Pension Comments and Letters

Pension Committee letter to Department of Treasury officials regarding the implementation of MAP-21 pension provisions. Attached to the letter is an outline of topics discussed by several Pension Committee members at a meeting with Treasury on July 23. (August 2, 2012)

Pension Practice Council letter to Sen. Orrin Hatch responding to a January 10, 2012 report entitled “State and Local Government Defined Benefit Pension Plans: The Pension Debt Crisis that Threatens America.” (July 31, 2012)

Pension Committee letter to the SOA regarding a new set of mortality tables and projection scales for the valuation of uninsured pension plans. (June 30, 2012)

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Pension Finance Task Force comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)

Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Pension Committee comments to the Internal Revenue Service on proposed regulations for partial annuity distribution options under defined benefit pension plans. (May 3, 2012)

Pension Committee comment letter to the Internal Revenue Service responding to proposed regulations for longevity annuity contracts. (May 3, 2012)

Pension Practice Council letter to members of the House-Senate Conference Committee commenting on the pension funding stabilization provisions included in S. 1813 as passed by the Senate. (May 2, 2012)

Pension Accounting Committee and Public Plans Subcommittee joint comment letter to the Governmental Accounting Standards Board responding to GASB’s Preliminary Views on Economic Condition Reporting: Financial Projections. (April 2, 2012)

Pension Committee letter to the Internal Revenue Service and Department of the Treasury addressing elections to reduce funding balances for defined benefit pension plans. (February 16, 2012)

Pension Committee letter to the Internal Revenue Service and Department of the Treasury concerning differing interpretations in the application of IRC Section 415(b) limits and requesting guidance. (January 30, 2012)

Pension Accounting Committee and Joint Committee on Retiree Health letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 9, 2011)

Pension Accounting Committee and Joint Committee on Retiree Health comment letter to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. (December 6, 2011)

PBGC response to the Pension Committee’s Oct. 14 inquiry regarding instructions on the Schedule H (Form 5500). (November 2, 2011)

Multiemployer Plans Subcommittee letter to the Pension Benefit Guaranty Corporation (PBGC) with proposed modifications to the multiemployer pension plan provisions of the Pension Protection Act (PPA). (October 26, 2011)

Pension Committee letter to the IRS and Department of Labor concerning a possible error in the instructions for Form 5500, Schedule H on the reporting of premium payments made to the PBGC from qualified DB plan assets.  (October 17, 2011)

Pension Practice Council comments to the Governmental Accounting Standards Board (GASB) to two exposure drafts on pension accounting and financial reporting by employers. (October 14, 2011)