Pension Comments and Letters

Comments on Notice Requirements Under Section 101(j) of ERISA

Pension Committee comments to the Internal Revenue Service regarding notice requirements under section 101(j) of ERISA, as promulgated in Notice 2012-46. (February 5, 2013)

Academy’s Letter to the New York Times Editor On “Social Security: It’s Worse than You Think” Opinion Piece

Academy’s Letter to the New York Times Editor On “Social Security: It’s Worse than You Think” Opinion Piece
(January 9, 2013)

Comments on Proposed Revisions to ASOP No. 25

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 25, Credibility Procedures. (December 28, 2012)

Comments to CAAP Regarding MAFPP Discussion Draft

Comments by Public Plans Subcommittee to the California Actuarial Advisors Panel (CAAP) in response to its discussion draft, Version 9c, Model Actuarial Funding Policies and Practices (MAFPP) for Public Pension and OPEB Plans. (October 3, 2012)

Comments to Moody’s on Proposed Adjustments to Public Pension Plan Data

Pension Practice Council comments to Moody’s in response to its proposed adjustments to public pension data reported by US state and local governments, as discussed in a Moody’s report, Adjustments to US State and Local Government Reported Pension Data. (October 2, 2012)

Comments to FASB on Proposed Accounting Standards Update for Financial Instruments

Pension Accounting Committee comments to the Financial Accounting Standards Board (FASB) regarding its proposed Accounting Standards Update: Financial Instruments (Topic 825) – Disclosures about Liquidity Risk and Interest Rate Risk. (October 1, 2012)

Comments on ASB’s Pension Risk Discussion Draft

Pension Practice Council comments to the Pension Committee of the Actuarial Standards Board regarding its discussion draft, Assessment and Disclosure of Risk Associated with Pension Obligations, Plan Costs, and Plan Contributions. (October 1, 2012)

Comments on Proposed Regulations on Lump-Sum Distributions When Plan Sponsor Files Bankruptcy

Pension Committee comments to the Internal Revenue Service in response to its proposed regulations concerning the prohibited payment option under single-employer defined benefit plans when a plan sponsor is in bankruptcy. (August 20, 2012)

Letter on Implementation of MAP-21 Pension Provisions

Pension Committee letter to Department of Treasury officials regarding the implementation of MAP-21 pension provisions. Attached to the letter is an outline of topics discussed by several Pension Committee members at a meeting with Treasury on July 23. (August 2, 2012)

Letter to Sen. Hatch on State, Local Government Defined Benefit Pension Plans

Pension Practice Council letter to Sen. Orrin Hatch responding to a January 10, 2012 report entitled “State and Local Government Defined Benefit Pension Plans: The Pension Debt Crisis that Threatens America.” (July 31, 2012)

Pension Committee Letter to SOA on Scale BB

Pension Committee letter to the SOA regarding a new set of mortality tables and projection scales for the valuation of uninsured pension plans. (June 30, 2012)

Letter on Proposed Revision to ASOP No. 27

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)

Letter on Proposed Revision to ASOP No. 4

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Letter on Proposed Revision to ASOP No. 4

Pension Finance Task Force comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Comments on Proposed Revisions to ASOP No. 27

Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012)

Comments on Proposed Revisions to ASOP No. 4

Joint Committee on Retiree Health comment letter to the Actuarial Standards Board responding to an exposure draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012)

Letter on Proposed Regulations for Partial Annuity Distribution Options

Pension Committee comments to the Internal Revenue Service on proposed regulations for partial annuity distribution options under defined benefit pension plans. (May 3, 2012)

Letter on Proposed Regulations for Longevity Annuity Contracts

Pension Committee comment letter to the Internal Revenue Service responding to proposed regulations for longevity annuity contracts. (May 3, 2012)

Comments on Pension Funding Stabilization

Pension Practice Council letter to members of the House-Senate Conference Committee commenting on the pension funding stabilization provisions included in S. 1813 as passed by the Senate. (May 2, 2012)

Joint Comments on GASB’s 'Preliminary Views on Economic Condition Reporting: Financial Projections'

Pension Accounting Committee and Public Plans Subcommittee joint comment letter to the Governmental Accounting Standards Board responding to GASB’s Preliminary Views on Economic Condition Reporting: Financial Projections. (April 2, 2012)