Pension Comments and Letters

Pension Committee comments to the Actuarial Standards Board (ASB) regarding proposed revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (March 31, 2010)

Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) on proposed regulations concerning reportable events under ERISA Section 4043 and the purchase of irrevocable commitments prior to initiating a standard plan termination under ERISA Section 4041. (January 22, 2010)

Pension Committee comments to the Department of Labor regarding the electronic display of certain information contained in the annual Form 5500 filing for single employer defined benefit plans. (December 9, 2009)

Pension Committee letter to Rep. Earl Pomeroy regarding H.R. 2748, Retirement Security Needs Lifetime Pay Act of 2009. (November 18, 2009)

Academy letter to FOX News responding to a news segment about the determination of cost of living adjustments (COLAs) for Social Security. (September 4, 2009)

Academy letter to Rep. Anthony Weiner concerning his comments about Social Security's annual cost-of-living adjustments (COLAs). (September 4, 2009)

Pension Practice Council response to the Governmental Accounting Standards Board (GASB)'s invitation to comment on pension accounting and financial reporting. (August 3, 2009)

Social Security Committee comment letter to the Federal Accounting Standards Advisory Board (FASAB) responding to an Exposure Draft: Accounting for Social Insurance. (June 3, 2009)

Pension Committee letter to Internal Revenue Service (IRS) providing input on the IRS guidance priority list for 2009-2010. (June 1, 2009)

Pension Committee comments to the Internal Revenue Service (IRS) regarding proposed regulations for some hybrid defined benefit (DB) pension plans. (March 3, 2008)

Pension Committee comments to the Internal Revenue Service (IRS) on proposed regulations for measuring pension assets and liabilities. (March 3, 2008)

Pension Committee letter to Internal Revenue Service (IRS) commenting on proposed benefit restrictions for defined benefit (DB) pension plans under Internal Revenue Code Sections 430(f) and 436. (November 5, 2007)

Pension Practice Council and Pension Committee letter to the House Ways and Means Committee requesting technical corrections to clarify aspects of the Pension Protection Act. (November 5, 2007)

Pension Committee letter to Joint Board for the Enrollment of Actuaries (JBEA) requesting the JBEA provide a summary of key mistakes or problems it has found in audits of enrolled actuaries CE filings. (September 3, 2007)

Cost Accounting Standards Task Force response to the Cost Accounting Standards Board (CASB) regarding a survey on harmonizing two cost accounting standards with provisions of the Pension Protection Act. (September 3, 2007)

Pension Committee letter to the Department of the Treasury requesting that Treasury reconsider its method for applying an anti-backloading rule (the four-thirds rule) to cash balance plans. (September 3, 2007)

Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)

Pension Committee comments to the Department of Energy (DOE) on the issues faced by the DOE and its contractors in managing the costs of pension and medical benefits. (May 10, 2007)

Social Security Committee comments to the Federal Accounting Standards Advisory Board (FASAB) regarding a preliminary views document on accounting for social insurance. (April 16, 2007)

Pension Committee comments to the Internal Revenue Service (IRS) regarding changes to the combined plan deduction limit under IRS Notice 2007-28. (March 1, 2007)