Pension Comments and Letters

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)

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)