Teacher Seeks Reconsideration of Proposed Retirement Annuity Regs

It has come to my attention that the Internal Revenue Service intends to eliminate Revenue Rule 90-24 as a part of sweeping changes to 403(b) plans in January 2008. Eliminating Revenue Rule 90-24 will cause significant financial duress to employees with 403(b) plans.

I am an educator in a K-12 public school district in NJ. Like many public school districts, my employer does not have a fiduciary requirement for 403(b) investment choices. As a result, the only options for 403(b) investment are high-fee products like load mutual funds or variable annuities. There are no low-cost or low-fee investment options. The only way that I am able to invest 403(b) monies in low-cost and low-fee financial products is by utilizing a 90-24 transfer.

Eliminating the 90-24 rule will handcuff employees to high cost retirement investments. This is an unacceptable financial burden to bear. Many already rely on the flexibility that the 90-24 transfer allows. As the government seeks to transform us into the "ownership society" it is imperative that no unfair restrictions be placed on retirement monies in 403(b) accounts. By eliminating the 90-24 rule the government condones high-fee financial institutions.

I urge you to strongly consider the negative ramifications and unintended consequences that eliminating the 90-24 transfer will have on employees with 403(b) accounts.