6 Best Alternatives to Annuities for Income
Patrick McNamara
Your financial future should be in your hands, not locked away in a complex product you don't fully control. While annuities can provide a sense of security, they often require you to surrender a significant amount of flexibility and growth potential. For investors who value transparency and want to stay in the driver's seat, it's worth exploring other paths. There are numerous ways to build a reliable income stream without the restrictive terms of a typical annuity. We will cover the best alternatives to annuities for income, focusing on options that allow you to define your own risk, participate in market gains, and keep your strategy aligned with your life.
Key Takeaways
Look beyond the annuity sales pitch: Annuities often come with high fees, limited access to your money, and capped growth potential, which are significant trade-offs for their promise of security.
Align your investments with your goals: Different alternatives serve different purposes; whether you need principal protection, higher income, or market growth, there is likely a more flexible and transparent option available.
Build your strategy around your personal needs: The right choice depends on your unique financial situation, so evaluating your personal risk tolerance, time horizon, and need for liquidity is the most important step in building an effective income portfolio.
What Are Annuities, and Why Consider Alternatives?
Annuities are a familiar fixture in the retirement planning world, often positioned as a straightforward way to secure a steady income for your later years. While they can provide a sense of security, they aren't a one-size-fits-all solution. For many investors, the high fees, limited flexibility, and capped growth potential are significant trade-offs that prompt a search for better options. In a financial landscape where traditional income sources may fall short, exploring alternatives is not just wise, it's essential for building a resilient portfolio.
Modern strategies, including investments like structured notes, can offer a more dynamic approach. These alternatives are designed to give you more control, allowing you to participate in market gains while still defining your level of risk. Before committing to a long-term contract with an insurance company, it’s important to understand what you might be giving up. Understanding both the purpose and the pitfalls of annuities is the first step toward deciding if they truly align with your financial goals or if a different path would serve you better.
What Is an Annuity?
At its core, an annuity is a contract between you and an insurance company. You make a payment, either as a lump sum or in installments, and in return, the insurer promises to send you regular payments. These payments can start right away (an immediate annuity) or at a future date (a deferred annuity), and can last for a set number of years or for the rest of your life. The primary appeal is creating a predictable income stream, much like a personal pension, which can be a comforting thought for anyone concerned about outliving their savings. However, this guarantee isn't free, and it’s crucial to look beyond the sales pitch to see the full picture.
The Downsides of Annuities
One of the most common criticisms of annuities is their complex and often costly structure. They frequently come with high commissions for the person selling them, along with administrative charges, mortality and expense fees, and steep surrender charges if you need to access your money early. Beyond the fees, there's a significant opportunity cost. The insurance company invests your premium to generate returns, but you only receive a portion of the profits. This means you could miss out on substantial market growth over time. This structure leads some to feel that annuities are sold by playing on an investor's fear of loss, locking them into an inflexible product that may underperform over the long run.
Is an Annuity Alternative Right for You?
Deciding whether to look for an alternative comes down to your personal financial goals and comfort with risk. Annuities do offer one unique feature: the potential for a guaranteed income that you cannot outlive. If that is your single most important objective, an annuity might be a consideration. However, if you value flexibility, want to keep your money accessible, and seek higher growth potential, an alternative is likely a better fit. Ask yourself what you need your money to accomplish. Are you focused on protecting your principal, generating a higher income stream, or growing your capital for the future? Answering these questions will help you determine if the trade-offs of an annuity are worth it for your situation.
What Are the Best Annuity Alternatives for Income?
When you’re planning for a steady income stream, annuities often come up in conversation. They promise reliability, which is certainly appealing. But they aren’t the only option available, and their complexity, fees, and lack of liquidity mean they might not be the best fit for your financial goals. The good news is that a world of alternatives exists, each with its own unique profile of risks, returns, and benefits. Finding the right one is about matching your personal financial situation and comfort with risk to the right investment vehicle.
Exploring these alternatives allows you to build a more flexible and potentially more profitable income strategy. Whether you prioritize the safety of your principal, are looking for higher yields, or need easier access to your cash, there’s likely an option that aligns better with your needs than a one-size-fits-all annuity. Let’s walk through some of the most effective annuity alternatives, from government-backed bonds to more dynamic market-linked products. This will help you see the full landscape of possibilities for generating the income you need.
