Editors’ Note: To salvage his Middle East legacy, advance American interests in the Arab world, and align with the position of the international community on this conflict, Ibrahim Fraihat argues, President Obama must make the long overdue decision of recognizing a sovereign and independent Palestinian state before leaving office. This post originally appeared on Middle East Eye.

Driven by the search for his legacy in the Middle East, it seems President Barack Obama has decided to spend additional political capital on reviving Israeli-Palestinian talks before the end of his second term in office.

Last month, the Wall Street Journal reported that the White House is working on a renewed peace push, including a possible Security Council resolution or other initiatives such as “a presidential speech and a joint statement from the Middle East Quartet.”

While it is still unclear where President Obama is going with this renewed effort, he must understand that using the same old techniques of U.S. mediation will only exacerbate the crisis, consequently tarnishing his legacy in the Middle East. To salvage his Middle East legacy, advance American interests in the Arab world, and align with the position of the international community on this conflict, he must make the long overdue decision of recognizing a sovereign and independent Palestinian state before leaving office.

[U]sing the same old techniques of U.S. mediation will only exacerbate the crisis, consequently tarnishing [Obama's] legacy in the Middle East.

First, Obama should learn from the mistakes of his predecessors, George W. Bush and Bill Clinton, who also tried to reach a mutually acceptable agreement between the Palestinian and Israelis with only a few months left in office.

Reaching an agreement between the two parties under severe time pressure will not work. A party that is not interested in a peace agreement can easily maneuver by using delaying tactics until Obama’s term ends. Israeli Prime Minister Benjamin Netanyahu already utilized this strategy when he publicly rejected an invitation from Obama to visit the White House to talk peace because he wanted to “avoid any perceived influence” in the forthcoming U.S. presidential election. These remarks came from the same person who meddled in domestic American affairs by aggressively lobbying against Obama during the last U.S. presidential election.

Obama has already put in the effort by working with the parties, but now he needs to make decisions. Unlike many American presidents, Obama made the resolution of this conflict a top priority. Despite the brutal civil wars engulfing the Middle East region in the past five years, Obama demonstrated a firm commitment and allocated the needed political capital to make a breakthrough in the Israeli-Palestinian conflict. During his time in office, Secretary of State John Kerry spent more time on Israeli-Palestinian negotiations than any other international conflict. However, the outcome of the Obama administration’s intensive diplomatic efforts has been a total failure. These negotiations ended without an accord or even a memorandum of understanding, agreements that could have built on Obama’s legacy in the Middle East.

Nonetheless, Obama knows very well who made him fail. Netanyahu repeatedly defied Obama: In Congress, he refused to engage in serious negotiations that could have led to an agreement, and he publicly lobbied against Obama’s election for a second term. Obama should not expect Netanyahu to change his position and cooperate on any renewed efforts that could save Obama’s failed legacy in the Middle East. This is the same Netanyahu whom Obama increasingly grew frustrated with throughout his presidency.

With the remaining few months in office, the time has come for Obama to shape his legacy in the Middle East the way he wants it, not the way that Netanyahu has lobbied to characterize it. Obama has an opportunity to take his place in history as the first American president to officially recognize an independent Palestinian state.

Obama has an opportunity to take his place in history as the first American president to officially recognize an independent Palestinian state.

Sooner or later, there will be a Palestinian state and the United States will recognize it. Obama knows that very well. So why should he miss this opportunity and let another president recognize it in the future? Obama should worry about his own legacy, not Netanyahu’s extremist views. Obama should never allow Netanyahu to shape his legacy in the Middle East and leave it stained with failure.

Obama’s Middle East legacy is equally bleak in other parts of the region. Syria could become Obama’s Rwanda; Benghazi and the late Ambassador Chris Stevens are witnesses to his legacy in Libya; al-Qaeda in Yemen is much stronger today than when Obama intensified his drone policy against the organization; only history will tell how the Iran nuclear deal turns out in the future. Unfortunately, Obama cannot change the facts in any of these countries with the limited time remaining for him in office. However, he can still restore his legacy in the Middle East by recognizing a Palestinian state.

By recognizing a Palestinian state now, Obama will have seized an historical opportunity to impact the future and establish a foundation for the next American administration in the Middle East. No matter who comes to the White House, they will have to deal with this new fact. Obama has the international community on his side in recognizing Palestine. France recently stated that it will recognize an independent Palestinian state if a final effort to bring about peace fails. Additionally, Sweden has officially recognized Palestine.

