Pension Comments and Letters

Pension Committee comments to the Internal Revenue Service (IRS) on proposed regulations for measuring pension assets and liabilities. (March 3, 2008)

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)

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)

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)

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)

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)

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)

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)

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)

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)

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

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)

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)

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

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

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)

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

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

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)

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)