Pension Comments and Letters

Pension Committee comments to the Pension Benefit Guaranty Corporation (PBGC) regarding the proposed changes to the §4010 reporting requirements.
(September 25, 2015)

Multiemployer Subcommittee comments to the IRS and Treasury on proposed regulations on suspensions of benefits under the Multiemployer Pension Reform Act of 2014.
(August 19, 2015)

Lifetime Income Risk Task Force comments to the Department of Labor regarding the proposed regulations defining fiduciaries and conflict of interest.
(July 20, 2015)

Pension Committee comments to the IRS regarding the timing for release of the mortality tables under §§430(h)(3) and 417(e) of the Internal Revenue Code for 2016.  (July 17, 2015)

The Financial Reporting Committee, Pension Accounting Committee, Casualty Committee on Property and Liability Financial Reporting, Health Financial Reporting and Solvency Committee, and Life Financial Reporting Committee comments on the Public Company Accounting Oversight Board’s (PCAOB) “The Auditor's Use of the Work of Specialists” consultation paper. (July 15, 2015)

Intersector Group notes of its April 2015 meeting with the Treasury Department and Internal Revenue Service.  (June 2, 2015)

Intersector Group notes of its April 2015 meeting with the Pension Benefit Guaranty Corporation (PBGC). (June 2, 2015)

Pension Committee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (June 1, 2015)

Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on its exposure draft, “Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.” (May 29, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the IRS and Treasury regarding the Request for Information on Suspensions of Benefits under the Multiemployer Pension Reform Act of 2014 (MPRA).  (April 7, 2015)

Pension Practice Council and Multiemployer Subcommittee comment letter to the Pension Benefit Guarantee Corporation regarding the Request for Information on Partitions and Facilitated Mergers under the Multiemployer Pension Reform Act of 2014 (MPRA). (April 6, 2015)

Pension Committee comment letter to the Actuarial Standards Board (ASB) regarding the second exposure draft of the proposed Actuarial Standard of Practice (ASOP) on modeling standards.  (March 1, 2015)

Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 5, 2015)

Pension Committee comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans.
(February 5, 2015)

Pension Practice Council (PPC) letter to Treasury Department regarding the benefits of allowing qualified defined benefit pension plans to provide longevity annuities directly, rather than requiring them to purchase an insurance contract.  (January 14, 2015)

Pension Committee comment letter to the PBGC regarding interpretation of plan provisions governing actuarial equivalence. (January 13, 2015)

Pension Committee comment letter to the IRS regarding the updated final and newly proposed regulations for hybrid retirement plans. (December 18, 2014)

Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Treasury Department and Internal Revenue Service. (November 24, 2014)

Intersector Group notes to the Pension Practice Council from its October 2014 meeting with the Pension Benefit Guaranty Corporation.  (November 24, 2014)

Pension Finance Task Force letter to the Actuarial Standards Board on actuarial valuations and other analyses used for determining public pension and other post-employment plan funding and accounting. (November 15, 2014)