Retirement Report, Spring 2018
VOL 1 | NO 1
Welcome to The Retirement Report
Welcome to the inaugural issue of The Retirement Report. This quarterly newsletter will replace two Academy publications—Retirement Account and Enrolled Actuaries Report—streamlining pension news into one easy-to-access source for enrolled actuaries and Academy members in the pension and retirement practice areas.
The Academy had a busy April, testifying before a key congressional committee and hosting a lifetime income briefing for congressional staff and media.
Goldman’s testimony outlined the basics of multiemployer plans, noting the 1974 passage of the Employee Retirement Income Security Act (ERISA), and pointing out that fewer workers are currently employed in industries sponsoring multiemployer plans than in the past. He then answered questions from the joint committee’s members on the subject. Watch the full testimony here.
The high-profile hearing—and the Academy’s role in informing the discussion—received national attention: Think Advisor, Plan Sponsor, Plan Adviser, and the Office of U.S. Sen. Rob Portman (R-Ohio)—which stated that the “status quo is unacceptable”—all ran news items on the hearing, as did a Pension Rights Center blog post.
The bipartisan joint committee is made up of 16 members appointed by House and Senate leaders—eight senators and eight House members, equally divided between Republicans and Democrats. Its goal is to draft a bill to address the pension crisis by end of November.
Congressional staff and others attended the April 13 Capitol Hill briefing, “Making Retirement Income Last a Lifetime: Public Policy Options and Practical Tools,” which highlighted lifetime income issues and initiatives. The briefing was co-hosted by the Academy’s Pension Practice Council (PPC) and the Lifetime Income Risk Joint Task Force, the latter of which is a joint task force of the PPC and the Academy’s Life Practice Council.
Panelists released a new quiz to help the public better understand their lifetime income needs, highlighted the Actuaries Longevity Illustrator, and provided an update on education and public policy efforts. Speakers were Noel Abkemeier, co-chairperson of the Lifetime Income Risk Joint Task Force, and Goldman, with Pension Vice President Josh Shapiro moderating. They demonstrated the Actuaries Longevity Illustrator and discussed the Academy’s position statement on the subject.
The Academy hosted a media roundtable immediately after the briefing, providing prominent retirement and pension policy journalists an opportunity to learn about the Academy’s work on lifetime income and retirement security issues.
Writers and contributors to U.S. News and World Report, Kiplinger’s Retirement Report, Bloomberg BNA, and Pensions & Investments participated in the hourlong roundtable with the Academy’s briefing presenters. The conversation delved into a wide range of issues, from legislation proposed in Congress that addresses different aspects of lifetime income needs to the challenges of appropriately limiting employer fiduciary risk and of supporting informed consumer choices of lifetime income options.
Essential Elements Paper Released
Related, the Academy published a new Essential Elements paper, “Income to Last a Lifetime,” highlighting the challenges workers face in planning for the risk that they may live longer in retirement than expected, and outlining public policy approaches to help future retirees secure and manage their lifetime income.
The Essential Elements series is designed to make actuarial analyses of public policy issues clearer to general audiences.
The Academy’s Pension Committee released an issue brief, The Pension Protection Act: Successes, Shortcomings, and Opportunities for Improvement, which looks at the Pension Protection Act of 2006 (PPA) and its subsequent amendments against the principles discussed in an Academy paper from 2005 on pension funding reform.
The new issue brief suggests several modifications to funding rules to bring them into closer alignment with the principles, thereby improving the PPA’s effectiveness in promoting pension plan solvency over the long term.
Pension Committee Chairperson Ellen Kleinstuber covered the issue in a session at the Enrolled Actuaries Meeting in April (see story, this issue).
Academy Senior Pension Fellow Ted Goldman gave two presentations to two actuarial clubs this spring on the topic of retirement readiness.
His May 10 interactive presentation at the spring meeting of the Middle Atlantic Actuarial Club in Columbia, Md., focused on the report, Retirement Readiness: A Comparative Analysis of Australia, the United Kingdom, and the United States, published last October by the Academy, the Institute and Faculty of Actuaries (U.K.), and the Actuaries Institute of Australia; after its release, the report was the topic of a well-attended Academy webinar on retirement issues in the three countries. Goldman discussed how the changing social, demographic, and economic landscape has transformed retirement expectations; the strategies and level of success of accumulating wealth to prepare for retirement; and the ability of individuals to consider and plan for the unexpected events that may occur during retirement.