American diplomats have a tradition of balancing their views after they leave office as they become free from the pressure of the Israel lobby and domestic politics. President Jimmy Carter is a one example of this.

Obama should not fall into this trap. No matter how he adjusts his views after leaving office, he will never save his legacy in the Middle East and the Israeli-Palestinian conflict if he does not recognize a Palestinian state while he still has the power to do so. The time is now and he must act rather than regretting it later.

President Obama, if not for your legacy, at least recognize Palestine for the Nobel Peace Prize that you received in advance. The committee trusted you and awarded you the prize before you achieved any real peace; do not disappoint them. Make sure you earn the prize, Mr. President. If not for your legacy or the prestigious prize, then please do something for your own personal pride and be the one who laughs last, not Benjamin Netanyahu.

Mr. President, recognize Palestine now.

Event Information

Americans — especially low- and middle-income workers — are simply not saving enough for retirement. The current retirement income deficit—the gap between what Americans will need in retirement and what they will actually have—is well over $6 trillion. This gap will be insurmountable without a significant change to current tax policy to help incentivize more Americans to save for their own retirement.

On September 9, the Retirement Security Project at Brookings hosted a briefing in collaboration with the Senate Special Committee on Aging to examine new ways to help Americans save for retirement without increasing government spending. A panel of experts on tax, retirement and budget policy explored ideas to modify the tax incentives for retirement savings.

After the panel, participants took audience questions.

Audio

• Rethinking Incentives to Save for a Secure Retirement

Transcript

• Uncorrected Transcript (.pdf)

Event Materials

• 20110909_retirement_saving_incentives

Americans who use defined contribution retirement savings plans (for example, 401(k) or 403(b) plans) or Individual Retirement Accounts will see their retirement security enhanced by two recently announced regulatory initiatives. The first is a series of Treasury Department/IRS proposed regulations that such individuals to use annuity-like guaranteed lifetime income products. The second is a final Department of Labor rule requiring complete fee disclosure to employers sponsoring retirement saving plans. Together, the two initiatives will give current retirement savers and future retirees more flexibility in structuring their retirement incomes, while making it possible to avoid excessive or hidden fees.

Four Treasury/IRS proposals, which were developed under the leadership of our former RSP colleague Mark Iwry, deal with several of the most pressing issues faced by employers and savers that currently reduce the use of annuities. The first proposal would reduce barriers to giving retiring savers the option of annuitizing part of their account balances. Currently, people need to annuitize either the entire balance or none at all. People are naturally wary of annuitizing the entire amount because it leaves them with little in the way of a cash cushion for emergencies. By choosing to annuitize part of the balance, people can retain a lump sum for emergency or other purposes.

A second proposal would remove a technical impediment to using longevity annuities, an annuity that is typically purchased close to retirement but does not begin to pay benefit until the retiree reaches age 85 or a similar age. Longevity annuities enable retirees to manage their money for a set period of time, secure in the knowledge that the longevity annuity will provide income after that, should they live longer than expected.

The third proposal would allow an individual to begin to partially annuitize their savings well before retirement. Starting to annuitize early by buying small pieces of an annuity over twenty or so years allows the saver to avoid having to make a “once and for all” decision and allows the savers to spread out the interest rate risk over time. This option had been subject to a requirement that the saver get a notarized statement from his or her spouse (if any) concerning whether the annuity covers just the saver or both the saver and his or her spouse. The proposal allows this to be handled by the issuing insurer when payments would begin rather than when purchases begin.

The fourth proposal would apply to relatively rare case where the employer has both a retirement savings plan and a traditional defined benefit pension, and would allow an employee to buy a low-cost annuity through the employer’s DB pension.

These four regulatory changes are positive developments. The changes announced today eliminate unintentional barriers to the use of lifetime income products without dictating how individuals should use them. Some may choose to partially annuitize at retirement, some to use longevity annuities to protect them in later years, and some to begin to buy annuities well before retirement. Whatever the choice, the proposals open up new options to future retirees, and should encourage even more market innovations.

At about the same time, the Department of Labor released final regulations requiring providers to disclose all direct and indirect fees to the employer sponsoring a 401(k) plan. The regulations will add needed transparency on fees that will enable increased competition to produce better results for employers and employees.

