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PensionLetter from the Pension Accounting Committee and Joint Committee on Retiree Health to the to the National Association of Insurance Commissioners (NAIC) on the exposure drafts of Statements of Statutory Accounting Principles (SSAP) No. 92 and No. 102. Comments from the Academy’s Multiemployer Plans Subcommittee to the PBGC, IRS, DOL and Department of the Treasury with suggestions for operational fixes to PPA for multiemployer pension plans. Comments from the Pension Committee to the IRS and Department of Labor regarding a possible error in the instructions for Form 5500, Schedule H. Comments from the Pension Practice Council to the Governmental Accounting Standards Board (GASB) in response to two exposure drafts on pension accounting and financial reporting. Comments from the Pension Committee 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. Comments Comments from the Pension Committee to the Pension Benefit Guaranty Corporation regarding the calculation of unfunded vested benefits for at risk pension plans. Comments from the Pension Committee to the Joint Board for Enrollment of Actuaries regarding final regulations and continuing education requirements. Comments from the Pension Practice Council and Public Plans Subcommittee to the U.S. Securities and Exchange Commission on the registration of municipal advisors. Comments from the Pension Committee to the Internal Revenue Service expressing concerns about the registration requirements for PTINs and the application of these rules to various reporting requirements for retirement plan professionals. Comments from the Pension Committee to the Internal Revenue Service and Department of the Treasury with recommendations for future guidance on merger and spinoff issues related to the measurement of assets and liabilities for pension funding purposes and funding ratios. Comments from the Pension Committee to the Internal Revenue Service and Department of the Treasury regarding the definition of "plan-related expenses" Comments from the Pension Committee on the Actuarial Standards Board's proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. Comments from the Pension Finance Task Force on the Actuarial Standards Board's proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. Comments on the Actuarial Standards Board's proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. Comments to the Internal Revenue Service regarding propose regulations for hybrid retirement plans. Comments to the Financial Accounting Standards Board regarding proposed updates to disclosures required for employers that participate in multiemployer plans Response to the Governmental Accounting Standards Board (GASB)'s Preliminary Views on Pension Accounting and Financial Reporting by Employers. Response to the International Accounting Standards Board (IASB)'s proposed amendments to IAS 19, Employee Benefits. Comments on the proposed rulemaking for harmonization of CAS Nos. 412 and 413 with the Pension Protection Act of 2006 (PPA) Comments to the Department of the Treasury and the Internal Revenue Service with suggestions for the 2011 Schedules SB and MB Instructions and Forms. Written Comments Submitted to the Senate Special Committee on Aging for a Hearing on "The Retirement Challenge: Making Savings Last a Lifetime" The Pension Committee and the Multiemployer Subcommittee comment on multiemployer pension plan provisions of H.R. 4213, the American Workers, State and Business Relief Act of 2010 Comments to Congressman Pomeroy on H.R. 2748, The Retirement Security Needs Lifetime Pay Act of 2009 (November 2009) Letter to Congressman Anthony Weiner concerning Social Security’s annual cost-of-living adjustments (COLAs) (September 2009) Response to the Governmental Accounting Standards Board (GASB)’s invitation to comment on pension accounting and financial reporting (August 2009) Comments on the IRS' guidance priority list and provides a list of key issues awaiting guidance (June 2009) Request for comments on FASAB Exposure Draft: Accounting for Social Insurance, Revised, dated November 17, 2008 (February 9, 2009) Comments on proposed IRS regulations concerning PPA changes forsome hybrid pension plans (March 2008) Comments on proposed IRS regulations for measuring pension assets and liabilities (March 2008) Letter to IRS commenting on proposed DB benefit restrictions under sections 430(f) and 436 of the Internal Revenue Code (November 2007) Letter to House Ways and Means Committee requesting technical corrections to clarify the Pension Protection Act (November 2007) Request for JBEA to provide summary of key mistakes or problems it has found in audits of enrolled actuaries' CE filings (September 2007) Response to recent CASB survey on harmonizing