"an immoral contract" which "put a premium on murder". In New Zealand at the time, another of the chief critics of tontines had been the government, which also issued its own insurance. Modern regulation In France and Belgium, tontines clauses are inserted into contracts such as ownership deeds for property as a means to potentially reduce inheritance tax. The First Life Directive of the European Union includes tontines as a permitted class of business for insurers however this does not mean that tontines should be considered insurance contracts. According to the Supreme Court of the United States the nature of "insurance" involves some investment risk-taking on the part of the company. Tontines replace idiosyncratic longevity risk with systemic longevity risk and therefore have aspects of insurance however unless the issuer of a tontine provides a fixed return, the issuer assumes no true risk in the insurance sense. The new Pan-European Pension legislation which came into effect in March 2022 specifically paves the way for other types of financial service providers to create new pension products that abide by the "tontine principle" which tontine PEPP products can be offered throughout Europe once approved in a single member state. In most places in the United States using tontines to raise capital or obtain lifetime income is consistently upheld as being legal; however, legislation in two states has fostered the false perception that selling tontines in the broader U.S. is not legal. The impetus for modern tontines In 2015, John Barry Forman and Michael J. Sabin, using modern actuarial techniques to calculate fair transfer payments when participants are of different ages and have made different contributions, proposed a new structure of pension plan on the tontine model, through which large employers could provide retirement income for their employees. They argued that tontine pensions would have two major advantages over traditional pensions, as they would always be fully funded, and the plan sponsor would not be required to bear the investment and actuarial risks. Similar arguments were put forward in the same year by Moshe Milevsky. In March 2017, The New York Times reported that tontines were getting fresh consideration as a way for people to get steady retirement income. In 2017, Dean McClelland, Richard Fullmer and Jon Matonis and others published a whitepaper to deliver secure low cost Tontine Pensions based loosely upon the Forman, Sabin and Milevsky format under the brand Tontine