Despite removing a required template of charges, the new regulations nevertheless give employers a complete and accurate picture of all charges they have to pay, including indirect fees paid by the provider to others. Currently, many indirect fees are not disclosed even though they may reduce the earnings of participants. Endorsed by industry and consumer groups, the disclosures will enable employers who use this information properly to meet their fiduciary responsibility to choose a responsible fee level. What is even more important, the full disclosure will enable employers to structure their 401(k) plan so that individual savers can get the best returns possible, and not be subject to unreasonable fees.

While much more remains to be done to improve retirement savings plan, the steps taken by the proposed Treasury/IRS regulations and the Department of Labor’s final regulations will help savers to improve retirement security.

The new 2013 budget unveiled by President Obama on Monday again contains the Automatic IRA, which was developed by Brookings' Retirement Security Project in conjunction with The Heritage Foundation. This year's version again includes an important change that will also encourage more employers to offer a 401(k) account to their workers. However, important changes to the Saver's Credit, which had been in previous budgets failed to make it this year.

Nearly half of American workers - an estimated 78 million- currently have no employer-sponsored retirement savings plan. The Automatic IRA is a simple, easy to administer and understand system that is designed to meet the needs of small businesses and their employees. Employers facilitate employee savings without having to sponsor a 401(k)-type plan, make matching contributions or meet complex eligibility rules. Employees are enrolled automatically into an IRA with a simplified system of investment choices and a set automatic savings level. However, they retain complete control over all aspects of the account including how much to save, which investment choice to use, or even to opt out completely. Automatic IRAs also offer savings options for the self-employed, for independent contractors, as well as providing those who are changing jobs the ability to continue their retirement savings.

The new 2013 budget would also double the size of the tax credit that employers receive in return for starting a new 401(k) plan from $500 annually for three years to $1,000 annually for the same period. This increase will ensure that the credit covers more of an employer's costs, and should encourage more employers to offer such a plan. This is a very good move, but the credit could be still further expanded to $1,500 for three years as will be proposed by a new House bill coming from Rep. Richard Neal. As Congress examines the proposal, it will have the opportunity to also expand the smaller credit that would be offered to employers that start an Automatic IRA to ensure that they are fully reimbursed for all expenses connected with starting and operating such an account for their workers.

A disappointing development is the failure to again include proposals to expand and improve the Saver's Credit by making it fully refundable. The Saver's Credit is an incentive for middle-and lower-income taxpayers to save in 401(k)-type accounts or IRAs. Retirement Security Project research found that more than 69 million taxpayers had income that was low enough for them to be eligible for the Saver's Credit in 2007. However, nearly 45 million of these filers actually failed to qualify for the credit because they had no federal tax liability. If the Saver's Credit was made refundable as RSP has proposed and deposited directly into the account as a match for savings, those 45 million taxpayers could have taken advantage of the program and had significantly higher retirement savings.

Event Information

Seven years ago, New Zealand recognized that if its people did not have sufficient assets as they aged, they would either face economic stress in retirement or place pressure on the government for costly additional benefits, and thus the KiwiSaver program was born. Designed to help citizens build retirement security, it guides individuals with limited financial experience while also giving them complete control of their finances. Benefits of this national automatic enrollment retirement savings plan include a $1,000 kick-start, employer contributions, and an annual tax credit. New Zealand Since its inception in July 2007, KiwiSaver has been deemed a great success, with over half of the eligible population as members, and over 70 percent of 18-24 year olds participating. Although membership continues to grow, it is at a slower rate than that seen in previous years.

Could the success of KiwiSaver mean that a similar program – at either the national or state level – might work here? On July 8^th, Diana Crossan, former Retirement Commissioner for New Zealand, will offer her insights into the KiwiSaver program and its impact on New Zealand saving, retirement security, and financial literacy. Ben Harris and David John, deputy directors of the Retirement Security Project at Brookings, will reflect on the role such a program might play in the U.S.

Email international@aarp.org to RSVP » 

Editors’ Note: On March 23, the Working Group on Egypt sent a letter to President Obama urging him to publicly and privately object to Egyptian President Abdel Fattah el-Sissi’s accelerating crackdown on human rights and civil society organizations. Brookings senior fellow and director of the Center for Middle East Policy Tamara Wittes was among the letter’s signers, and she explains her decision to do so. The letter was originally published by the Project on Middle East Democracy (POMED).

Tamara Wittes: In a disordered Middle East, America needs anchors of stability and reliable partners to help it achieve its goals. Both are in sadly short supply. 

