Other Pension documents

2010

The Joint Committee on Retiree Health and the Pension Accounting Committee jointly submitted comments [1] to the NAIC regarding the exposure draft of SSAP 92 (OPEBs) and proposed revisions to SSAP 89 (pensions) (September 2010)

The Pension Practice Council and Life Practice Council's response [2] 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 [3] to the Actuarial Standards Board regarding proposed revisions to ASOP 41 (March 2010)

Pension Committee comments [4] to the Actuarial Standards Board regarding proposed revisions to ASOP 35 (March 2010)

Comments [5] 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 [6] and the purchase of irrevocable commitments prior to initiating a standard plan termination under ERISA Section 4041 [7](January 2010)

2009

Comments [8] 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 [9], The Preserve Benefits and Jobs Act of 2009 (December 2009)

Practice note on Preparing a Certification [10] of the Adjusted Funding Target Attainment Percentage (AFTAP) for a Pension Plan (December 2009)

Comments [11] 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 [12] on H.R. 2748, The Retirement Security Needs Lifetime Pay Act of 2009 (November 2009)

Practice note on selecting and documenting other pension assumptions [13] (October 2009)

Practice note on selecting and documenting mortality assumptions [14](October 2009)

Updated issue brief [15] on understanding assumptions used to evaluate Social Security's financial condition (September 2009)

Letter [16] to Congressman Anthony Weiner concerning Social Security’s annual cost-of-living adjustments (September 2009)

Letter to the IRS regarding the use of Surplus Assets as Matching Contributions [17] under 401(k) Replacement Plans (August 2009)

Response [18] to the Governmental Accounting Standards Board (GASB)’s invitation to comment on pension accounting and financial reporting (August 2009)

Comments [19] on the IRS' guidance priority list and provides a list of key issues awaiting guidance (June 2009)

Slides [20] and other information from an Academy Capitol Hill briefing on financial reform (June 2009)

An Actuarial Perspective on the 2009 Social Security Trustees’ Report [21](May 2009; annually updated issue brief)

Request for comments [22] on FASAB Exposure Draft: Accounting for Social Insurance, Revised, dated November 17, 2008 (February 9, 2009)

2008

Report [23] from the Public Interest Committee to the ASB to examining pension disclosures, which was partly developed from information obtained through a public forum [24] held on Sept. 4 (September 2008)

Slides and other information from an Academy Capitol Hill briefing on social security [25] (September 2008)

Comments [26] to the Actuarial Standards Board regarding ASOP 27 revisions. (September 2008)

A letter to the IRS [27] 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 [28] responding to request for comments on its discussion paper on IAS19, accounting standard for employee benefits. (September 2008)

Letter to the editor [29] of the New York Times, responding to "Actuaries Scrutinized on Pensions" article (May 2008)

Election 2008 [30] section (launched March 2008)

Comments on proposed IRS regulations concerning PPA changes for some hybrid pension plans [31] (March 2008)

Comments on proposed IRS regulations for measuring pension assets and liabilities [32] (March 2008)

2007

Letter to IRS commenting on proposed DB benefit restrictions [33]under sections 430(f) and 436 of the Internal Revenue Code (November 2007)

Letter to House Ways and Means Committee requesting technical corrections [34] 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 [35] (September 2007)

Response to recent CASB survey on harmonizing two cost accounting standards [36] 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 [37] (September 2007)

Letter to Texas officials from the Joint Committee on Retiree Health about misinterpretations of the committee’s 2006 comments onaccounting standards for OPEBs [38] (June 2007)

Comment letter to Department of Energy about its DB pension reimbursement policy for DOE contractors [39] (May 2007)

Letter [40] to the IRS outlining key issues awaiting guidance for 2007 (May 2007)

Comments [41] to Federal Accounting Standards Advisory Board (FASAB) on Preliminary Views - Accounting for Social Insurance, Revised (April 2007)

Comments to the IRS regarding changes to the combined plan deduction limit [42] under Notice 2007-28 (March 2007)

Letter to IPSASB regarding additional to time to review Exposure Draft (ED) 31 [43] (March 2007)

2006

A Pension Actuary's Guide to Financial Economics [44] (by a joint Academy/SOA task force, 2006)

Comments to the IRS and Treasury Department on usingsubstitute mortality tables [45] (November 2006)

Draft practice note on valuing employee stock options [46] (October 2006)

Comments on a proposed asset-question addition to Form 5500 [47](September 2006)

A revised request for technical guidance from the IRS on Circular 230 [48] regulatory issues (August 2006)

The Value of Defined Benefit Plans (July 2006 issue brief [49], plusexecutive summary [50])

Letters to FASB expressing concern over proposed changes in financial accounting standards for pensions [51] and OPEBs [52], accompanied by news release [53] (May 31, 2006)

Follow-up letter to GAO about its cash balance [54] report (May 2006)

“Keeping Employers Responsible for Their (and Only Their) Pension Promises [55]” (May 2006 analysis)

Letter to Secretary of Energy about Department of Energy policy on reimbursing DOE contractors’ DB pension [56] costs (May 2006)