Goldman also gave a presentation May 22 at the Actuaries Club of Hartford and Springfield in Hartford, Conn. He shared the main findings of the survey, including how the changing social, demographic, and economic landscape has transformed retirement expectations; the strategies and level of success of accumulating wealth to prepare for retirement; and the ability of individuals to consider and plan for the unexpected events that may occur during retirement.
The Academy’s new Lifetime Income Quiz poses questions to the public that provide insight into issues in planning for retirement income, a better understanding of key concepts, and choices that people may face in deciding how to convert savings into lifetime retirement income. Quiz takers are asked to test their knowledge, will receive an overall score, and can download informational materials developed by the Lifetime Income Risk Joint Task Force.
More resources are available on the Academy’s Lifetime Income Initiative webpage. The Academy hosted an April 13 Capitol Hill briefing on lifetime income, in part to draw attention to the Academy’s position statement on lifetime income, and released a new Essential Elements paper on the subject (see story, this issue).
Extra-early registration rates run through Friday, June 8, for the Academy’s 2018 Annual Meeting and Public Policy Forum, to be held Nov. 1–2 in Washington, D.C., just prior to the 2018 mid-term elections.
Preliminary pension session topics include multiemployer pension reform, evaluating guaranteed benefits, and lifetime income issues.
This highly focused meeting and policy forum provides attendees with multiple opportunities to engage with policymakers, business leaders, actuaries from all practice areas, and Academy leaders. Political analyst Charlie Cook of the Cook Political Report will be among the keynote speakers. Prices will increase after June 8—register today and save.
If you are an actuary interested in learning more about the public policy aspects and implications of our profession’s work, make plans to join us for the one event that consistently delivers in-depth presentations from recognized experts on the top public policy and professionalism issues relevant to you, your work, and our profession. And, as usual, we will have some unusual and fun entertainment at our festive dinner between the two days of meetings.
Join us in November—register today to take advantage of our deeply discounted extra-early rate.
The Actuarial Standards Board (ASB) approved exposure drafts of revisions of Actuarial Standard of Practice (ASOP) Nos. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions; 27, Selection of Economic Assumptions for Measuring Pension Obligations; and 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations.
The proposed revisions are based on suggestions from the Pension Task Force report issued in 2016 as a result of the extensive public comments received on a 2014 Request for Comments on ASOPs and Public Pension Plan Funding and Accounting, as well as a subsequent widely publicized 2015 public hearing, where those who wished to give in-person testimony to the ASB offered comments as well.
The comment deadline for the current exposure drafts is July 31, 2018. Information on how to submit comments can be found in the drafts, which can be viewed here. All comments are welcome, and participating in the comment process is encouraged. As earlier commenters will recognize, proposed new or revised ASOPs are always put out for public comment, and Appendix 2 of the ASOPs contains summaries of comments submitted within the exposure period and the resulting responses and revisions made to drafts by the ASB as a result of comments received.
New Issue Briefs Released on
Academy pension committees released two issue briefs in early May, one on multiemployer pension plans and one on Social Security.
Loan Programs for Underfunded Multiemployer Plans, published by the Multiemployer Plans Committee, notes that certain loan programs for troubled multiemployer plans have the potential to help preserve participant benefits and improve the financial condition of the plans. The brief points out that loans would incur a cost to the government if they charge plans an artificially low interest rate, and there will be additional costs if plans are ultimately unable to repay the loans.
Social Security—Automatic Adjustments, released by the Social Security Committee, notes that since the 1980s the Annual Report of the Board of Trustees of the Federal Old-Age and Survivors Insurance and Federal Disability Insurance Trust Fund has consistently indicated a need for corrective legislation to avoid a shortfall in the amount needed to pay all promised benefits in the future. While Congress has been reluctant to pass any corrective legislation because it would require potentially unpopular payroll tax increases or benefit decreases, even if action is taken, actual experience will diverge from the demographic and financial assumptions and a shortfall could again develop.