For more than thirty years, Egypt was an anchor of stability and a reliable American partner in regional security. From the time Sadat expelled Soviet advisers and broached peace with Israel, ties with Egypt have been a core pillar of American Middle East policy. But, as my colleague Steven Cook presciently noted way back in February 2012, Egypt’s revolution accelerated the launch of what he calls a “long goodbye” between these two formerly indispensable partners. He argued back then that shifting from a “special relationship” to something more transaction would have four concrete benefits for Washington:

First, Washington will no longer be in the unseemly position of providing taxpayer largesse—however small in the grand scheme of things—to a government that resents the United States and clearly does not share its values. Second, it will provide an opportunity for a much-needed change in military-to-military relations in which the United States merely pays for the services it needs like expedited transit through the Suez Canal. Third, it is consistent with this moment of empowerment and dignity for Egyptians many of whom do not want U.S. assistance either because they believe it actually stands in the way of a democratic transition or accept Aboul Naga’s argument along with those who couldn’t care less about U.S. assistance because it doesn’t touch their lives. Finally, it will free up funds for the United States to help others who actually might want Washington’s help, perhaps the Tunisians, Moroccans, or some sub-Saharan African countries would be grateful for development assistance.

Since that blog post went up, Egypt has had three different governments and lost its place as a diplomatic and security leader in the region; while the United States has withdrawn from Iraq and begun to do the same in Afghanistan, while emphasizing burden-sharing in its new fight against ISIS. All of these shifts strengthen the argument for a more distant and transactional U.S.-Egyptian relationship. 

Moreover, since his accession to power (first in a military coup in July 2013 and then in a highly constrained election in 2014), President Abdel Fattah el-Sisi has made decisions that are undermining both Egypt’s domestic stability and key American policy goals in the region. 

• Sisi’s failure to move forward on economic reforms (recommended by leading Egyptian voices, regional supporters, and international donors) has left his country in a spiral of shrinking cash reserves, capital flight and currency devaluation that together threaten the government’s ability to import needed food and medicine and to carry out core government functions. 
• Sisi’s counterterrorism campaign in the Sinai has succeeded in “making the sand jump,” as one regional security official told me, but it seems to have stoked more than tamped down the fire of violent extremism threatening both Egypt and Israel; meanwhile, its alleged military abuses have sparked a Senate request for investigation.
• The intense political polarization and relentless repression of post-coup Egypt are producing other destabilizing effects, which are detailed in the Egypt Working Group’s newest letter to President Obama posted below (I am a member of the Working Group). 

To top it all off, the Egyptian government continues to throw obstacles in the road of U.S.-Egyptian cooperation. Its military resists learning from the hard-won American experience in effective counterinsurgency. Its leadership has resolutely refused to allow core bilateral aid programs, like those supporting higher education, to move forward. And at the same time, the Egyptian government continues to promote conspiracy theories about the United States to its public through media smears and show trials, and now, apparently, to its newly elected parliamentarians. 

It’s long past time for the United States to undertake a strategic review of its approach to the Middle East, one focused on building anchors of stability and sustaining reliable partners in pursuit of American priorities. Egypt, as I told The New York Times, no longer qualifies as either one. That doesn’t mean the two countries can’t continue to work together in those narrow areas where they agree on interests, priorities, and approaches. 

But Secretary of State Kerry’s public embrace last week of Egyptian Foreign Minister Shoukry cannot hide the facts—there is no “back to business” option for the U.S.-Egyptian relationship, and it seems increasingly clear that even direct White House engagement would not shift Egypt’s leadership off of its self-destructive trajectory. Egypt's looming instability demands that the United States take steps now to safeguard itself from reliance on a country we cannot rescue, not least from its own leaders' worst impulses. 

March 23, 2016

Dear Mr. President,

We are writing to urge you to speak directly with Egyptian President Abdel Fattah el-Sissi and to express both publicly and privately your objection to his accelerating crackdown on human rights, including recent moves to prosecute civil society organizations. You were correct to declare in September 2014 that “America’s support for civil society is a matter of national security,” and nowhere is that more true than in Egypt today.

President el-Sissi’s campaign against civil society takes place against the backdrop of unprecedented abuses by Egyptian security forces, including extrajudicial killings, the detention of tens of thousands of political prisoners, the widespread documented use of torture, and the forced disappearances of hundreds of Egyptians. The killing of Italian student Giulio Regeni, whose tortured body appeared on a roadside near Cairo a week after his abduction in late January, has come to international attention, but many Egyptians have shared his fate since President el-Sissi came to power.

