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2010
The Pension Practice Council and Life Practice Council's response to a request for information from the departments of Labor and the Treasury regarding lifetime-income options for participants and beneficiaries in retirement plans. (May 2010)
Pension Committee comments to
the Actuarial Standards Board regarding proposed revisions to ASOP 41 (March
2010)
Pension Committee comments to
the Actuarial Standards Board regarding proposed revisions to ASOP 35 (March
2010)
Comments to the Department
of the Treasury and the Internal Revenue Service concerning final
regulations on pension funding and benefit restrictions under Internal
Revenue Code Sections 430 and 436 (March 2010)
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 2010)
2009
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 2009)
Comments on H.R. 3936, The Preserve Benefits and Jobs Act of 2009 (December 2009)
Practice note on Preparing a Certification of the Adjusted Funding Target Attainment Percentage (AFTAP) for a Pension Plan (December 2009)
Comments to the Joint Board in response to proposed regulations governing the performance of actuarial services under the Employee Retirement Income Security Act of 1974 (November 2009)
Comments on H.R. 2748, The Retirement Security Needs Lifetime Pay Act of 2009 (November 2009)
Request for comments on FASAB Exposure Draft: Accounting for Social Insurance, Revised, dated November 17, 2008 (February 9, 2009)
2008
Report from the Public Interest Committee to the ASB to examining pension disclosures, which was partly developed from information obtained
through a public forum held on Sept. 4 (September 2008)
Slides and other information from an Academy Capitol Hill briefing on social security (September 2008)
Comments to the Actuarial Standards Board regarding ASOP 27 revisions. (September 2008)
A letter to the IRS regarding the proposed regulations providing guidance on the application of the accrual rule for defined benefit plans under section 411(b)(1)(B). (September 2008)
A letter to the IASB responding to request for comments on its discussion paper on IAS19, accounting standard for employee benefits. (September 2008)
Letter to the editor of
the New York Times, responding to "Actuaries Scrutinized
on Pensions" article (May 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 committee’s 2006 comments
on accounting
standards for OPEBs (June 2007)
Comment letter to Department of Energy about its DB pension
reimbursement policy for DOE
contractors (May 2007)
Letter to the IRS
outlining key issues awaiting guidance for 2007 (May 2007)
Comments to Federal Accounting Standards Advisory Board (FASAB) on Preliminary Views - Accounting for Social Insurance, Revised (April 2007)
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 on a proposed GASB technical bulletin about the Medicare
Part D retiree drug subsidy (April
2006)
Longevity and Retirement Policy: Modernizing America's Retirement
Programs to Keep Pace with Longevity (April 2006 issue
brief, accompanied by news
release)
An updated analysis of pension
funding reform bills (March 2006, updating a November 2005
report)
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)
A white paper on how cash
balance plans can adapt features of traditional DB designs
(August 2005)
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)
Follow-up response
to Sen. Ted Kennedy after Academy testimony on the PBGC and pension
funding reform (May 31, 2005)
Fact sheet about
United Airlines' recently terminated pension plans and the PBGC's
deficit; related news
release (May 12, 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)
Testimony for
a Senate hearing on the PBGC and pension funding reform; related news
release (April 26, 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) Note: In a slightly different format, this paper was presented
as written testimony for a March 8, 2005 House Ways and Means
subcommittee hearing.
Comments on proposed regulations for multiemployer
plans' annual funding notices (March 8, 2005)
Suggested funding reform principles for single-employer pension
plans (February 2005)