two cost accounting standards with provisions of the Pension Protection Act (September 2007) Request that the Treasury Department reconsider its method for applying an anti-backloading rule (the four-thirds rule) to cash balance plans (September 2007) Letter to Texas officials from the Joint Committee on Retiree Health about misinterpretations of the committees 2006 comments on accounting standards for OPEBs (June 2007) Comments to Federal Accounting Standards Advisory Board (FASAB) on Preliminary Views - Accounting for Social Insurance, Revised (April 2007) Comment letter to Department of Energy about its DB pension reimbursement policy for DOE contractors (May 2007) Comments to the IRS regarding changes to the combined plan deduction limit under Notice 2007-28 (March 2007) Letter to IPSASB regarding additional to time to review Exposure Draft (ED) 31 (March 2007) Comments to the IRS and Treasury Department on using substitute mortality tables (November 2006) Comments on a proposed asset-question addition to Form 5500 (September 2006) A revised request for technical guidance from the IRS on Circular 230 regulatory issues (August 2006) Letters to FASB expressing concern over proposed changes in financial accounting standards for pensions and OPEBs, accompanied by news release (May 31, 2006) Follow-up letter to GAO about its cash balance report (May 2006) “Keeping Employers Responsible for Their (and Only Their) Pension Promises” (May 2006 analysis) Letter to Secretary of Energy about Department of Energy policy on reimbursing DOE contractors’ DB pension costs (May 2006) Comments to the SEC on a proposed executive-compensation disclosure rule (April 2006) Comments on a proposed GASB technical bulletin about the Medicare Part D retiree drug subsidy (April 2006) An updated analysis of pension funding reform bills (March 2006, updating a November 2005 report) Comments on Moody’s proposed rating methodology for companies with multiemployer DB plans (March 2006) Comments on a FASB project to reconsider accounting for pension benefits and other benefits (February 2006) Original letter sent to the editor of the Economist and the published version (February 2006) Letter to the editor of the Financial Times (Dec. 2, 2005) Comments on a GAO report about cash balance plans, and the GAO's response (November 2005, December 2005) An analysis of single-employer issues in pension funding legislation (November 2005; superseded by March 2006 update) An analysis of multi-employer issues in pension funding legislation (November 2005) Request for technical advice ruling on Circular 230 issues (October 2005) Updated Pension Committee analysis of President Bush's retirement-savings proposals (August 2005 report, followed by news release) Letter to FASB about concerns that should be addressed if it reconsiders FAS 87 (August 5, 2005) Comments to House leaders urging that the proposed Pension Protection Act include a "look-back" option for determining quarterly pension contributions (July 27, 2005) Presentation to ERISA advisory council meeting about DB and DC distribution options (July 2005) Letter to the IRS about communication under relative value regulations (May 10, 2005) Letter to the IRS about applying Circular 230 to actuarial work (May 9, 2005) Follow-up response to Sen. Ted Kennedy after Academy testimony on the PBGC and pension funding reform (May 31, 2005) Comment letter on proposed multiemployer rules for annual funding notices (March 7, 2005) Backgrounder on credit balance options for DB pension funding reform (March 2005) Comment letter on the IRS position on crediting contributions for multiemployer pension plans (March 22, 2005) An analysis of the Bush administration's proposal for single-employer pension funding. (March 8, 2005) Suggested funding reform principles for single-employer pension plans (February 2005) Comments on proposed IRS regulations for phased retirement (Feb. 8, 2005) Comments on a delay of amortization relief under IRC 412(e) (Jan. 28, 2005) Pension Committee comments to the ASB on a proposed pension valuation standard (October 2004) Letter to IRS on proposed changes to ERISA regulations (September 2004) Paper on current funding and accounting fundamentals for private-sector pension plans (July 2004; updates the February 2004 original) Comments on an IASB draft interpretation concerning financial reporting for multiemployer plans (July 9, 2004) Comment letter to FASB about measuring the value of employee stock options (June 30, 2004) A letter to GASB on accounting by governmental employers for other postemployment benefits (April 30, 2004) Letter to Senate staffers on multiemployer provisions in HR 3108 (March 4, 2004) Summary of a draft paper on principles for revising pension funding rules (February 