RECENT ACTIVITIES
CONGRESSIONAL MATTERS
Congressional Testimony on Social Security
Donald Fuerst, senior pension fellow, submitted written testimony to the U.S. Senate Special Committee on Aging for its hearing on “Bridging the Gap: How Prepared are Americans for Retirement?” Fuerst said “some steps have been taken to improve retirement security, but workers, retirees, and society could benefit from further actions that aid people in creating assured, adequate income throughout their retirement years.”
Social Security Hearing Responses
Janet Barr, former chairperson of the Academy’s Social Security Committee, responded to questions from members of the Senate Committee on Finance following its hearing on “Social Security: Is a Key Foundation of Economic Security Working for Women?” on Jan. 15. Read the original written testimony and news release, or watch the full hearing video. A story in The Motley Fool expanded on Janet Barr’s testimony. The article builds on three key points made in Barr’s testimony: 1) Women are more likely than men to have gaps in employment or never to have entered the workforce at all; 2) Women’s average earnings are lower than men’s; and 3) Women tend to live longer than men. Barr’s testimony was also covered in recent stories in Examiner.com, The Daily Caller, Benefits Link, and an AdviceIQ column.
REGULATORY MATTERS
Multiemployer Meeting with PBGC
The Multiemployer Subcommittee met on March 18 with the Pension Benefit Guaranty Corp., along with officials from the Department of Labor and Treasury Department, regarding forthcoming guidance on the Multiemployer Pension Reform Act.
Comments to IRS on Mortality Tables
The Pension Committee sent a comment letter on Feb. 5 to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. The committee recommended that pension plans should be using up-to-date mortality assumptions and best practices where possible, but that smaller plans should have alternatives available in order to simplify administration and valuations where the cost of the application of more sophisticated methods may not be justified.
Comments to IRS on Pension Plan Funded Status
Also on Feb. 5, the Pension Committee sent a comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans. The committee is generally supportive of the aims of IRC §436, but believes it is unnecessarily cumbersome in some respects and could be made easier to administer.
Comments to Treasury on QLACs
The Pension Practice Council sent a letter on Jan. 14 to the Treasury Department regarding the advantages of allowing qualified defined benefit pension plans to provide longevity annuities directly, rather than requiring them to purchase an insurance contract.
Comments to PBGC on Actuarial Equivalence
On Jan. 13, the Pension Committee sent a comment letter to the PBGC regarding interpretation of plan provisions governing actuarial equivalence. The committee believes the PBGC is interpreting plan provisions governing actuarial equivalence in a manner that results in benefits that are not actuarially equivalent. The PBGC responded to the letter, stating that a misunderstanding exists on “PBGC’s position regarding late retirement actuarial adjustments in a situation where a plan provides a 100% pre-retirement death benefit.” Furthermore, PBGC states, “The mere presence of the term ‘actuarial equivalence’ does not preclude a plan from using a methodology that results in benefits larger than the minimum benefit required by ERISA” or in this case, larger than what the Pension Committee considered the actuarial equivalence.
PROFESSIONALISM MATTERS
Comments to ASB on Modeling Standards
The Pension Committee sent a comment letter to the Actuarial Standards Board on March 1 regarding the second exposure draft of the proposed actuarial standard of practice on modeling standards. The committee specifically commented on three primary areas of concern with the proposed standard—scope, clarity, and interaction with other standards. |