Fellows Chats &  Leadership Conversations

Chris Spence of TIAA and Chris Gaston of Davis & Harman join Surya Kolluri to explore innovative approaches for addressing the retirement income guarantee gap.

Fireside Chat: Bridging the Guaranteed Income Gap

Moderator: Surya Kolluri, Head of the TIAA Institute in conversation with Chris Spence of TIAA and Chris Gaston of Davis Harmon

Surya Kolluri: Hello, everyone. I'm Surya Kolluri from the TIAA Institute, and I'm delighted to moderate today's conversation on what we call the "guarantee gap”, a critical challenge facing America's retirement system. Joining me are two distinguished guests: Chris Spence from TIAA Government Relations, and Chris Gaston from Davis Harmon, who together deep expertise in retirement services and income solutions, and both have been instrumental in navigating the regulatory landscape around retirement security

Let me set the stage with a sobering statistic: 45% of American households are projected to run short of money in retirement. Even more striking, 64% of Americans worry more about running out of money than their own mortality. Chris Spence, let's start with you. When we talk about the "guarantee gap," what exactly are we describing?

Chris Spence (TIAA): Thank you, Surya. The guarantee gap is really quite straightforward, yet profoundly important. While defined contribution plans like 401(k)s have done an admirable job helping Americans save for retirement, we feel they've fallen short in the next critical step, converting those accumulated savings into guaranteed income designed to last throughout retirement. Think about it: you spend 30 or 40 years building a nest egg, and then you're suddenly on your own to figure out how to make it last for what could be another 30 years in retirement. That's the gap we're addressing.

Surya Kolluri: The psychological dimension is fascinating. About a third of people who've already retired cite not addressing the risk of outliving their savings as their top financial regret. Chris Gaston, from a legal and regulatory perspective, what's been holding back broader adoption of lifetime income solutions?

Chris Gaston (Davis Harmon): Well, Surya, there are several factors at play. First, we have to acknowledge that Congress has taken important bipartisan steps with the SECURE Act and SECURE 2.0. Chairman Walberg's annuity provider safe harbor legislation was particularly significant. However, plan sponsors still face perceived barriers, regulatory uncertainty, fiduciary concerns, and frankly, some misperceptions about complexity and cost. Many employers sponsoring 401(k) plans hesitate because they're not entirely clear on their obligations and protections when offering these products.

Surya Kolluri: Let's dig into those misperceptions. Chris Spence, what are you hearing from plan participants themselves? What do they actually want?

Chris Spence (TIAA): Recent research from Capital Group found that sixty percent of investors of all ages believe generating steady income is more important than growing assets.1 That's a remarkable finding because it cuts across generations. Participants value security, predictability, and simplicity. They want to know they'll have a monthly or regular check in retirement, just like they did during their working years. Yet here's the troubling reality: less than twenty percent of 401(k) plans offer participants access to lifetime income options.2 And among those that do, some are simply systematic withdrawals that don't actually protect against longevity risk.

Chris Gaston (Davis Harmon): That's a critical distinction, Chris. Not all "income options" are created equal. From a legal standpoint, we need clear definitions and standards for what constitutes true longevity protection versus what's merely a distribution strategy.

Surya Kolluri: Exactly. Which brings us to solutions. As you both know, I recently testified before the House Subcommittee on Health, Employment, Labor, and Pensions with three specific policy proposals. Let's walk through them. The first involves amending the Department of Labor's qualified default investment alternative, or QDIA, regulations. Chris Gaston, can you explain why this matters?

Chris Gaston (Davis Harmon): Certainly. QDIAs are the default investments where participant contributions go if they don't make an active choice. They're incredibly powerful because of participant inertia, most people end up in the default. Currently, we feel the safe harbor regulations don't adequately encourage guaranteed lifetime income products as part of these defaults. The Lifetime Income for Employees Act, bipartisan legislation previously introduced by Chairman Walberg and Congressman Norcross, takes steps toward addressing this. But we also would like the Department of Labor to provide greater clarity to give plan sponsors confidence when integrating lifetime income solutions.

Surya Kolluri: Chris Spence, from the practitioner's side, how would amending QDIA regulations change the landscape?

Chris Spence (TIAA): It could be transformative. When lifetime income becomes part of the default, it normalizes these solutions. Plan sponsors would have a clearer path forward, and participants would naturally accumulate both savings and income protection throughout their careers. It shifts the conversation from "Should I consider an annuity?" to "This is how might retirement work, you save, and that saving could automatically converts to lifetime income."

Surya Kolluri: The second proposal involves requiring defined contribution plans to offer what we call Q-POPs, qualified payout options. Walk us through this concept.

Chris Spence (TIAA): Q-POPs would create a menu of options at retirement, including guaranteed lifetime income solutions, systematic withdrawal approaches, managed payout strategies, or access to an exchange platform offering various approaches. The key word is "menu." We're not mandating that everyone take lifetime income, but we're ensuring that everyone has access to it as a legitimate, fiduciary-approved option.

Chris Gaston (Davis Harmon): From a legal perspective, this addresses one of the fundamental misperceptions among plan sponsors, that offering these options creates liability. By establishing clear standards for what qualifies as a Q-POP and providing safe harbor protections, Congress can reassure employers that they're fulfilling their fiduciary duty, not increasing their risk.

Surya Kolluri: The third proposal is perhaps the most fundamental, improving what we call "longevity literacy." Just so we are all working from a shared understanding. Longevity literacy is simply an understanding of how long an individual is likely to live in retirement. The Institute’s research consistently shows that savers underestimate their life expectancy. They plan for 15 years in retirement when they should be planning for 25 or 30.3 This creates what we call longevity risk, the risk of outliving your savings. If people understood how long they're likely to live, they'd make very different choices about income protection.

