This statement is presented on behalf of the Savings Coalition of America -- a broad-based group of parties interested in increasing personal savings in the United States. The 75 member organizations of the Savings Coalition represent a wide variety of private sector organizations including consumer, education and business groups; senior citizen groups; home builders and realtors; health care providers; engineering organizations; and trust companies, banks, insurance companies, securities firms, and other financial institutions. A list of the members of the Savings Coalition is attached.

On behalf of Merrill Lynch and all of the other members of the Savings Coalition of America, let me begin by commending the Finance Committee for holding this hearing today. Savings, and particularly retirement savings, is the key to America’s long-term economic prosperity.

With Americans saving less than at any time since World War II, we stand at a crossroads. For individuals (including especially the baby boom generation), inadequate savings today will lead to a retirement crisis in the next century. If Americans do not begin saving more for retirement soon, the pressures on the Social Security system that are caused by the aging of our population will be compounded. With Americans living longer, millions of Americans will face prolonged retirements without the financial wherewithal to meet day-to-day needs. Moreover, if low savings rates continue at the national level, they will, over time, lead to higher interest rates and slower economic growth -- further increasing the difficulty of dealing with the problems raised by the changing demographics of our population. For these and many other reasons, doing something now to enhance retirement savings is critical.

Traditionally, retirement security for Americans has been based on the so-called "three-legged stool" -- Social Security, employer-sponsored retirement plans and personal savings. Dealing with our nation’s ongoing savings shortfall effectively will require that each of those legs be strengthened. In particular, Congress should not ignore the critical personal savings leg of the three-legged stool and the Individual Retirement Account, or IRA, has proven over the last 25 years to be the most effective method for focusing personal savings.

The members of the Savings Coalition ask the members of this Committee to enact the provisions of S. 646 -- the Retirement Savings Opportunity Act of 1999, introduced by Senators Roth and Baucus. Among other important changes, that legislation would substantially expand personal savings by increasing the maximum permitted IRA contribution from $2,000 to $5,000, eliminating the complex and counterproductive income limits on IRA participation, and allowing additional catch-up contributions to IRAs for those approaching retirement.

IRAs and Roth IRAs Work

Before going into the provisions of S. 646 in more detail, let me congratulate the members of this committee, and in particular Chairman Roth and Senator Breaux, for beginning the process of bringing the Individual Retirement Account "out of retirement" in 1997. Our experience at Merrill Lynch indicates that the new Roth IRA could well be the most effective new savings generator since the successful expansion of section 401(k) plans in the 80s and early 90s.

One need go no further than the advertisements in the newspapers and other media to see that the Roth IRA changes that Congress enacted in 1997 have revitalized America’s interest in the IRA. With expanded advertising, more and more people have begun asking questions about the new savings options available to them. In the process, they are becoming better educated about the importance of saving for retirement. For many, there has been a growing awareness of how far behind they are in saving for a financially secure retirement.

Although it is still early, our Financial Consultants tell us that many of our customers are responding to the pro-savings message that the Roth IRA sends. Significantly, they are increasing their savings not only through Roth IRAs, but also through traditional IRAs and other savings vehicles.

As with any new financial product, consumer interest builds over time. But under almost any reasonable measure, the Roth IRA has been a tremendous success. Industry-wide statistics are not yet available for 1998, the first year that the Taxpayer Relief Act of 1997 IRA changes went into effect, but preliminary results at Merrill Lynch show an unprecedented increase in IRA activity. Through December 1998, we have seen an increase of more than 80 percent in the number of total IRA contributions over the same period in 1997 -- an astounding increase for a new savings vehicle. This includes new Roth IRAs and increased contributions to traditional IRAs. And we can expect contributions for 1999 and beyond to increase even more as consumer awareness grows, just as IRA contributions grew steadily between 1982 (the first year IRAs became universally available) and 1986 (when IRA access was severely restricted).

One interesting aspect of the Roth IRA expansion is that we have seen considerable spillover savings resulting from the Roth IRA advertising. For example, we have experienced a sizable increase in traditional deductible IRA contributions. To some extent that increase is attributable to the changes that were enacted in 1997 expanding the availability of deductible IRAs. However, we have seen people who were always eligible for deductible IRAs come back because they did not realize they were eligible in the past. They have called to ask about the Roth IRA, but have decided to contribute to a traditional IRA or another savings vehicle. The Roth IRA legislation deserves the credit for putting those people back in the savings habit.

To illustrate how big a success the Roth IRA and other 1997 Act IRA changes have been, one need only compare the early stages of today’s developing IRA market with the early stages of other new savings vehicles created by Congress -- including earlier versions of the IRA. Once again, we won’t have complete statistics for quite some time, but when you compare the IRA activity we have seen in 1998 with our early experience with other products, the success of the 1997 IRA changes becomes clear.

