"With regard to whether investment management services, described in paragraph (e)(4)(iii) of the QDIA regulation, may incorporate lifetime income products and features in compliance with the regulation, it is the view of the Department that such investment alternatives can be QDIAs provided they satisfy the transferability requirements and other provisions of the regulation.... [T]he LIS program would not fail to be a QDIA solely because it is offered through a variable annuity contract with a GLWB component ... [It] is the view of the Department that the LIS program, if operating as [described], would satisfy the requirements to be a QDIA as described in paragraph (e) of the QDIA regulation."  MORE >>