Pension Comments and Letters

Pension Committee comment letter to the Actuarial Standards Board regarding the discussion draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (October 12, 2011)

Pension Committee comment letter to the Pension Benefit Guaranty Corporation regarding the calculation of unfunded vested benefits for at risk pension plans. (September 22, 2011)

Social Security Committee letter urging the president, congressional leaders, and the Joint Select Committee on Deficit Reduction to improve the long-term solvency and sustainability of Social Security. (September 22, 2011)

Public Interest Committee second follow-up letter to Chairman Johnson and Ranking Member Becerra of the House Ways and Means Subcommittee on Social Security regarding Academy's congressional testimony. (August 26, 2011)

Letter following up Public Interest Committee congressional testimony to House Ways and Means Subcommittee on Social Security. (August 15, 2011)

Pension Committee comment letter to the Joint Board for Enrollment of Actuaries regarding final regulations and continuing education requirements for enrolled actuaries. (June 29, 2011)

Pension Practice Council and Public Plans Subcommittee comment letter to the Securities and Exchange Commission requesting that public pension plans be excluded from the definition of "investment strategies" and that enrolled actuaries and members of the five U.S.-based actuarial organizations be excluded from the definition of "municipal advisors" to the extent they are providing actuarial services that are governed by the Actuarial Standards of Practice and the Code of Professional Conduct. (June 22, 2011)

Pension Committee letter to the Internal Revenue Service with concerns about the implications of the proposed modifications to Circular 230 and registration requirements for PTINs and the application of these rules to various reporting requirements for retirement plan professionals. (June 14, 2011)

Pension Committee letter to the Internal Revenue Service and Department of the Treasury with comments and recommendations for future guidance on merger and spinoff issues related to the measurement of assets and liabilities for pension funding purposes and funding ratios. (June 1, 2011)

Pension Committee comments to the IRS and Treasury regarding the potential implications of expected regulatory guidance on the definition of "plan-related expenses expected to be paid from plan assets" under Internal Revenue Code (IRC) Section 430(b). (May 24, 2011)

Pension Committee comments to the Actuarial Standards Board regarding a proposed revision of ASOP No. 27, "Selection of Economic Assumptions for Measuring Pension Obligations." (May 12, 2011)

Pension Committee comments to the Internal Revenue Service regarding proposed regulations for hybrid retirement plans. (January 12, 2011)

Multiemployer Pension Plans Subcommittee comments to the Financial Accounting Standards Board regarding proposed updates to disclosures required for employers that participate in multiemployer plans (November 1, 2010)

Joint Committee on Retiree Health and the Pension Accounting Committee joint comments to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions). (October 4, 2010)

Pension Practice Council response to the Governmental Accounting Standards Board (GASB)'s "Preliminary Views on Pension Accounting and Financial Reporting by Employers." (September 17, 2010)

Pension Accounting Committee comments to the International Accounting Standards Board (IASB) regarding  proposed amendments to IAS 19. (September 3, 2010)

Pension Committee comments to the Cost Accounting Standards Board on the proposed rulemaking for harmonization of CAS Nos. 412 and 413 with the Pension Protection Act of 2006. (July 9, 2010)

Pension Committee letter to the Department of the Treasury and the Internal Revenue Service (IRS) with suggestions for the 2011 schedules SB and MB instructions and forms. (July 7, 2010)

Pension Committee and the Multiemployer Subcommittee comments on multiemployer pension plan provisions of H.R. 4213, the American Workers, State and Business Relief Act of 2010. (May 4, 2010)

Pension Practice Council and Life Practice Council's response to a request for information from the Labor and Treasury departments regarding lifetime-income options for participants and beneficiaries in retirement plans. (May 3, 2010)