In calendar year 1998, Merrill Lynch established more than two and one half times more new IRAs than we established during the same period in 1982, the first year of universal IRA eligibility. This despite the fact that the IRA available in 1982 was simpler, available on a fully-deductible basis to most Americans, and more tax-advantaged (due to higher marginal income tax rates that were in effect in 1982). Additionally, with the ongoing popularity of the 401(k) plan, the Roth IRA has succeeded in the face of a variety of other alternative choice’s. Similarly, the new Roth IRA has been extremely well received when compared with other recently introduced tax vehicles. In 1998, for example, Merrill Lynch established one hundred times more Roth IRAs than Medical Savings Accounts.

These recent developments, confirm what we already knew from earlier experience, the IRA works at increasing individual savings. The IRA has proven time and again to be the single most effective vehicle for encouraging personal retirement savings by Americans.

Despite the initial success of the changes enacted in 1997, there is no question that current savings incentives will not be sufficient to reverse America’s serious savings shortfall. The 1997 Act IRA changes were important steps in beginning the process of improving the incentives to save. But more change is needed.

Since the 1970s the U.S. personal savings rate has declined steadily. During the 1960s and 70s, our national savings rate averaged around 8% per year. In the last half of the 80s, it dropped to about 5.5% and in the 90s it has dropped to a 3.6% annual average. Last year, the savings rate was an anemic ½ of 1 percent, the lowest level since the Great Depression of the 1930s.

It is the baby boom generation that is in the most danger. Research by Stanford University economist Douglas Bernheim, who compiles an annual Baby Boom Retirement Index for Merrill Lynch, has consistently shown that the baby boom generation has fallen as much as two-thirds behind the rate of savings that they need to maintain their current standard of living in retirement. It is our responsibility to help the baby boom generation (and future generations) to start saving more. If we do not accomplish that goal soon, the financial burden that will be placed on our Social Security system, our economy, and ultimately our children and grandchildren, in the next millennium could be disastrous.

While there are many causes for our national savings shortfall, one of the main reasons is that our tax system continues to penalize savings and investment. What became known as the Roth IRA was an innovative step to correct that imbalance. The additional proposals made in S. 646, are the next logical steps toward providing every American with a meaningful opportunity to save for a secure retirement.

Let me highlight a few of the changes proposed in the S. 646 that we believe would have the most beneficial impact.

Why 2K?

The current $2,000 maximum IRA contribution has been in place since 1981. S. 646 would increase the maximum IRA contribution to $5,000 for both Roth and traditional IRAs (and would index that limit for future inflation). That change is long overdue -- almost 20 years overdue. The limit on IRA contributions has been stuck at $2,000 since 1981. If the IRA contribution limit had been adjusted for inflation since IRAs were created in 1974, Americans could now contribute about $5,000 per year to an IRA. Of all retirement savings plans, only the IRA limit has never been indexed for inflation.

As things stand today, the maximum IRA contribution is not adequate to meet the growing retirement needs of Americans. Future retirees can look forward to longer life expectancies and more years in retirement. When combined with continuing inflation in medical costs (which are especially important for those in retirement) and the long range financial challenges facing the Social Security Trust Fund, it becomes clear that the need for a significant personal savings component in retirement is becoming even more critical than it was in the past. A two-legged, stool consisting of Social Security and employment-based retirement plans, cannot be expected to meet the increasing need. Also, for many of the more than 50 million workers who are not covered by an employment-based retirement plan, IRAs may be the only retirement savings opportunity.

Interestingly, we have found that more than 90% of our customers contributing to an IRA fund it at the annual $2,000 maximum. They save the maximum amount permitted and commit that amount to long-term retirement savings. With higher contribution limits, we fully expect that many of those individuals will save more.

Even for those who do not contribute the maximum in every year, the higher contribution limit will allow flexibility to make IRA contributions in the years that they have the resources to make the contributions. For example, a family where one spouse remains at home to care for children will often not have disposable income for large IRA contributions. When the children are older, however, the couple may be better able to make IRA contributions. The higher contribution limit will allow that couple to make larger IRA contributions during the years they can afford to do so.

Let me also note that in the course of our experience with millions of IRAs we have found that there is a very strong correlation between the size of an account and the attention and discipline that an individual affords to that account. Put simply, once an account achieves a certain "critical mass," it becomes the individual’s nest egg and they become much more disciplined with respect to that account balance. They become less likely to make withdrawals and more likely to continue adding to the account. Conversely, relatively small accounts have a tendency to go dormant after only one contribution and are more likely to be withdrawn. Of course, every person’s "critical mass" is different, but by raising the maximum initial IRA contribution, the chances that more people will start down the savings path (and stick to it) will be increased substantially.

Today, eligibility for traditional deductible IRAs, Roth IRAs and spousal IRAs can be determined only after the taxpayer works through a complex maze of eligibility requirements that include a variety of income limitations and phase-outs. Which of the various eligibility limits applies depends, in part, on the type of IRA the individual wishes to establish and whether the individual (or the individual’s spouse) actively participates in certain types of employment-based retirement plans.