On March 24, an Egyptian court will hear a request to freeze the bank accounts and other assets of two internationally-respected human rights defenders, Hossam Bahgat and Gamal Eid, along with members of Eid’s family. Mr. Bahgat and Mr. Eid and other activists may soon be indicted and face trial for illegally accepting foreign funding—a criminal charge that violates their right to free association and could carry a sentence of up to 25 years in prison.

The imminent proceedings are a major step in Egyptian authorities’ campaign to crush the last remnants of Egypt’s independent civil society and human rights community. Egypt’s media has recently reported that dozens of organizations are under criminal investigation, essentially for their peaceful work to monitor abuses and to hold Egypt’s government accountable to its own constitution and international human rights commitments. In recent weeks, Egyptian authorities have ordered the closure of a prominent anti-torture organization, the Nadeem Center; summoned staff from several human rights organizations for interrogation; banned prominent rights activists and advocates from traveling outside Egypt in violation of the Egyptian constitution; and harassed and threatened human rights activists with arrest and violence. The media regularly propagate vitriol against human rights defenders, portraying them as traitors and security threats.

If this crackdown is allowed to reach its conclusion, it will silence an indigenous human rights community that has survived more than 30 years of authoritarian rule, leaving few if any Egyptians free to investigate mounting abuses by the state.

The current attacks on Egypt’s rights advocates are a continuation of the same criminal prosecution of American and German NGO workers in Egypt that began in 2011. That prosecution, driven by senior members of the Egyptian government still in high office today, resulted in the June 2013 criminal convictions, in a deeply flawed trial, of 43 Egyptian and international NGO staff, including 17 American citizens. President el-Sissi, who was the head of military intelligence in 2011 when Egypt’s military government launched the investigation, has refused repeated requests to overturn the convictions.

While the current crackdown is primarily targeting domestic organizations, there are indications that international NGOs may also face increased pressure, including some that currently do not even have offices or staff working in Egypt. On March 20, the newspaper Al Masry Al Youm published the names of more than 150 individuals and civil society organizations reportedly under investigation for receiving foreign funding, including prominent American and European organizations such as the Center for International Private Enterprise, the Solidarity Center, Transparency International, Save the Children, Catholic Relief Services, CARE, AMIDEAST, the National Democratic Institute, and the International Republican Institute.

Mr. President, in your September 2014 Presidential Memorandum on Civil Society, you pledged that the United States government—including you personally—would stand firmly with those in civil society facing pressure or harassment from their governments. While the past five years have been tumultuous and challenging for U.S. policy toward Egypt, this is another defining moment for the United States, a moment that tests your pledge to “stand with civil society.” Secretary Kerry’s March 18 statement of concern was welcome, but further action is urgently needed. Past practice demonstrates that when the United States government speaks clearly, in one voice, and consistently on NGO freedom and human rights in Egypt, the government in Cairo listens.

It is essential that you act to stand up for human rights, freedom of association, and the rights of both Egyptian and international civil society organizations to work together on behalf of common goals. You must make crystal clear to President el-Sissi that continued assaults on civil society, including harassment of U.S. organizations, will make it difficult for the administration to cooperate across a range of issues, including your administration’s efforts to promote American investment in Egypt and to provide financial assistance to the Egyptian government and military. If Egypt’s government continues down a path to destroy its own civil society, American support and assistance will become, in both principled and practical terms, impossible.

Sincerely,

The Working Group on Egypt

Financial advisors offer their clients many advantages, such as setting reasonable savings goals, avoiding fraudulent investments and mistakes like buying high and selling low, and determining the right level of risk for a particular household. However, these same advisors are often incentivized to choose funds that increase their own financial rewards, and the nature and amount of the fees received by advisors may not be transparent to their clients, and small-scale savers may not be able to access affordable advice at all.  What is in the best interest of an individual may not be in the best interest of his or her financial advisor.

To combat this problem, the Department of Labor (DoL) recently proposed a regulation designed to increase consumer protection by treating some investment advisors as fiduciaries under ERISA and the 1986 Internal Revenue Code.  The proposed conflict of interest rule is an important step in the right direction to increasing consumer protections.  It addresses evidence from a February 2015 report by the Council of Economic Advisers suggesting that consumers often receive poor recommendations from their financial advisors and that as a result their investment returns on IRAs are about 1 percentage point lower each year.   Naturally, the proposal is not without its controversies and it has already attracted at least 775 public comments, including one from us .