Academy President Steve Alpert, a pension actuary himself, gave an opening address at the meeting, citing major changes in the past year including the new tax-reform law and congressional proposals to improve retirement security. He noted the Academy’s work in the retirement area in the past year included a position statement on lifetime income, and a comparative analysis paper on retirement readiness in the U.S., U.K. and Australia, produced jointly with the Institute and Faculty of Actuaries (U.K.) and the Actuaries Institute of Australia.
The meeting—sponsored by the Academy and the Conference of Consulting Actuaries—included a number of well-attended interactive sessions featuring presentations from Academy volunteers, including Pension Practice Council Vice President Josh Shapiro, who moderated a multiemployer plans session; and Pension Committee Chairperson Ellen Kleinstuber, who presented on the Academy’s new issue brief on the seven principles of pension funding that was released just prior to the meeting (see story, this issue).
In the spirit of springtime in Washington, the Academy’s exhibit drew many visitors with a fun photo booth offering free photos of attendees letting their hair down with a backdrop of the capital’s renowned cherry blossoms. Curtis Harris, principal of pension actuarial firm Harris Resources, won the Academy’s photo contest as voted by attendees, an Academy EA “superhero” posing as a Batman-like figure with the D.C. backdrop.
‘Talking Risk’ Plenary Session
ASB session panelists Dixon, Kausch, and NobleThe opening plenary session on April 9, “Talking Risk,” featured Frank Todisco, chief actuary with the U.S. Government Accountability Office and immediate past vice chairperson of the Actuarial Standards Board (ASB), who gave a brief overview of the development of Actuarial Standard of Practice (ASOP) No. 51, Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions, and looked at several aspects of that ASOP.
The ASB and Pension ASOPs
The exposure drafts are seeking comments from all those interested in order to provide the profession and the public the opportunity to continue to participate in the development of these proposed standards.
Alpert participated in an a lively plenary session on ethics on April 10, in which the panel offered hypothetical situations (based in part by actual events) that raised ethical questions and from which they took input from meeting attendees. The panel also included David Godofsky, Deborah Tully, and Margaret Berger, a vice chairperson of the Academy’s Pension Practice Council and a member of the ASB’s Pension Committee.
In one case regarding questionable gift-giving among the example parties, Alpert noted that both were identified as credentialed actuaries and, regardless of what organization they belong to, were subject to the same Code of Professional Conduct. “If something sounds shady, it means that it probably is—especially if it were splashed on the front page of a newspaper,” he said.
‘Life (Expectancy) Isn’t Always Fair’
The concluding plenary session on April 11, “Life (Expectancy) Isn’t Always Fair,” featured Stephen Goss, chief actuary of the Social Security Administration (SSA) and the 2013 recipient of the Academy’s Robert J. Myers Public Service Award; Steve Vernon, a research scholar at the Stanford Center on Longevity; and Amy Kessler, with Prudential Retirement.
At the session, which was moderated by Academy Senior Pension Fellow Ted Goldman, the panelists looked at everything from SSA tables to income, education, health, and race/gender aspects of mortality and longevity, noting the average lifespan jumped from about 47 in 1900 to 78.8 in 2014. Kessler noted that significant medical advances are on the near-term horizon, including such things as gene editing, stem cells to grow organs, and artificial organs.
The meeting included a host of breakout sessions covering a range of topics of interest to pension and enrolled actuaries. Following are summaries of some key sessions.
The “Late-Breaking Deployments” session provided updates on regulatory items that have come out in the past 12 months. Panelists were Eric Keener, chairperson of the Academy’s Retirement System Assessment and Policy Committee; Kent Mason, a partner at Davis & Harman LLP; Michael Pollack, senior consultant at Willis Towers Watson; and IRS officials Carolyn Zimmerman and Linda Marshall.
“One important thing to note with respect to contribution risk is that the actuary is not required to assess the likelihood or capability that the plan sponsor makes the contributions that they’re supposed to make,” Mason noted. Pollack then talked about the substitute mortality rules, which were mostly unchanged from the proposed regulation.