Structured Notes
If you're looking for a blend of protection and market participation, structured notes are an excellent alternative. Think of them as a hybrid investment. They are debt securities issued by major banks, but their returns are linked to the performance of an underlying asset, like a stock index or a basket of stocks. This design allows you to potentially earn higher returns than you would with traditional fixed-income products.
Many structured notes are designed to provide an enhanced income with protection against market downturns. For example, a note might offer regular coupon payments as long as the underlying asset stays above a certain barrier. This can create a consistent income stream even in flat or moderately declining markets, offering a level of stability that direct stock investments can't match.
Treasury Bonds and TIPS
For investors who place the highest premium on safety, government bonds are a classic choice. Treasury bonds, notes, and bills are backed by the full faith and credit of the U.S. government, making them one of the safest investments you can own. They pay interest at regular intervals, providing a predictable income stream. You’re also guaranteed to get your principal back when the bond matures.
Treasury Inflation-Protected Securities (TIPS) take this a step further by offering protection against inflation. The principal value of a TIPS increases with inflation and decreases with deflation, so your interest payments adjust accordingly. This helps your income and principal maintain their purchasing power over time, a feature that is especially valuable during periods of rising prices. You can purchase these securities directly from the government or through a broker.
Dividend-Paying Stocks
Investing in dividend-paying stocks is a straightforward way to generate income from your portfolio. These are typically well-established companies that distribute a portion of their earnings to shareholders on a regular basis. This can create a reliable stream of cash flow, and you also have the potential for your initial investment to grow if the stock's price appreciates over time.
However, this approach comes with more risk. Unlike the guaranteed payments from a bond, a company’s dividends are not set in stone; they can be cut or eliminated, especially during tough economic times. Furthermore, the value of your shares can fall, meaning you could lose principal. This alternative is best suited for investors who are comfortable with market fluctuations and have a longer time horizon.
Real Estate Investment Trusts (REITs)
Real Estate Investment Trusts (REITs) offer a way to invest in a portfolio of income-producing real estate without having to buy or manage any properties yourself. You can buy shares in a REIT just like you would with a stock, and they trade on major exchanges. By law, REITs are required to pay out at least 90% of their taxable income to shareholders in the form of dividends.
This structure makes REITs a popular choice for income-focused investors. The income is generated from the rent collected on the properties in the REIT’s portfolio, which can include everything from apartment buildings and office towers to shopping centers and warehouses. While REITs offer diversification and high dividend yields, their performance is tied to the health of the real estate market.
Certificates of Deposit (CDs)
Certificates of Deposit (CDs) are one of the simplest and safest annuity alternatives. When you buy a CD from a bank, you agree to leave your money deposited for a set period, which can range from a few months to several years. In exchange, the bank pays you a fixed interest rate that is typically higher than a standard savings account. Your principal is protected up to FDIC insurance limits.
CDs are ideal for conservative investors who want a guaranteed return without any market risk. The trade-off for this safety is that returns are generally lower than what you might find with other investments. There are also penalties for withdrawing your money before the CD’s term is up, so they are best for funds you know you won’t need to access immediately.
Bond Ladders
A bond ladder is not a specific type of investment but rather a strategy for managing a portfolio of bonds. It involves purchasing multiple bonds that mature at different times. For example, you might buy bonds that mature in one, two, three, four, and five years. As each bond matures, you can either reinvest the principal into a new, longer-term bond or use the cash for income.
This strategy helps manage interest rate risk. If rates rise, you can reinvest your maturing bonds at the new, higher rates. If rates fall, you still have your longer-term bonds locked in at the old, higher rates. A bond ladder provides a steady, predictable stream of income from interest payments and can be built using various types of bonds, including Treasurys, municipals, or corporates.
Comparing Annuity Alternatives: Risk vs. Return
Every investment decision involves balancing risk, return, and your access to the money. Finding the right annuity alternative means understanding how each option performs in these three key areas. Some investments prioritize protecting your initial capital above all else, while others aim for higher growth but come with more uncertainty. Let’s look at how these alternatives stack up so you can find the one that aligns with your financial goals.
Breaking Down the Risk Profiles
When we talk about risk, we’re usually talking about the possibility of losing your principal investment. Annuities are often seen as low-risk because they can offer a guaranteed income stream. Alternatives like Certificates of Deposit (CDs) and government bonds are also on the safer end of the spectrum. They are designed for capital preservation and provide a predictable, though often modest, income.
