1210-AC38 comment 3667 Nuovalo Ltd. 06012026
Nuovalo Ltd.SupportBusiness
Summary: Nuovalo Ltd, an actuarial consulting and technology provider, supports the inclusion of longevity risk-sharing pools (LRSPs) in defined contribution plans. They argue that LRSPs are a cost-efficient way to provide lifetime income and suggest specific improvements to the rule regarding design flexibility, fairness criteria, and tax treatment.
Re:RIN 1210-AC38 – Fiduciary Duties in Selecting Designated Investment Alternatives
On behalf of Nuovalo, an actuarial consulting and technology provider that specializes in longevity risk-sharing, I thank the Employee Benefits Security Administration for the opportunity to comment on this proposed rule. The rule focuses on two areas: 1) the inclusion of private and other alternative assets in defined contribution (DC) plan portfolios and 2) the use of longevity risk-sharing pools (LRSPs). Our expertise lies in the latter and for this reason we direct our comments primarily to the discussion of LRSPs.
Our comments are provided in the accompanying file attachment.