Comments to the SEC on a proposed executive-compensation disclosure [57] rule (April 2006)

Comments on a proposed GASB technical bulletin about the Medicare Part D retiree drug subsidy [58] (April 2006)

Longevity and Retirement Policy: Modernizing America's Retirement Programs to Keep Pace with Longevity (April 2006 issue brief [59], accompanied by news release [60])

An updated analysis of pension funding reform [61] bills (March 2006, updating a November 2005 report)

Comments on Moody’s proposed rating methodology [62] for companies with multiemployer DB plans (March 2006)

Comments on a FASB project to reconsider accounting for pension benefits [63] and other benefits (February 2006)

Original [64] letter sent to the editor of the Economist and thepublished version [65] (February 2006)

2005

Comments on a GAO report about cash balance plans [66] and the GAO's response [67]. (November 2005, December 2005)

Letter to the editor [68] of the Financial Times (December. 2, 2005)

An analysis of single-employer issues in pension funding legislation (November 2005; superseded by March 2006 update [61])

An analysis [69] of multi-employer issues in pension funding legislation (November 2005)

Request for technical advice ruling on Circular 230 [70] issues (October 2005)

Updated Pension Committee analysis of President Bush's retirement-savings proposals (August 2005 report [71], followed bynews release [72])

A white paper on how cash balance plans [73] can adapt features of traditional DB designs (August 2005)

Letter to FASB about concerns [74] 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 [75] (July 27, 2005)

Presentation to ERISA advisory council meeting about DB and DCdistribution options [76] (July 2005)

Follow-up [77] response to Sen. Ted Kennedy after Academy testimony on the PBGC and pension funding reform (May 31, 2005)

Fact sheet [78] about United Airlines' recently terminated pension plans and the PBGC's deficit; related news release [79] (May 12, 2005)

Letter [80] to the IRS about communication under relative value regulations (May 10, 2005)

Letter [81] to the IRS about applying Circular 230 to actuarial work (May 9, 2005)

Testimony [82] for a Senate hearing on the PBGC and pension funding reform; related news release [83] (April 26, 2005)

Backgrounder [84] on credit balance options for DB pension funding reform (March 2005)

Comment [85] letter on the IRS position on crediting contributions for multiemployer pension plans (March 22, 2005)

An analysis of the Bush administration's proposal [86] 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' [87]annual funding notices (March 8, 2005)

Suggested funding reform principles for single-employer pension plans (February 2005)

paper [88]
news release [89]

Comments on proposed IRS regulations for phased retirement [90](Feb. 8, 2005)

Principles of Pension Funding Reform [91] for Multiemployer Plans(January 2005 issue brief)

Comments on a delay of amortization relief [92] under IRC 412(e) (Jan. 28, 2005)

2004

Pension Committee comments to the ASB on a proposed pension valuation [93] standard (October 2004)

Letter to IRS on proposed changes to ERISA regulations [94] (September 2004)

Paper on current funding and accounting fundamentals [95] for private-sector pension plans (July 2004; updates the February 2004 original)

Comments [96] on an IASB draft interpretation concerning financial reporting for multiemployer plans (July 9, 2004)

Comment letter [97] to FASB about measuring the value of employee stock options (June 30, 2004)

A letter [98] on delaying the effective date of relative value Treasury regulations (May 25, 2004)

A paper [99] on the rules for maximum tax-deductible pension contributions (May 14, 2004)

A letter [100] 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 [101] (April 30, 2004)

Testimony [102] by Ken Kent for a House hearing on pension system reform (April 29, 2004)

A letter to FASB [103] about accounting and disclosure requirements related to the Medicare Modernization Act financial (April 13, 2004)

A letter [104] from the Pension Practice Council to the ASB on a proposed revision of a data quality standard 23 (April 9, 2004)

A letter [105] 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 [106] at aninternational forum [107] on retirement security (March 4, 2004)

Letter [108] to Senate staffers on multiemployer provisions in HR 3108 (March 4, 2004)

Summary [109] of a draft paper on principles for revising pension funding rules (February 2004)

Pension plan funding [110] presentation by Ron Gebhardtsbauer for a briefing sponsored by a congressional steering committee and an industry benefits group (January 2004)

2003

Recommendations [111] on pension plans' using the RP-2000 mortality tables when determining current liability (Dec. 31, 2003)

Letter [112] 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 [113] (December 2003)

Letter [114] again asking Congress to fix the pension discount rate before adjourning (Dec. 5, 2003)

Letter [115] asking Congress to fix the pension discount rate before adjourning (Nov. 20, 2003)

Suggested changes [116] in FASB financial disclosure proposals for pensions and other postretirement benefits (Oct. 27, 2003)

A Letter to Sen. Evan Bayh [117] on his DB pension legislation (Oct. 7, 2003)

Comments to the IRS about a revenue ruling on entry age [118] funding methods (Aug. 18, 2003)

A Pension Committee analysis [119] 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 [120]facing the traditional pension system (July 24, 2003)

A letter to the IRS on concerns [121] about “good faith” compliance for qualified plans (July 2, 2003)

