Pension Comments and Letters

Lifetime Income Risk Joint Task Force comment letter to the Department of Labor concerning proposals for increasing retiree income options, with a focus on additional safe harbors that encourage delivering lifetime income.
(August 19, 2016)

Multiemployer Subcommittee comment letter on the Pension Benefit Guaranty Corporation’s (PBGC) proposed rule on mergers and transfers between multiemployer plans.
(August 5, 2016)

Pension Committee comment letter on the decision by the Internal Revenue Service (IRS) to limit the pension actuaries’ potential to interact with IRS actuaries and other experienced employee-benefits personnel.
(July 15, 2016)

Pension Committee comment letter to the Pension Benefit Guarantee Corporation (PBGC) expressing appreciation for proposed regulations providing a reduction or partial waiver of the penalty due upon the late payment of premiums to the single employer and multiemployer insurance programs.
(June 22, 2016)

Pension Committee comment letter to the IRS and Treasury requesting that the 2017 Applicable Mortality Tables be issued as soon as possible. (June 10, 2016)

Intersector Group notes of its March 2016 meeting with the Treasury Department and Internal Revenue Service.  (June 7, 2016)

Intersector Group notes of its March 2016 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 7, 2016)

Pension Committee comments to the Internal Revenue Service regarding the proposed regulations for nondiscrimination relief for closed defined benefit plans.
(April 28, 2016)

Pension Practice Council comments to the Department of Defense regarding the use of personal discount rates to calculate lump-sum payments from military pensions as required in the National Defense Authorization Act for Fiscal Year 2016.
(April 27, 2016)

Pension Accounting Committee comments to the Financial Accounting Standards Board on its exposure draft on changes to the disclosure requirements for defined benefit plans.
(April 25, 2016)

Senior Pension Fellow Ted Goldman comments to the Senate Finance Committee on its hearing, “The Multiemployer Pension Plan System: Recent Reforms and Current Challenges.”
(March 17, 2016)

Intersector Group notes of its September 2015 meeting with the Treasury Department and Internal Revenue Service. 
(December 9, 2015)

Intersector Group notes of its September 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC).
(December 9, 2015)

Pension Practice Council comments to the Treasury Department and the Internal Revenue Service regarding final regulations concerning Qualified Longevity Annuity Contracts (QLACs) and their advantages. (November 6, 2015)

Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) regarding the proposed changes to the §4010 reporting requirements.
(September 25, 2015)

Multiemployer Subcommittee comments to the IRS and Treasury on proposed regulations on suspensions of benefits under the Multiemployer Pension Reform Act of 2014.
(August 19, 2015)

Lifetime Income Risk Task Force comments to the Department of Labor regarding the proposed regulations defining fiduciaries and conflict of interest.
(July 20, 2015)

Pension Committee comments to the IRS regarding the timing for release of the mortality tables under §§430(h)(3) and 417(e) of the Internal Revenue Code for 2016.  (July 17, 2015)

The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)

Intersector Group notes of its April 2015 meeting with the Treasury Department and Internal Revenue Service.  (June 2, 2015)