Pension Comments and Letters

Intersector Group notes of its April 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 2, 2015)

Pension Committee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (June 1, 2015)

Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (May 29, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the IRS and Treasury regarding the Request for Information on Suspensions of Benefits under the Multiemployer Pension Reform Act of 2014 (MPRA).  (April 7, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the Pension Benefit Guarantee Corporation regarding the Request for Information on Partitions and Facilitated Mergers under the Multiemployer Pension Reform Act of 2014 (MPRA). (April 6, 2015)

Pension Committee comment letter to the Actuarial Standards Board (ASB) regarding the second exposure draft of the proposed Actuarial Standard of Practice (ASOP) on modeling standards.  (March 1, 2015)

Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 5, 2015)

Pension Committee comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans.
(February 5, 2015)

Pension Practice Council (PPC) letter to Treasury Department regarding the benefits of allowing qualified defined benefit pension plans to provide longevity annuities directly, rather than requiring them to purchase an insurance contract.  (January 14, 2015)

Pension Committee comment letter to the PBGC regarding interpretation of plan provisions governing actuarial equivalence. (January 13, 2015)

Pension Committee comment letter to the IRS regarding the updated final and newly proposed regulations for hybrid retirement plans. (December 18, 2014)

Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Treasury Department and Internal Revenue Service. (November 24, 2014)

Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Pension Benefit Guaranty Corporation.  (November 24, 2014)

Pension Finance Task Force letter to the Actuarial Standards Board on actuarial valuations and other analyses used for determining public pension and other post-employment plan funding and accounting. (November 15, 2014)

Joint Committee on Retiree Health letter to the Actuarial Standards Board on actuarial valuations and other analyses used for determining public pension and other post-employment plan funding and accounting. (November 15, 2014)

Public Plans Subcommittee letter to the Actuarial Standards Board on actuarial valuations and other analyses used for determining public pension and other post-employment plan funding and accounting. 
(November 15, 2014)

The Pension Committee's Public Plans Subcommittee letter to the Governmental Accounting Standards Board commenting on an Exposure Draft on accounting and financial reporting for pension plans that are not administered through trusts and amendments to certain provisions of GASB Statements 67 and 68. (August 29, 2014)

The Joint Committee on Retiree Health letter to the Governmental Accounting Standards Board commenting on proposed statements of accounting and financial reporting by governmental employers for other postemployment benefits (OPEBs). (August 29, 2014)

Pension Committee letter to the Internal Revenue Service and Treasury Department on guidance needed regarding the Highway and Transportation Funding Act of 2014. (August 26, 2014)

Pension Practice Council letter to Congressional leaders on concerns about proposals to raise revenues by changing private sector pension law to offset unrelated spending increases. (July 25, 2014)