Regarding automatic approvals, Pollack mentioned the issue of change in data elements, stating that although “many actuaries might not have viewed data elements as a part of [the] funding methods, if you make these types of changes, that’s a change in the funding method.” The panel wrapped up with PBGC and multiemployer updates, including an update of the fiscal year 2016 PBGC projections report for the single-employer program, which stated that by 2026, the program is projected to likely have a surplus of $9.6 billion.
Funding Method Changes Under the New Guidance
In the “Funding Method Changes under the New Guidance” session, panelists looked at the new revenue procedures that provide automatic approvals for some method changes for single-employer plans and revised procedures for requesting approvals for all plans covered by ERISA. The speakers were James Holland, chief research actuary at Cheiron; Susan Breen-Held, member of the Academy’s Pension Committee; Tonya Manning, co-chairperson of the Academy’s Lifetime Income Risk Joint Task Force; and Carolyn Zimmerman with the IRS.
Holland stated that IRS Revenue Procedure (Rev. Proc.) 2017-56 clarified that Rev. Proc. 2000-40 is no longer applicable to single-employer plans and that it provides similar automatic approvals for certain changes in funding method. He stated that Rev. Proc. 2017-57 provides procedures for obtaining approval for a change in funding method including revocation of certain interest rate elections. Panelists then discussed the definition for funding method, automatic approvals, and the approval process for automatic approvals.
Manning highlighted that Rev. Proc. 2017-57 defines funding method as “the method used to determine minimum funding, which includes the overall cost method (assets and liabilities), each specific method of computation and each data element.” She also underscored that there were “no big new revelations conceptually in these updated revenue procedures versus what we already knew from the old ones.” She also added that although “Rev. Proc. 2017-57 did not change the concept, it did change the details.”
Kleinstuber—who gave an in-depth interview on the subject in the March Enrolled Actuaries Report—offered background on the Academy’s new issue brief, The Pension Protection Act: Successes, Shortcomings, and Opportunities for Improvement, a follow-up to the PPC’s February 2005 paper on the subject. The original paper identified seven principles (solvency, predictability and hedgeability, incentives to fund/flexibility, avoidance of moral hazards, transparency, simplicity, and transition), acknowledged that some of the principles were inherently contradictory and thus must be balanced, and identified that reform could either be incremental or comprehensive. The new paper reviewed the PPA against the seven principles from the original paper and offered suggestions of possible improvements and changes.
Geddes followed up with a detailed overview of the principles, and Kleinstuber finished with a discussion of the proposals for improvement, enhancing contribution predictability, and reducing regulatory burden. Attendees were invited to share their thoughts on the subject, with one offering that “the problem with [defined benefit] plans is that they’re becoming too complicated and we need to simplify them to survive.”
Dialogue With the Joint Board
The “Dialogue With the Joint Board” session was intended to provide participants with updates on the work that the Joint Board for the Enrollment of Actuaries (JBEA) was undertaking, such as pointers for successfully preparing an application for initial enrollment, navigating an audit of continuing education, complying with the regulations that govern enrolled actuaries, and disciplinary issues. The session also included an opportunity for interested actuaries to ask questions relating to the issues discussed. Panelists were Chet Andrzejewski with the U.S Department of Labor and chair of the JBEA; Susan Breen-Held, member of the Academy’s Pension Committee; and David Ziegler of the IRS.
Andrzejewski began by noting the JBEA consists of five voting members who serve rotating three-year terms. He introduced the JBEA’s new executive director, Thomas Curtin.
He then proceeded with a discussion about enrollment renewals, giving examples of core and noncore credits. He noted that examples of noncore credits were economics, investment and finance, and general tax law. One attendee asked whether a moderator could receive credits because of the preparation necessary to moderate a panel, and Andrzejewski said that while there was nothing in the regulations that stated that moderators could not receive credit, they would need to prepare substantially. The session wrapped up with a discussion of some of the audit issues the JBEA is dealing with and how individuals could avoid making these mistakes if audited.