Dividend-paying stocks and REITs carry more risk. While they can provide income, that income isn't guaranteed, and your principal can decrease if the market takes a downturn. Structured notes offer a unique middle ground. Their risk profiles are customizable; some notes come with 100% principal protection, ensuring you get your initial investment back at maturity, while others provide a buffer against a certain amount of market loss. This flexibility allows you to define your own risk-reward balance.
Weighing Potential Returns
The trade-off for lower risk is typically lower potential returns. Safe-haven assets like government bonds and CDs offer stability, but their returns may not always keep pace with inflation, especially in low-interest-rate environments. On the other hand, dividend stocks and retirement income funds give you a chance to benefit from market growth, but their returns are never guaranteed. A market dip could impact both your principal and your income stream.
This is another area where structured notes can fill the gap. They are designed to provide returns linked to the performance of an underlying asset, like a stock index. This allows you to participate in market gains, often with features that can lead to enhanced growth with protection. By setting predefined outcomes,
Considering Liquidity and Access
Liquidity refers to how quickly you can convert an asset into cash without a significant loss in value. This is a major drawback for annuities, which often come with hefty penalties for early withdrawals. If you need to access your money for an emergency, an annuity can be restrictive. Most alternatives offer better liquidity. Dividend stocks and bonds can be sold on any business day, giving you immediate access to your funds.
CDs are less liquid than stocks but more accessible than annuities, with fixed terms and predictable penalties for early withdrawal. Structured notes are also designed to be held until maturity. While a secondary market may exist, it’s not as active as the stock market. It’s important to match the note’s term with your financial timeline, ensuring you won’t need the funds before it matures. Understanding how to invest and the specific terms of a note is key to using them effectively in your portfolio.
Which Annuity Alternative Offers the Best Protection?
When building a long-term income stream, protecting your money is just as important as growing it. Different annuity alternatives approach protection in different ways. Some focus on safeguarding your initial investment, while others are designed to shield you from market dips or the effects of inflation. Understanding these nuances helps you find the right fit for your financial goals and peace of mind. Let's look at how various options stack up when it comes to keeping your portfolio secure.
Options for Protecting Your Principal
When your top priority is getting your initial investment back, certain assets stand out. Government bonds are well-known for their safety, promising to return your principal at maturity. But what if you want that security with more growth potential? This is where 100% Principal Protected notes come in. These investments are designed to return your full principal at maturity, no matter what the underlying market does. They offer a way to participate in potential market gains without putting your initial capital on the line, providing a powerful combination of security and opportunity.
How to Mitigate Downside Risk
Mitigating downside risk means creating a buffer against market declines. Traditionally, investors use high-quality bonds to balance stock market volatility. While effective, this can sometimes limit your growth potential. Structured notes offer a more dynamic way to manage this risk. Many notes are built with protection features, like a buffer that absorbs a certain amount of loss. For instance, a note with a 20% buffer means the index can fall by up to 20% before your principal is affected. This built-in cushion allows you to invest for growth with protection, giving you exposure to market upside while defining your risk from the start.
Protecting Your Income from Inflation
A steady income stream is only valuable if it keeps up with the rising cost of living. Inflation can erode the purchasing power of fixed payments from traditional bonds. While some investors turn to dividend stocks or Treasury Inflation-Protected Securities (TIPS), these options have their own risks. Structured notes provide another path. By linking returns to market indexes, they offer the potential for income and growth that can outpace inflation. An enhanced income note, for example, can provide coupon payments significantly higher than many bonds, helping your income retain its value over time.
Comparing the Costs: Annuities vs. Alternatives
When you’re weighing different investment options for your income strategy, it’s easy to focus on the potential returns. But the real story is often in the fine print. Fees and other costs, both obvious and hidden, can significantly affect how much your investment actually grows over time. A clear understanding of the cost structure of any financial product is essential. Let’s break down the typical costs associated with annuities and compare them to some of the more popular alternatives.