Chris Spence, what role can policymakers play in improving longevity literacy?

Chris Spence (TIAA): We have over 30 million Baby Boomers approaching retirement age right now, many of whom can expect to live 30 years or more in retirement. There are several levers available for policymakers. Congress could require more robust lifetime income illustrations in participant statements, showing what their accumulated balance could generate in monthly income. The Department of Labor could mandate educational materials that help people understand longevity risk. We could even look at incentivizing employers to provide retirement planning resources that include longevity projections. The key is making this information accessible and actionable, not buried in disclosure documents that nobody reads.

Surya Kolluri: Let's talk implementation. Chris Gaston, if Congress enacted these three reforms tomorrow, what would the rollout look like from an industry perspective?

Chris Gaston (Davis Harmon): We'd need a thoughtful transition period, certainly. Plan sponsors would need time to evaluate lifetime income providers, update their plan documents, and communicate changes to participants. The Department of Labor would need to issue guidance on the QDIA amendments. But here's the exciting part, the infrastructure largely exists. Providers like TIAA have decades of experience delivering guaranteed lifetime income. The products are tested and proven. We're really just removing barriers and creating clearer pathways.  

Surya Kolluri: Chris Spence – anything to add?

Chris Spence (TIAA): I'd add that we'd likely see some standardization emerge, which would benefit everyone. Just as target-date funds became the dominant QDIA over time, we might see certain structures for lifetime income options become industry standard, making it easier for plan sponsors to compare and select providers.

Surya Kolluri: One question I'm often asked: wouldn't mandating or encouraging lifetime income options reduce flexibility for participants who want to manage their own withdrawals?

Chris Spence (TIAA): That's a common concern, but the Q-POP approach addresses it directly. We're not forcing anyone into lifetime income, we're ensuring it's available alongside other options. Some participants will want complete control and flexibility. Others will value the security of guaranteed income. Many will want a blend, perhaps covering essential expenses with guaranteed income and maintaining some assets for discretionary spending and legacy goals. The menu approach accommodates all of these preferences.

Surya Kolluri: Chris Gaston, are there legal precedents for this kind of mandated menu approach?

Chris Gaston (Davis Harmon): Absolutely. We already see this with investment options in 401(k) plans. ERISA doesn't dictate specific investments, but it does establish standards for fiduciary selection and monitoring. The Q-POP concept follows similar logic, establishing standards for what qualifies as an appropriate payout option while leaving specific selections to plan sponsors and participant choices to individuals.

Surya Kolluri: Let's address the elephant in the room: cost. Critics sometimes argue that guaranteed lifetime income products are expensive or represent poor value compared to DIY withdrawal strategies. Chris Spence, how do you respond?

Chris Spence (TIAA): It's important to distinguish between cost and value. Yes, insurance products have costs, you're paying for longevity protection, professional management, and guaranteed outcomes. But what's the cost of running out of money at age 85? What's the cost of the anxiety that 64% of Americans feel about outliving their savings?4 When you factor in the psychological benefits, the protection against poor market timing at retirement, and the insurance against outliving your assets, many participants find tremendous value in these products. And increased adoption through QDIA integration would likely drive costs down through economies of scale.

Chris Gaston (Davis Harmon): I'd also note that the SECURE Acts included provisions requiring clearer disclosure of fees and features, which helps participants make informed comparisons. Transparency is the best disinfectant for any concerns about cost.

Surya Kolluri: We're living in an era of increasing longevity, yet also increasing economic uncertainty. How do these three reforms position America's retirement system for the next generation?

Chris Spence (TIAA): They fundamentally complete the retirement security framework. Social Security provides a foundation. Defined contribution plans have successfully created a savings culture. These reforms add the third leg of the stool, systematic conversion of savings into lifetime income. Together, they enable Americans to retire with dignity, which should be our ultimate goal.

Chris Gaston (Davis Harmon): From a policy perspective, these reforms also represent a bipartisan opportunity. Chairman Walberg and Congressman Norcross have already demonstrated that lifetime income solutions can attract support across the aisle. These aren't partisan issues; they're about fulfilling the promise of retirement security for all Americans.

Surya Kolluri: As we close, I want to return to that statistic about retirees' top financial regret, not addressing the risk of outliving their savings. Chris Spence, if you could speak directly to someone who's five or ten years from retirement, what would you tell them?

Chris Spence (TIAA): I'd tell them that they have more options than they might realize, and that those options will continue to improve as these policy reforms move forward. I'd encourage them to think about retirement income the same way they think about their regular check during their working years, as something reliable and guaranteed. And I'd urge them to have conversations now with their plan sponsor about lifetime income options, because demand from participants is one of the most powerful drivers of change. 

Surya Kolluri: Chris Gaston, your final thoughts

Chris Gaston (Davis Harmon): We're at an inflection point. The legal and regulatory framework is evolving to support lifetime income solutions. The industry has the products and expertise to deliver them. What we need now is the policy certainty that comes from Congressional action on QDIA reform, Q-POP legislation, and longevity literacy initiatives. These three reforms, working together, can help millions of Americans retire with confidence and security.

Surya Kolluri: Thank you both for this illuminating conversation. The guarantee gap is real, the solutions are within reach, and the time to act is now. With over 30 million Baby Boomers approaching retirement, we have both the urgency and the opportunity to modernize our retirement system and help Americans retire with dignity. We look forward to sharing this conversation with our partners along with the related research. Thank you for joining us today.

This material is for informational or educational purposes only and is not fiduciary investment advice, or a securities, investment strategy, or insurance product recommendation. This material does not consider an individual’s own objectives or circumstances which should be the basis of any investment decision.

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