Pension archives
2004
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 on delaying the effective date of relative value Treasury regulations (May 25, 2004)
A paper on the rules for maximum tax-deductible pension contributions (May 14, 2004)
A letter to House subcommittee members, accompanying a paper on maximum tax-deductible pension contributions (May 14, 2004)
A letter to GASB on accounting by governmental employers for other postemployment benefits (April 30, 2004)
Testimony by Ken Kent for a House hearing on pension system reform (April 29, 2004)
A letter to FASB about accounting and disclosure requirements related to the Medicare Modernization Act financial (April 13, 2004)
A letter from the Pension Practice Council to the ASB on a proposed revision of a data quality standard 23 (April 9, 2004)
A letter from the Pension Practice Council to the ASB on a proposed introduction to the ASOPs (April 9, 2004)
A presentation by Ron Gebhardtsbauer on DB vs. DC plans at an international forum on retirement security (March 4, 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)
Pension plan funding presentation by Ron Gebhardtsbauer for a briefing sponsored by a congressional steering committee and an industry benefits group (January 2004)
2003
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)
Winter 2003 Enrolled Actuaries Report (December 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 other 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 admininistration plan to create three new types of savings accounts (Aug. 13, 2003)
A statement to the ERISA Advisory Council on funding problems facing the traditional pension system (July 24, 2003)
A letter to the IRS on concerns about 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)
Testimony for a House Education and Workforce subcommittee hearing on pension security (June 4, 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)
Presentation slides for "Taking Pension Funding Into Account," Capitol Hill briefing (May 16, 2003)
Presentation slides for Washington Forum session, "Is Retirement Security Under Fire?" (May 9, 2003)
Testimony for a House Ways and Means subcommittee hearing on pension funding problems (April 30, 2003)
Memo to the North Carolina State Bar Association about allegations of unauthorized practice of law by retirement plan professionals (April 9, 2003)
Comment letter to the IRS on proposed age discrimination regulations for cash balance plans (March 26, 2003)
Comment letter to the IRS on proposed age discrimination regulations for non-cash-balance plans (March 26, 2003)
Comment letter to PBGC on calculating withdrawal liability for multiemployer DB plans (March 12, 2003)
Testimony for Senate Finance Committee hearing on funding challenges for DB pension plans (March 11, 2003)
What's Whipsaw? Why Is It a Problem? (February 2003 issue brief)
Letter asking the IRS for guidance on alternative funding relief provisions for multi-employer plans (Jan. 16, 2003)
DB-K Plus: A Defined Benefit Plan With 401(k) Features (issue brief, January 2003)
2002
Letter to the IRS on implementing phased retirement arrangements (Dec. 30, 2002)
Letter to GASB about a proposed accounting standard for post-employment benefit plans (Dec. 13, 2002)
Comment letter to the IRS on proposed rules to eliminate certain optional forms of benefit payments from DB plans (Oct. 23, 2002)
Statement to IRS on concerns about temporary regulation 1.401(a)9)-6T (Oct. 9, 2002)
Comment letter to FASB on cash balance accounting issues and the prevalence of cash balance plans (Aug. 20, 2002)
Comment letter on areas under IRC Section 412 that lack regulatory guidance or need clarification (Aug. 13, 2002)
Report offering alternatives to the 30-year Treasury rate in determining pension plan funding (July 17, 2002)
Letter to the IRS asking for a public hearing on 401(a)(9)-6T(July 16, 2002)
Testimony for House Ways and Means Oversight Subcommittee hearing on retirement security (June 20, 2002)
Comments to the Oklahoma legislature about pending legislation (May 31, 2002)
2001 and earlier
Letter to GASB on a simpler estimation method for small OPEB plans (Dec. 20, 2001)
Presentation to GAO employees comparing federal DB and DC pension plans (Dec. 18, 2001)
Proposed technical correctionsto pension provisions in EGTRRA (Oct. 12, 2001)
Request to the Joint Board to extend the deadline for EAs' CE credits (Sept. 21, 2001)
Statement to the ERISA Advisory Council on increasing pension coverage and preparing for retirement, plus presentation slides (July 17, 2001)
Statement about the impact of inordinately low 30-year Treasury rates on defined benefit plans (July 11, 2001)
Selecting and Documenting Investment Return Assumptions (practice note, May 2001)
Comments to the Treasury Department on using the RP-2000 mortality table for plan liability determinations (April 27, 2001)
Comment letter about a proposed ASOP, "Projected Benefit Illustrations in Connection With Retirement Plan Amendments" (Dec. 8, 2000)
Comment letter on applying anti-backloading tests to multiple benefit formulas (Sept. 14, 2000)
Comment letter on a proposed pension reform commission (July 2000)
Letter to Sen. Harkin about possible cash balance legislation (July 2000)
Comment letter on proposed amendments to SOP 92-6 (June 22, 2000)
Cash balance statement for Senate Special Committee on Aging hearing (June 5, 2000)
PBGC plan termination cost study (May 4, 2000)
"When Your Retirement Plan Changes: Understanding Your Cash Balance Plan" (Q&A, May 2000)
Letter to Sen. Kennedy on pension wear-away legislation (Nov. 8, 1999)
Testimony for Senate hearing on hybrid pension plan coverage(Sept. 21, 1999)
Cash balance plans (July 13, 1999)
Testimony on cash balance plans to ERISA Advisory Council (May and June 1999)
Cash balance plans (June 30, 1999)
Testimony to an Erisa Advisory Council working group on employer access to pension surplus (May 5, 1999)
Statement on universal savings accounts (February 1999)
Proposed Statement of Accounting for Social Insurance (Aug. 10, 1998)
Financing the Retirement of Future Generations (1998, No. 1) (455KB)
Comment letter on a proposed modification of the timing of plan valuations (June 22, 1998)
Testimony to ERISA Advisory Council on pension “leakage” (June 9, 1998)
Testimony for House hearing on pension reform issues (June 1996)
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