Uncovering Hidden Annuity Fees
One of the most common criticisms of annuities is their complex and often high fee structure. These costs can eat into your returns year after year, making it harder to reach your goals. Annuity fees can include mortality and expense charges, administrative fees, and surrender charges if you need to access your money early. On top of that, any special features, or riders, that you add for benefits like guaranteed lifetime income will come with their own price tag. It’s not uncommon for the total annual fees on a variable annuity to exceed 2% or 3%. This is also why placing an annuity inside a retirement account like an IRA is often a poor choice; you end up paying extra fees for tax-deferral benefits you already have.
Understanding the Costs of Alternatives
In contrast, many annuity alternatives come with more transparent and lower costs. Investments like Treasury bonds and Certificates of Deposit (CDs) have very straightforward fee structures, if any at all. With dividend stocks or REITs, you’ll typically only have to consider standard brokerage commissions. Even more sophisticated products like structured notes are designed with costs built directly into the terms of the investment, so there are no surprise annual fees. This upfront clarity makes it much easier to calculate your potential net returns. When you understand exactly how to invest and what the associated costs are from day one, you can make decisions with greater confidence.
How Fees Impact Your Overall Returns
A small percentage point here or there might not seem like a big deal, but the long-term effect of high fees can be staggering. Thanks to the power of compounding, even a 1% difference in annual fees can reduce your final portfolio value by tens of thousands of dollars over a couple of decades. This is the fundamental trade-off with many annuities: in exchange for a promise of security, you often give up a significant amount of your growth potential to fees. It’s worth asking whether that trade-off is truly worth it, especially when alternatives can offer enhanced growth with protection without the same heavy cost burden.
How to Choose the Right Annuity Alternative
Finding the right annuity alternative isn’t about picking the one with the highest advertised return. It’s about finding the investment that fits your unique financial situation and goals. What works for your neighbor might not be the right fit for you. Before you commit your capital, it’s essential to look inward and define what you need your money to accomplish. This process is less about chasing trends and more about building a strategy that supports your life.
Think of it as creating a personal investment blueprint. Are you focused on generating a steady income stream for retirement, preserving the capital you’ve worked hard to save, or growing your wealth for the long term? Your answers to these questions will guide your decisions. By evaluating a few key personal factors, you can confidently filter through the options and select an alternative that aligns perfectly with your financial objectives and comfort level. The following considerations will help you build that blueprint and make a more informed choice, ensuring your portfolio works for you, not against you. This self-assessment is the most important step you can take toward building a resilient and effective income strategy.
Assess Your Risk Tolerance
First, you need to be honest about your relationship with risk. Your risk tolerance is essentially how much potential loss you’re willing to accept in exchange for the chance at higher gains. Are you someone who can sleep soundly with market fluctuations, or does the thought of your principal dropping make you anxious? There’s no right or wrong answer, but it’s a critical piece of your financial identity.
Knowing what you want your money to do is the first step. If your primary goal is capital preservation, you’ll lean toward lower-risk options. If you’re aiming for growth and can handle some volatility, you might explore other avenues. Many investors find themselves somewhere in the middle, seeking solutions that offer enhanced growth with protection to balance risk and reward.
Define Your Liquidity Needs
Liquidity is simply how quickly you can access your money without taking a significant loss. Life is unpredictable, and you might need cash for an emergency or a sudden opportunity. One of the main drawbacks of annuities is that your money is often tied up for years, with steep penalties for early withdrawals. When considering alternatives, you need to decide how much access you require.
Investments like stocks and ETFs are highly liquid, as you can typically sell them any business day. On the other hand, assets like real estate are illiquid. Other options, such as CDs and some structured notes, have fixed terms. It’s crucial to match the investment’s term to your personal time horizon. Make sure you have a separate, easily accessible emergency fund so you aren’t forced to sell a long-term investment at the wrong time.
Consider the Tax Implications
Taxes can take a significant bite out of your investment returns, so it’s important to understand how different annuity alternatives are treated. Unlike the tax-deferred growth offered by annuities, many alternatives generate income or gains that are taxed annually. For example, the interest you earn from CDs and most bonds is typically taxed as ordinary income each year.
The tax rules can get complex. Dividend-paying stocks have different tax rates depending on whether the dividends are qualified or non-qualified. With structured notes, the tax treatment can vary based on the note's specific design. Because every investor's situation is different, it's a good idea to review the potential tax consequences with a financial professional. Understanding these implications beforehand helps you accurately project your net returns and avoid surprises come tax season.