An analysis [122] of proposals to change the discount rate used to determine lump-sum pension benefits (June 17, 2003)

Testimony [123] for a House Education and Workforce subcommittee hearing on pension security (June 4, 2003)

A letter to FASB about cash balance [124] accounting issues (May 23, 2003)

A comment letter to GASB about financial reporting for retiree health plans and other non-pension benefits [125] (May 16, 2003)

Presentation slides [126] for "Taking Pension Funding Into Account," Capitol Hill briefing (May 16, 2003)

Presentation slides [127] for Washington Forum session, "Is Retirement Security Under Fire?" (May 9, 2003)

Testimony [128] for a House Ways and Means subcommittee hearing on pension funding problems (April 30, 2003)

Memo [129]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 [130] (March 26, 2003)

Comment letter to the IRS on proposed age discrimination regulations for non-cash-balance plans [131] (March 26, 2003)

Comment letter to PBGC on calculating withdrawal liability [132] for multiemployer DB plans (March 12, 2003)

Testimony for Senate Finance Committee hearing on funding challenges for DB pension plans [133] (March 11, 2003)

What's Whipsaw? Why Is It a Problem? [134] (February 2003 issue brief)

Letter asking the IRS for guidance on alternative funding relief provisions for multi-employer plans [135] (Jan. 16, 2003)

DB-K Plus: [136] A Defined Benefit Plan With 401(k) Features (issue brief, January 2003)

2002

Letter to the IRS on implementing phased retirement [137] arrangements (Dec. 30, 2002)

Letter to GASB about a proposed accounting standard [138]for post-employment benefit plans (Dec. 13, 2002)

Comment letter to the IRS on proposed rules to eliminate certainoptional forms of benefit payments [139] from DB plans (Oct. 23, 2002)

Statement to IRS on concerns about temporary regulation 1.401(a)9)-6T [140] (Oct. 9, 2002)

Comment letter to FASB on cash balance accounting issues [141] and the prevalence of cash balance plans (Aug. 20, 2002)

Comment letter on areas under IRC Section 412 [142] that lack regulatory guidance or need clarification (Aug. 13, 2002)

Report offering alternatives to the 30-year Treasury rate [143] in determining pension plan funding (July 17, 2002)

Letter to the IRS asking for a public hearing on 401(a)(9)-6T [144](July 16, 2002)

Testimony for House Ways and Means Oversight Subcommittee hearing [145] on retirement security (June 20, 2002)

Comments to the Oklahoma legislature [146] about pending legislation (May 31, 2002)

2001 and earlier

Letter to GASB on a simpler estimation method for small OPEB plans [147](Dec. 20, 2001)

Presentation to GAO employees comparing federal DB and DC pension plans [148] (Dec. 18, 2001)

Proposed technical correctionsto pension provisions in EGTRRA [149] (Oct. 12, 2001)

Request to the Joint Board to extend the deadline for EAs' CE credits [150] (Sept. 21, 2001)

Statement [151] to the ERISA Advisory Council on increasing pension coverage and preparing for retirement, plus presentation slides [152](July 17, 2001)

Statement about the impact of inordinately low 30-year Treasury rates [153]on defined benefit plans (July 11, 2001)

Selecting and Documenting Investment Return Assumptions [154] (practice note, May 2001)

Comments to the Treasury Department on using the RP-2000 mortality table [155]for plan liability determinations (April 27, 2001)

Comment letter about a proposed ASOP [156], "Projected Benefit Illustrations in Connection With Retirement Plan Amendments" (Dec. 8, 2000)

Comment letter on applying anti-backloading tests to multiple benefit formulas [157] (Sept. 14, 2000)

Comment letter on a proposed pension reform commission [158] (July 2000)

Letter to Sen. Harkin about possible cash balance legislation [159] (July 2000)

Comment letter on proposed amendments to SOP 92-6 [160] (June 22, 2000)

Cash balance statement for Senate Special Committee on Aging hearing (June 5, 2000)

PBGC plan termination [161] cost study (May 4, 2000)

"When Your Retirement Plan Changes: Understanding Your Cash Balance Plan" [162] (Q&A, May 2000)

Letter to Sen. Kennedy on pension wear-away legislation [163] (Nov. 8, 1999)

Testimony for Senate hearing on hybrid pension plan coverage [164](Sept. 21, 1999)

Cash balance plans [165] (July 13, 1999)

Testimony on cash balance plans [166] to ERISA Advisory Council (May and June 1999)

Cash balance plans [167] (June 30, 1999)

Testimony to an Erisa Advisory Council working group on employer access to pension surplus [168] (May 5, 1999)

Statement on universal savings accounts [169] (February 1999)

Proposed Statement of Accounting for Social Insurance [170] (Aug. 10, 1998)

Financing the Retirement of Future Generations [171] (1998, No. 1) (455KB)

Comment letter on a proposed modification of the timing of plan valuations [172] (June 22, 1998)

Testimony to ERISA Advisory Council on pension “leakage [173]” (June 9, 1998)

Testimony for House hearing on pension reform [174] issues (June 1996)