Plan Termination—Tricks and Traps
“Plan Termination—Tricks and Traps” was intended to provide participants with tips to smooth the process of plan terminations and traps to avoid them. The panel included Harold Ashner from Keightley & Ashner LLP; Hilja Viidemann, senior consultant at Conduent; and Bela Palli, manager of the Pension Benefit Guaranty Corporation’s (PBGC) standard termination compliance division.
The session opened with an overview of a standard plan termination, how to prepare for and complete a smooth termination process, PBGC and IRS requirements, and typical “traps” and “tricks” for dealing with them. Viidermann offered details about planning a standard termination where she highlighted that actuaries would first need to check whether there were any collective bargaining agreement bars to termination, and if not, then the actuary would need to determine who had “settlor” authority for a decision, then to document it.
It concluded with a discussion where it was noted that the only way for an underfunded plan to terminate voluntarily was through a distress termination. Panelists highlighted that each controlled group member must meet at least one of the following tests for a distress termination: liquidation in bankruptcy/insolvency; reorganization in bankruptcy; inability to continue in business; or unreasonably burdensome pension costs.
PBGC—Update and Dialogue for Single-Employer Plans
The “PBGC—Update and Dialogue for Single-Employer Plans” session included a panel of representatives who provided an overview of recently published board guidance and program operations, and offered tips, hints, and other information about various PBGC programs. Moderated by Breen-Held, the panelists were PBGC officials Amy Viener, acting chief policy actuary; Kristina Archeval, senior adviser of the corporate finance and restructuring division; and Anne Henderson, senior adviser for external affairs.
They opened with discussion about the Pilot Mediation Program Overview, which began in 2017 and was intended to offer mediation during settlement negotiations. It was noted that only cases from the Termination Liability Collection and the Early Warning Programs would be eligible for inclusion in the pilot. The panel also discussed the PBGC’s new pre-filing consultation, which is a discussion with sponsors and advisers about whether a distress filing is appropriate. Also discussed were reportable event updates, the missing participants program, and 4010 filling tips. The session finished with panelists noting that the best way to get feedback from the PBGC on any of the discussed issues was to reach out through its website.
Dialogue with IRS/Treasury
The “Dialogue with the IRS/Treasury” was an opportunity for actuaries to ask questions relating to the work the IRS has been doing on various pension-related matters. The panel was moderated by Tonya Manning, co-chair of the Academy’s Lifetime Income Task Force, and included Harlan Weller of the U.S. Department of the Treasury, and Linda Marshall and Carolyn Zimmerman of the IRS.
Zimmerman shared that the preapproved program had been expanded for those who use the program, while she also noted that the IRS had issued a notice asking for comments for those using individually designed plans.
Manning then opened up the discussion to audience questions, with one asking if there was a chance of getting final regulation on the 414 regs. Harlan shared that they were aware of the fact that the proposed regulation “didn’t work well in the 21st century” and although there has been some attention directed at the issue, he was hesitant to say where it would go. Harlan also asked the audience to share any fact patterns that Treasury should be aware of on the issue. The session continued with questions about closed plans, when spinoffs were considered a funding method change, and whether the agencies were currently looking to fill actuarial positions.
DC Plans Issues When Combined With DB Plans for Testing
In the session “DC Plans Issues When Combined with DB Plans for Testing,” speakers Richard Block, who is currently chairperson of the Actuarial Board for Counseling and Discipline, and Kevin Donovan, president of Pinnacle Plan Design, explored issues that arise when defined contribution (DC) plans are combined with defined benefit (DB) plans for testing. The presentation addressed topics such as benefits rights and features, coverage, gateway, top-heavy minimums, plan deduction limits, and other relevant issues when designing DC plans.
Block and Donovan outlined key requirements for aggregating both types of plans, highlighting issues actuaries should be mindful of. They also detailed DC plan provisions, such as 401(k) safe harbor plans, and provided insight into a full range of plan features, including comparability of benefits, eligibility criteria, normal retirement age, vesting, allocation eligibility, deductibility, and top paid group election.
The presentation also included examples of issues that might arise of that actuaries should consider in each of these features when plans are combined for testing. In addition, they shared some of their personal experiences combining DC and DB plans for testing, offering examples of issues that they had encountered in their own careers.