Factor in Your Time Horizon
Your time horizon is the length of time you plan to keep your money invested before you need it. This single factor can dramatically influence your investment strategy. If you’re investing for a goal that’s decades away, you can generally afford to take on more risk for potentially higher growth. Market downturns are less concerning when you have plenty of time to recover.
Conversely, if you’re nearing retirement or investing for a short-term goal, your focus will likely shift toward capital preservation. For investors with a shorter time horizon, options that offer 100% principal protection can be particularly appealing. Aligning your investment choice with your time horizon ensures your portfolio is structured to meet your needs when you need it, without exposing you to unnecessary risk.
Building a Diversified Income Portfolio
Creating a reliable income stream isn’t about finding one perfect investment. It’s about building a resilient portfolio that can weather different economic climates by combining various assets. The goal is to construct a portfolio that aligns with your personal financial situation and income needs. A well-diversified income portfolio provides peace of mind, knowing your income sources are spread out and not entirely dependent on the performance of a single market sector.
The Power of Combining Different Assets
A truly effective income strategy relies on a blend of different financial products. Relying on a single asset for income can be risky, but combining several helps you meet your goals more consistently. Each type of investment reacts differently to market changes. For instance, while stocks may offer growth potential, they can also be volatile. Bonds might provide stability, but their returns can be modest. By including a mix of assets, you can smooth out your returns over time. This diversification is a core principle for building a portfolio that can provide income through various market cycles, which you can explore in various case studies.
Smart Asset Allocation Strategies
Your asset allocation is the blueprint for your income portfolio. It’s how you decide to divide your money among different investments to match your goals and comfort with risk. If you want more predictable returns, you might lean more heavily on investments like bonds or CDs. If you’re comfortable with more market risk for the chance of higher growth, you might allocate more to dividend stocks or real estate. The key is to find a balance that feels right for you. Your personal investment strategy should give you control over your financial future while aligning with your income objectives.
Balancing Your Need for Growth and Income
A successful income portfolio often needs to do two jobs at once: generate regular cash flow and grow over time to keep up with inflation. This is where the balance between income-focused and growth-oriented assets becomes critical. Dividend-paying stocks, for example, can provide both income and capital appreciation, but that income isn't guaranteed, and you could lose money if the stock market drops. Some investments prioritize stability over high growth. Products designed to provide enhanced income with protection can help bridge this gap, offering a way to generate income while managing potential downside risk in your portfolio.
Common Myths to Watch Out For
When you're planning for retirement income, it’s easy to get tangled in marketing claims and long-held beliefs about certain financial products. Annuities, in particular, are often surrounded by a cloud of myths that can make it difficult to see if they’re truly the right fit for your goals. Let's clear the air and look at some of the most common misconceptions so you can make a more informed decision about your financial future. Understanding these points will help you better evaluate all your options, from annuities to the alternatives we've discussed.
Debunking Annuity Marketing Claims
Many annuity sales pitches play on the fear of stock market volatility. The message is simple: the market is risky, but an annuity is safe. While comforting, it’s important to understand how that safety is created. Insurance companies invest your money, often in the same stock market, and pay you a return that is less than what they earn. This structure means you could be sacrificing significant growth potential for the feeling of security. It's always a good idea to look past the marketing and review insights and case studies to see how different investment vehicles perform in the real world.
Rethinking Your Perception of Risk
The promise of eliminating risk is powerful, but it almost always comes at a cost. With many annuities, that cost is your portfolio's growth potential. While they can protect you from downturns, they often cap your upside, limiting your ability to keep pace with inflation. True financial security isn't about avoiding risk entirely; it's about managing it intelligently. Sometimes, accepting a calculated level of risk is necessary for the long-term growth you need. Products designed for enhanced growth with protection aim to find a better balance, allowing you to participate in market gains while still defining your downside.
The Truth About "Guaranteed" Returns
The word "guaranteed" is perhaps the most appealing part of an annuity. A guaranteed income for life sounds like the ultimate retirement solution. However, annuities are not the only way to generate a reliable income stream. Other financial products can help you reach your goals, often with more flexibility and lower fees. While alternatives might not offer the exact same lifetime guarantee, many provide a high degree of principal protection and predictable returns. Exploring different types of structured notes can reveal ways to secure income and protect your principal without a rigid, long-term contract.