For us, the DoL’s proposed rule is a significant step in the right direction towards increased consumer protection and retirement security.  It is important to make sure that retirement advisors face the right incentives and place customer interests first.  It is also important make sure savers can access good advice so they can make sound decisions and avoid costly mistakes.  However, some thoughtful revisions are needed to ensure the rule offers a net benefit. 

If the rule causes advisors’ compliance costs to rise, they may abandon clients with small-scale savings, since these clients will no longer be profitable for them.  If these small-scale savers are crowded out of the financial advice market, we might see the retirement savings gap widen.  Therefore we encourage the DoL to consider ways to minimize or manage these costs, perhaps by incentivizing advisors to continue guiding these types of clients.  We also worry that the proposed rule does not adequately clarify the difference between education and advice, and encourage the DoL to close any potential loopholes by standardizing the general educational information that advisors can share without triggering fiduciary responsibility (which DoL is trying to do).  Finally, the proposed rule could encourage some advisors to become excessively risk averse in an overzealous attempt to avoid litigation or other negative consequences.  Extreme risk aversion could decrease market returns for investors and the ‘value-add’ of professional advisors, so we suggest the DoL think carefully about discouraging conflicted advice without also discouraging healthy risk.

The proposed rule addresses an important problem, but in its current form it may open the door to some undesirable or problematic outcomes.  We explore these issues in further detail in our recent paper.

Americans are enjoying longer lifespans than ever before. Living longer affords individuals the opportunity to make more contributions to the world, to spend more time with their loved ones, and to devote more years to their favorite activities – but a longer life, and particularly a longer retirement, is also expensive. The retirement security landscape is evolving as workers, employers, retirees, and financial services companies find their needs shifting. Once, many workers planned to stay with a single employer for most or all of their careers, building up a sizeable pension and looking forward to a comfortable retirement. Today, workers more and more workers will be employed by many different employers.  Additionally, generous defined benefit (DB) retirement plans are less popular than they once were – though they were never truly commonplace – and defined contribution (DC) plans are becoming ever more prevalent.  

Figure 1, below, shows the change from DB to DC that has occurred over the past three decades.

In the past many retirees struggled financially towards the end of their lives, just as they do now, but even so, the changes to the retirement security landscape have been real and marked, and have had a serious impact on workers and retirees alike. DB plans are dwindling, DC plans are on the rise, and as a result individuals must now take a more active role in managing their retirement savings. DC plans incorporate contributions from employees and employers alike, and workers much choose how to invest their nest egg.  When a worker leaves a job for retirement or for a different job he or she will often roll over the money from a 401(k) plan into an Individual Retirement Account (IRA). While having more control over one’s retirement funds might seem on its face to be a net improvement, the reality is that the average American lacks the financial literacy to make sound decisions (SEC 2012).

The Council of Economic Advisers (CEA) expressed concern earlier this year that savers with IRA accounts may receive poor investment advice, particularly in cases where their financial advisors are compensated through fees and commissions. “[The] best recommendation for the saver may not be the best recommendation for the adviser’s bottom line” (CEA 2015). President Obama echoed these concerns in a speech at AARP in February, asking the Department of Labor (DoL) to update its rules for financial advisors to follow when handling IRA accounts (White House 2015). The DoL receives its authority to craft such rules and requirements from the 1974 Employee Retirement Income Security Act (ERISA) (DoL 2015a).

The DoL recently proposed a regulation designed to increase consumer protection by treating some investment advisors as fiduciaries under ERISA and the 1986 Internal Revenue Code (DoL 2015b). The proposed rule has generated heated debate, and some financial advisors have responded with great concern, arguing that it will be difficult or impossible to comply with the rule without raising costs to consumers and/or abandoning smaller accounts that generate little or no profit. Advisors who have traditionally offered only the proprietary products of a single company worry that the business model they have used for many years will no longer be considered to be serving the best interests of clients.

Rather than offering detailed comments on the DoL proposals, this paper will look more broadly at the problem of saving for retirement and the role for professional advice. This is, of course, a well-travelled road with a large literature by academics, institutions and policy-makers, however, it is worthwhile to think about market failures, lack of information and individual incentives and what they imply for the investment advice market.

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