On October 7, the CLHIA wrote to Finance Canada with recommendations to further expand the decumulation options for Canadians beyond what was promised in the 2019 federal budget. In particular, we advocate that insurers should be allowed to pool Variable Payment Life Annuities (VPLAs) across plans rather than requiring pooling to happen within each plan only. This would allow member to offer stand-alone "aggregator" VPLAs to increase scale and cost effectiveness for consumers. As well, we advocate that Canadians should be able to use savings in their TFSAs to purchase deferred annuities. Technical refinements to the VPLA and Advanced Life Deferred Annuity proposals have also been provided to Finance Canada.