Related Articles
Frequently Asked Questions
Are annuities ever a good choice? While this post focuses on alternatives, annuities aren't universally bad for everyone. Their one standout feature is the potential for a guaranteed income you cannot outlive. If your single most important goal is to create a personal pension and you are willing to accept high fees, limited access to your money, and capped growth in exchange for that specific guarantee, then an annuity might be worth considering as one piece of your overall financial picture.
What makes structured notes different from other income investments like dividend stocks or bonds? The key difference is their design. Unlike a bond that pays a fixed interest rate or a stock that may pay a dividend, a structured note provides returns based on a predefined formula linked to an underlying asset. This allows for customized outcomes. You can have notes designed for enhanced income, growth with a buffer against losses, or even full principal protection, giving you a level of control over your risk and reward that you can't get from directly owning stocks or bonds.
How can I be sure my principal is actually protected with these alternatives? Protection comes in different forms depending on the investment. U.S. Treasury bonds and FDIC-insured CDs offer a direct government guarantee on your principal. With structured notes, protection is a contractual obligation from the issuing bank. For example, a 100% principal protected note is designed to return your initial investment at maturity, regardless of market performance. It's crucial to understand that this protection is dependent on the financial health of the issuing institution.
What's the biggest mistake to avoid when choosing an annuity alternative? The most common mistake is failing to match the investment's characteristics to your personal timeline and liquidity needs. It's easy to be drawn to a potentially higher return without considering how long your money will be tied up or what penalties might exist for early access. Before committing to any strategy, be realistic about when you might need the funds and ensure you have a separate, accessible emergency fund to cover unexpected expenses.
How do I get started with building a diversified income portfolio? The best first step is to clearly define your goals. Determine what you need the income for, how much risk you are comfortable with, and your time horizon. From there, you can begin to explore a mix of the alternatives discussed, such as blending the safety of bonds with the unique risk-management features of structured notes and the growth potential of dividend stocks. A thoughtful allocation based on your personal blueprint is more effective than chasing any single investment.
Patrick McNamara
CFP®, Financial Advisor at Claro Advisors
About the Author
Patrick McNamara, CFP® is a Financial Advisor at Claro Advisors
with nearly 30 years of experiencein the financial services industry.
He has held senior roles at Fidelity Investments, Goldman Sachs, and
Morgan Stanley. He founded StructuredNotes.com to educate investors
on institutional-style investment strategies and structured notes.
Disclosure: Claro Advisors Inc. (“Claro”) is a Registered Investment Advisor with the U.S. Securities and Exchange Commision (“SEC”) based in the Commonwealth of Massachusetts. Registration of an Investment Advisor does not imply a specific level of skill or training. Information contained herein is for educational purposes only and is not considered to be investment advice. Claro provides individualized advice only after obtaining all necessary background information from a client.
The investment products discussed herein are considered complex investment products. Such products contain unique features, risks, terms, conditions, fees, charges, and expenses specific to each product. The overall performance of the product is dependent on the performance of an underlying or linked derivative financial instrument, formula, or strategy. Return of principal is not guaranteed and is subject to the credit risk of the issuer. Investments in complex products are subject to the risks of the underlying reference asset classes to which the product may be linked, which include, but are not limited to, market risk, liquidity risk, call risk, income risk, reinvestment risk, as well as other risks associated with foreign, developing, or emerging markets, such as currency, political, and economic risks. Depending upon the particular complex product, participation in any underlying asset (“underlier”) is subject to certain caps and restrictions. Any investment product with leverage associated may work for or against the investor. Market-Linked Products are subject to the credit risk of the issuer. Investors who sell complex products or Market-Linked Products prior to maturity are subject to the risk of loss of principal, as there may not be an active secondary market. You should not purchase a complex investment product until you have read the specific offering documentation and understand the specific investment terms, features, risks, fees, charges, and expenses of such investment.
The information contained herein does not constitute an offer to sell or a solicitation of an offer to buy securities. Investment products described herein may not be offered for sale in any state or jurisdiction in which such offer, solicitation, or sale would be unlawful or prohibited by the specific offering documentation.
©2025 by Claro Advisors, Inc. All rights reserved.
For all Market-Linked Products, excluding Market-Linked CDs, the following applies: Not FDIC insured // Not bank guaranteed // May lose value // Not a bank deposit // Not insured by any government agency