2004) Recommendations on pension plans' using the RP-2000 mortality tables when determining current liability (Dec. 31, 2003) Letter supporting a FASB staff proposal to defer accounting for the effects of the Medicare Prescription Drug Act (Dec. 26, 2003) Letter again asking Congress to fix the pension discount rate before adjourning (Dec. 5, 2003) Letter asking Congress to fix the pension discount rate before adjourning (Nov. 20, 2003) Suggested changes in FASB financial disclosure proposals for pensions and postretirement benefits (Oct. 27, 2003) A letter to Sen. Evan Bayh on his DB pension legislation (Oct. 7, 2003) Comments to the IRS about a revenue ruling on entry age funding methods (Aug. 18, 2003) A Pension Committee analysis of a Bush administration plan to create three new types of savings accounts (Aug. 13, 2003) A letter to the IRS about concerns over "good faith compliance" for qualified plans (July 2, 2003) An analysis of proposals to change the discount rate used to determine lump-sum pension benefits (June 17, 2003) A letter to FASB about cash balance accounting issues (May 23, 2003) A comment letter to GASB about financial reporting for retiree health plans and other non-pension benefits (May 16, 2003) A memo to the North Carolina State Bar Association about allegations of unauthorized practice of law by retirement plan professionals (April 9, 2003) A comment letter to the IRS on proposed age discrimination regulations for cash balance plans (March 25, 2003) A comment letter to the IRS on proposed age discrimination regulations for non-cash-balance plans (March 25, 2003) Comment letter to the PBGC on calculating withdrawal liability for multiemployer DB plans (March 12, 2003). A letter from the Multi-Employer Task Force asking the IRS for guidance on alternative funding relief provisions for multi-employer plans (Jan. 16, 2003). A letter to the IRS from the Pension Committee on implementing phased retirement arrangements (Dec. 30, 2002). A letter from the Academy's vice presidents for financial reporting, health, and pension issues to GASB about a proposed accounting standard for post-retirement benefit plans (Dec. 13, 2002). A comment letter to the IRS from the Pension Committee on proposed rules to eliminate certain optional forms of benefit payments from DB plans (Oct. 23, 2002). A comment letter to FASB from the Pension Accounting Committee on cash balance accounting issues and the prevalence of cash balance plans (Aug. 20, 2002). A comment letter from a Pension Committee task force on areas under IRC Section 412 that lack regulatory guidance or need clarification (Aug. 13, 2002). Report from the Pension Practice Council offering alternatives to using the 30-year Treasury rate in determining pension plan funding (July 17, 2002). Letter from the Public Plans Task Force to the IRS about 401(a)(9)-6T, asking for a public hearing on the temporary regulation (July 16,2002). Comments from the Public Plans Task Force to the Oklahoma Legislature about HB 1719 (May 31, 2002). Letter from the Pension Accounting Committee letter to the Government Accounting Standards Board (GASB) on a simpler estimation method for small OPEB plans (Dec. 20, 2001). Proposed technical corrections in the pension provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), sent by the Pension Committee to the Treasury Department (Oct. 12, 2001). A request from the Academy to the Joint Board for Enrolled Actuaries to extend the deadline for EAs' CE credits (Sept. 21, 2001). A public statement by the Pension Practice Council on the impact of inordinately low 30-year Treasury rates on defined benefit plans (July 11, 2001) The Pension Committee's comments to the Treasury Department on using the RP-2000 mortality table for pension plan liability determinations. Comment letter to the ASB from the Academy's Pension Committee about a proposed ASOP, "Projected Benefit Illustrations in Connection With Retirement Plan Amendments." (Dec. 8, 2000) Application of 133-1/3 % Anti-Backloading Test to Multiple Benefit Formulas (September 14, 2000) Harkin-Andrews Request on Wear-Way Proposals (July 2000) Pension Reform Commission (July 2000) Comment Letter to the AICPA on the Proposed Amendments to SOP 92-6 (June 22, 2000) When Your Retirement Plan Changes: PBGC Termination Cost Study (May 4, 2000) Pension Wear Away Legislation Letter to Senator Edward Kennedy (November 8, 1999) Cash Balance Plans (July 13, 1999) Cash Balance Plans (June 30, 1999) Universal Savings Accounts (February, 1999) Proposed Statement of Accounting for Social Insurance (August 10, 1998) A comment letter to Sen. Bob Graham from the Academy Pension Committee on a proposed modification of the timing of plan valuations (June 22, 1998). |
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