Pension Comments and Letters

Pension Committee comments to the Actuarial Standards Board on its recent modeling ASOP exposure draft that included concerns that the potential ASOP could be applied too broadly. (September 27, 2013)

Pension Finance Task Force letter to the Financial Accounting Standards Board (FASB) that provides suggestions, based on financial economics, to improve accounting for single employer pension plans, an issue that FASB may consider revisiting. (September 26, 2013)

Pension Committee comments to the Internal Revenue Service regarding the Annual Return/Report of Employee Benefit Plan (Form 5500) that focus on the electronic submission of data on Schedules SB and MB. (September 23, 2013)

Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to a second exposure draft of ASOP No. 6, Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or Prefunding Contributions. (August 30, 2013)

Health and Pension Practice Council letter to the Actuarial Standards Board on coordinating Actuarial Standards of Practice (ASOP) affecting pension and retiree group benefits. (August 30, 2013)

Pension Committee comments on Department of Labor’s advance notice of proposed rulemaking regarding pension benefit statement requirements under section 105 of the Employee Retirement Income Security Act of 1974. (August 7, 2013)

Letter from Senior Pension Fellow Don Fuerst to Chairman Johnson and Ranking Member Becerra of the House Ways and Means Subcommittee on Social Security in response to questions from Chairman Johnson following Fuerst’s May 23 testimony to the subcommittee. (July 31, 2013)

Pension Committee comments to the Pension Benefit Guaranty Corporation regarding its proposed rule on reportable events under ERISA Section 4043. (June 3, 2013)

Pension Finance Task Force comments to the Actuarial Standards Board on revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2013)

Pension Committee comments to the Actuarial Standards Board on revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2013)

Academy letter to the president and Congressional leaders that encourages them to appoint at least one qualified actuary to the newly-established Military Compensation and Retirement Modernization Commission. (April 22, 2013)

Pension Committee comments to the Internal Revenue Service regarding notice requirements under section 101(j) of ERISA, as promulgated in Notice 2012-46. (February 5, 2013)

Joint Committee on Retiree Health comments to the Actuarial Standards Board on revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (February 2, 2013)

Academy’s Letter to the New York Times Editor On “Social Security: It’s Worse than You Think” Opinion Piece
(January 9, 2013)

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 25, Credibility Procedures. (December 28, 2012)

Comments by Public Plans Subcommittee to the California Actuarial Advisors Panel (CAAP) in response to its discussion draft, Version 9c, Model Actuarial Funding Policies and Practices (MAFPP) for Public Pension and OPEB Plans. (October 3, 2012)

Pension Practice Council comments to Moody’s in response to its proposed adjustments to public pension data reported by US state and local governments, as discussed in a Moody’s report, Adjustments to US State and Local Government Reported Pension Data. (October 2, 2012)

Pension Practice Council comments to the Pension Committee of the Actuarial Standards Board regarding its discussion draft, Assessment and Disclosure of Risk Associated with Pension Obligations, Plan Costs, and Plan Contributions. (October 1, 2012)

Pension Accounting Committee comments to the Financial Accounting Standards Board (FASB) regarding its proposed Accounting Standards Update: Financial Instruments (Topic 825) – Disclosures about Liquidity Risk and Interest Rate Risk. (October 1, 2012)

Pension Committee comments to the Internal Revenue Service in response to its proposed regulations concerning the prohibited payment option under single-employer defined benefit plans when a plan sponsor is in bankruptcy. (August 20, 2012)