Pension Comments and Letters

Letter to IRS on Proposed DB Benefit Restrictions under IRC Sections 430(f) and 436

Pension Committee letter to Internal Revenue Service (IRS) commenting on proposed benefit restrictions for defined benefit (DB) pension plans under Internal Revenue Code Sections 430(f) and 436. (November 5, 2007)

Letter to House Committee Requesting Technical Corrections on Pension Protection Act

Pension Practice Council and Pension Committee letter to the House Ways and Means Committee requesting technical corrections to clarify aspects of the Pension Protection Act. (November 5, 2007)

Letter to JBEA on Audits of Enrolled Actuaries' CE Filings

Pension Committee letter to Joint Board for the Enrollment of Actuaries (JBEA) requesting the JBEA provide a summary of key mistakes or problems it has found in audits of enrolled actuaries CE filings. (September 3, 2007)

Letter to CASB on Harmonization Survey of Cost Accounting Standards with PPA

Cost Accounting Standards Task Force response to the Cost Accounting Standards Board (CASB) regarding a survey on harmonizing two cost accounting standards with provisions of the Pension Protection Act. (September 3, 2007)

Letter to Treasury Department on Method for Applying Anti-Backloading Rule to Cash Balance Plans

Pension Committee letter to the Department of the Treasury requesting that Treasury reconsider its method for applying an anti-backloading rule (the four-thirds rule) to cash balance plans. (September 3, 2007)

Letter to Texas Officials Clarifying Comments on OPEB Accounting Standards

Joint Committee on Retiree Health letter to Texas officials about misinterpretations of the committee's 2006 comments on accounting standards for OPEBs. (June 15, 2007)

Letter to Energy Department on Pension Reimbursement Policy for DOE Contractors

Pension Committee comments to the Department of Energy (DOE) on the issues faced by the DOE and its contractors in managing the costs of pension and medical benefits. (May 10, 2007)

Letter to FASAB on Preliminary Views - Accounting for Social Insurance

Social Security Committee comments to the Federal Accounting Standards Advisory Board (FASAB) regarding a preliminary views document on accounting for social insurance. (April 16, 2007)

Letter to IRS on Combined Plan Deduction Limits under Notice 2007-28

Pension Committee comments to the Internal Revenue Service (IRS) regarding changes to the combined plan deduction limit under IRS Notice 2007-28. (March 1, 2007)

Letter to IPSASB on Exposure Draft 31, Employee Benefits

Public Plans Task Force letter to the International Public Sector Accounting Standards Board (IPSASB) regarding Exposure Draft (ED) 31, Employee Benefits. (February 28, 2007)

Comments to IRS and Treasury on Substitute Mortality Tables

Pension Committee discussion paper to the Internal Revenue Service (IRS) and Department of the Treasury regarding the use of substitute mortality tables. (November 6, 2006)

Letter to DOL on Proposed Addition of Asset-Related Question to Form 5500

Pension Committee letter to the Department of Labor (DOL) expressing objections to the proposed addition of an asset information question to Form 5500 Schedule B. (September 4, 2006)

Letter to IRS on Requests for Technical Guidance on Circular 230

Pension Practice Council letter to the Internal Revenue Service (IRS) requesting technical guidance on regulatory issues related to IRS Circular 230. (August 29, 2006)

Letters to FASB on Proposed Changes in Financial Accounting Standards

Joint Committee on Retiree Health letters to FASB expressing concern over proposed changes in financial accounting standards for pensions and OPEBs. (May 31, 2006)

Letter to Energy Department on Reimbursing DOE Contractors' DB Pension Costs

Pension Practice Council letter to the Department of Energy regarding its policy to no longer reimburse DOE contractors for costs associated with defined benefit (DB) plans. (May 3, 2006)

Follow-up Letter to GAO on Cash Balance Pension Plans Report

Pension Practice Council follow-up letter to the Government Accountability Office (GAO) regarding a GAO report on cash balance pension plans. (May 1, 2006)

Comments to SEC on Proposed Executive-Compensation Disclosure Rule

Pension Committee letter to the Securities and Exchange Commission (SEC) responding to a proposed executive-compensation disclosure rule. (April 3, 2006)

Letter to Moody's on Proposed Rating Methodology for Companies with Multiemployer DB Plans

Multiemployer Plans Task Force letter to Moody's Investors Service commenting on a proposed rating methodology for companies with multiemployer defined benefit (DB) pension plans. (March 6, 2006)

Letter to FASB on Project to Reconsider Accounting for Postemployment Benefits

Pension Accounting Committee letter to Financial Accounting Standards Board (FASB) regarding a FASB project to reconsider accounting for pension benefits and other postemployment benefits (OPEBs). (February 10, 2006)

Letter to Economist Regarding Article on Defined Benefit Plans

Pension Practice Council Vice-President, Don Segal, letter to the editor of The Economist in response to an article about the problems associated with defined benefit (DB) pension plans. An abridged version of the letter was published. (February 4, 2006)