, MA
Metropolitan Life Insurance Company, New York, NY
National Life Group®, Montpelier, VT
Nationwide Life Insurance Companies, Columbus, OH
New York Life Insurance Company, New York, NY
Northwestern Mutual Life Insurance Company, Milwaukee, WI
Ohio National Financial Services, Cincinnati, OH
Pacific Life Insurance Company, Newport Beach, CA
Protective Life Insurance Company, Birmingham, AL
Prudential Insurance Company of America, Newark, NJ
Sammons Financial Group, Chicago, IL
Security Benefit Life Insurance Company, Topeka, KS
Symetra Financial, Bellevue, WA
Talcott Resolution, Windsor, CT
TIAA, New York, NY
The Transamerica companies, Cedar Rapids, IA
USAA Life Insurance Company, San Antonio, TX

The Committee of Annuity Insurers was formed in 1981 to participate in the development of federal policies with respect to annuities. The member companies of the Committee represent more than 80% of the annuity business in the United States.