The current IRA eligibility limitations (which were initially included in the Tax Reform Act of 1986) are unnecessarily complex and counterproductive -- doing far more harm than good. Those limitations substantially impair the potential effectiveness of IRAs as a savings promoter and should be repealed as proposed in S. 646. Without the income limits, we would see increased savings among all income classes and would also eliminate the marriage penalties that are inherent in the structure.

Even with the improvements included in the 1997 Act, many middle income Americans are still not eligible for a fully deductible IRA. For couples with income above $51,000 and individuals with income above $31,000, the fully deductible IRA is generally not an option. Although the Roth IRA was wisely made available to a broader segment of the population, the application of income limits on Roth IRAs remains detrimental.

To begin with, the current income limits impose a severe marriage penalty on certain couples. Take, for example two individuals who will earn $30,000 each this year. If they are unmarried, both are allowed to make fully deductible $2,000 contributions to an IRA. If they marry, however, their IRA deductions will be reduced to $200 each. Under today’s tax rules, that couple faces an increase of $1,250 in their Federal income taxes just for getting married, and $1,000 of that marriage penalty (about 80%) is attributable to the eligibility limits currently imposed on deductible IRAs. S. 646 would eliminate that marriage penalty.

Our experience has also shown that the people who are harmed most by the income limits are not the wealthy. To the truly wealthy, the relatively small IRA tax advantage has little affect on their overall tax burden. The people who are harmed by the income limits are those who are stuck in the middle. These are people who do not necessarily have sophisticated tax planners and accountants giving them advice. They will only proceed in committing their money into an IRA if they are confident that they will not get tripped up by the rules. Some of these people will delay contributions to make sure they will qualify, and then later forget to make the contribution or spend the money before they get around to making a contribution. Others may qualify for a full or partial IRA this year, but still will not contribute because the contribution permitted this year is too small, or because they assume they won’t qualify in the future and they don’t want to start contributing if they are not sure they will be able to continue the process in future years. Still others are confused and believe they may have to withdraw the funds if their income goes up in the future.

The end result of today’s complicated limits on IRA eligibility is that contributions are not made by many of those who are technically eligible (or partially eligible) under the rules in a given year. This same chilling effect has been in effect since Congress originally imposed income limits on deductible IRA eligibility in 1986. Before the 1986 Tax Reform Act, the IRA was available to all Americans with earned income. The year after the income limits on IRAs went into effect, contributions by those who remained eligible dropped by 40%.

In restoring universal IRA eligibility and -- the rule that was in effect before 1986 -- S. 646 would help all Americans to save more. By eliminating the complexity in the current rules, Americans will be presented with a consistent and understandable pro-savings message -- a clear consensus path to follow toward retirement security. That message will be reinforced by the general media, financial press, financial planners, and word-of-mouth. As families gain confidence in the retirement savings vehicles available to them, more and more will commit to the consensus path.

Catch-up Contributions

S. 646 would also allow those age 50 and older to make additional IRA contributions of $2,500 per year. This change could be a critical step in helping people who are closer to retirement to save more. We believe that this type of targeted change could be particularly effective because as people approach retirement age they become more focused on retirement needs. In many cases, individuals forego making an IRA contribution in a particular year because of insufficient income, illness, temporary unemployment, a decision to stay home with children, or pay for their children’s education. Annual contribution limitations prevent these individuals from making-up for lost retirement savings once the cash-flow crisis is over or their income rises.

Women, in particular, are more likely to have left the paid workforce for a period of time to care of children or elderly parents. During those years they were probably not eligible (or did not have the resources) to make retirement savings contributions. Allowing an IRA catch-up would help ensure that a woman’s decision to fulfill family responsibilities does not have to lead to retirement insecurity.

It is also worth noting that many of those in today’s population who are approaching or have reached age 50 did not have IRAs or 401(k) plans available through most of their working careers. They did not have the same opportunities to save that today’s generations have. Instead, due to changes in the structure of the American workplace, they were caught in the transition from a relatively robust system of defined benefit pensions to the self-reliance focus of today's defined contribution landscape. Giving the baby boom generation the chance to catch-up for years they may not have saved adequately is not only fair, it is critical to helping them build a bridge to a financially secure retirement.

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In the end, each American must accept significant responsibility for his or her own retirement security. But the government must help by reducing the tax burden on those who save and by making the choices simple and understandable. With that end in mind, our national retirement savings strategy must include an effective set of incentives that will expand personal savings. And the proven IRA vehicle should be the backbone of that effort.

The IRA changes enacted in the 1997 Act were a significant first step toward an improved set of rules for promoting personal savings. But more remains to be done. Today, with an improved federal budgetary picture, it is time to act on additional proposals, like those included in S. 646, that will directly address America’s impending retirement savings crisis. Enhanced retirement savings incentives are the most effective investments we can make as a nation. Those investments will pay back many times over in increased retirement security for Americans and in a stronger economy. For these reasons we urge the members of this Committee to include proposals that will strengthen the IRA as part of any legislation that is reported this year.