The two concluded with a reminder that actuaries should never make assumptions when aggregating DC and DB plans for testing. They also reminded the audience that clients can be forgetful, and may fail to provide actuaries notice of important plan features or changes to plans.
Variable Annuity Plans: Funding
Speakers Bruce Cadenhead, an Academy Board member and vice chairperson of the Pension Committee, and Lloyd Katz, management partner at The Benefit Practice, blended practice and theory in their discussion of accounting issues for variable annuity plans (VAPs). The session provided a comprehensive overview of VAPs, an explanation of how they work, and their significant features. In addition, the session provided detailed descriptions of VAP valuation and plan design possibilities, and addressed uncertainties in interpreting regulations governing VAPs.
Cadenhead and Katz also provided a variety of hypothetical scenarios to demonstrate accounting issues for VAPs. Speaking about one particularly exaggerated scenario—in which Congress passes a “No More Annuity Schemes” (“No MAS”) act that requires all plans to be fully funded immediately, and mortality is no longer a factor (because individuals are living forever)—Katz remarked, “Examples are always great when you can make them up and choose whatever you want to make them!” They also highlighted regulations governing VAPs that may be vague and difficult for actuaries to interpret.
This and other scenarios prompted engaged discussion and questions from the audience. The two noted that the questions about—and range of interpretations of—different scenarios indicated that answers to questions actuaries may have about assumptions and accounting methods for VAPs are not always clear-cut and are open to interpretation. They emphasized that actuaries should be thoughtful about determining the “best” or “safest” valuation methods and plan designs.
Making Retirement Assets Last a Lifetime: The Next Big Actuarial Challenge
In “Making Retirement Assets Last a Lifetime: The Next Big Actuarial Challenge,” Ted Goldman, the Academy’s senior pension fellow; and Steve Vernon, research scholar at the Stanford Center for Longevity, discussed the challenges Americans face in ensuring their retirement income will last as long as needed.
Goldman, noting that “lifetime income is becoming one of the most, if not the most, critical issues for retirement security,” highlighted recent Academy publications and tools, including the lifetime income position statement, the Actuaries Longevity Illustrator developed with the Society of Actuaries, last year’s report published by Academy in conjunction with the Institute and Faculty of Actuaries in the U.K. and the Australian Actuaries Institute and a well-attended Academy webinar on the subject following the report’s release, and the newly introduced Academy Lifetime Income Quiz.
Goldman and Vernon followed their presentations with audience Q&A. Questions touched on issues such as encouraging employers to provide DC plans with structured withdrawal programs, tools to help near-retirees with only minimal savings, and concerns about oversimplifying Social Security withdrawal strategies for individuals who might not be likely to live until 70.
More Than One Right Number
Based on a July 2017 Academy issue brief, the session “More Than One Right Number—Explaining Multiple Liability Measures” offered valuable insights about how different measures of liability can provide a more complete picture.
Tim Geddes, Bill Hallmark, Tim Leier, and Yubo Qiu were the speakers. Geddes, an Academy board member, spoke on corporate plans and the issue brief, Assessing Pension Plan Health: More Than One Right Number Tells the Whole Story, noting that it explored the rationale for providing multiple figures and how those figures might be put to use.
Leier, who was on the Pension Practice Council last year when the issue brief was released, spoke on Social Security and multiemployer plans issues, and Qiu talked about economic value and forecasting issues. Hallmark, former Academy vice president, pension, wrapped up the session with a discussion on the public sector.
Valuation of Lump Sums for Accounting
The “Valuation of Lump Sums for Accounting” session looked at issues related to a forthcoming Academy practice note on the subject. Panelists were Bruce Cadenhead, an Academy Board member and vice chairperson of the Pension Committee, and Aaron Weindling, a member of the Pension Committee and a 2017 recipient of the Academy’s Outstanding Volunteerism Award. The practice note is likely to be released this summer.
The session’s background, leading up to the practice note, included issues such as the emergence of alternative accounting methods, which spotlights the importance of projected benefits payments; and that lump-sum payment options (including timing and amount) can significantly alter projected benefit payments. The two looked at valuation paradigms for lump sums; interest rate fundamentals; approaches to valuing interest-sensitive lump sums; determining interest cost; and other related issues.
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