By Eli Greenblum
As this issue of Contingencies goes into distribution, the world’s biggest tournament in sports will just be a month away. From June 11 through July 19, the World Cup of soccer (“football” everywhere except in the United States, Canada, and a few other English-speaking nations—to distinguish it from other forms of “football” popular in those areas) men’s tournament will feature 104 matches involving 48 national teams (expanded from 32 in 2022), hosted by the three major North American countries in 16 cities, including 11 in the United States.
The World Cup is sponsored by FIFA, the Fédération Internationale de Football Association. The only other time the United States hosted the men’s tourney was back in 1994, when I was privileged to see nine matches in Washington, D.C., New York City, and Boston. There has been a major upsurge in domestic interest since then; for example, we’ve gone from having no top-tier men’s professional league to 30 Major League Soccer teams in the United States and Canada. Further evidence of this growth is how much harder—and expensive—it is to obtain match tickets this time. I am shooting for at least seven matches this time, if not to equal my 1994 total.
Non-soccer fans in the United States point to two main barriers to interest, beyond fierce competition from the other major sports: low scoring (but is a 3-1 result any different from a 21-7 football score?) and not understanding the rules (formally known as the “Laws of the Game”). While it is really a simple game—get the ball into the goal net without using arms or hands—many point to the offside rule as the primary difficulty preventing enjoyment of the nearly constant action.
What constitutes offside in soccer? At the instant the ball is passed to you by a teammate, two (or more) opposing players must be closer to the goal line you are attacking (one, usually the goalkeeper) —otherwise, you are offside. Note that it does not involve your position when you receive the pass. Of course, there are some exceptions to when this offside rule is applicable: for example, on throw-ins; when the pass-receiving player is in their own half of the field; or when they are “behind the ball” when it is passed. Okay, it is still a bit complicated, compared to hockey or American football offside rules, which involve players crossing a fixed blue or scrimmage line, respectively.
Actuarial Offside: Staying Qualified and Onside
“Thanks for the brief tutorial,” you might be thinking, “but why would this be in a Contingencies article?” The answer is because the actual topic is actuarial offside: How does one determine that? In our largely self-governing profession, it is crucial for us to remain mindful of our obligations. First and foremost, we need to maintain our credentials in whichever of the five U.S.-based actuarial organizations are relevant to us. After achieving initial admission criteria, this is generally accomplished by paying annual dues and attesting that we meet other ongoing requirements. Chief among those annual obligations is compliance with U.S. Qualification Standards (USQS), in order to issue any statement of actuarial opinion (SAO). These standards include satisfying basic education and experience requirements, specific qualification standards for those signing an NAIC opinion, and continuing education (CE) requirements. As to the latter, actuaries are required to earn a minimum of 30 annual CE hours, including three hours on professionalism topics, one hour on bias topics, and six hours on organized activities.
Staying onside also means adhering to the many actuarial standards of practice (ASOPs) that guide the work we do in all areas of the profession, and—perhaps most important—not violating the Code of Professional Conduct (the Code), which contains 14 precepts. For U.S. actuaries, the Code requires compliance with both the USQS (Precept 2) and applicable ASOPs (Precept 3). To draw an analogy to soccer, you must know your position when first accepting an actuarial assignment: You must be qualified for the task at hand, and you cannot expect to “play into form” or learn enough to become qualified as you proceed with it.
Private-sector pension plan actuarial certifications of annual funding and Pension Benefit Guaranty Corporation premium requirements are exceptions to the self-regulating regimen. These are governed by the Joint Board for the Enrollment of Actuaries (JBEA) under the U.S. Treasury Department. To stay onside, enrolled actuaries must renew enrollment every three years, by answering a few questions (e.g., did you timely file your federal income taxes?) and attest to meeting somewhat different CE requirements—with a clear possibility of having that CE attestation audited.
Enforcement and Guidance:
The ABCD and VAR Analogy?
How is the offside rule enforced?
In soccer, the rule is actively monitored by assistant referees (aka linesmen), the guys or gals running up and down each sideline with flags, which they point across the field to signal offside. Video Assistant Referee (VAR) technology and staff help referees and assistants confirm rulings in certain circumstances. For example, VAR determines whether an offside occurred whenever a possible goal was scored. To do that, VAR officials (who are qualified referees) in an offsite facility determine the exact instant the ball leaves the passer’s foot and then use technology to place an on-screen offside line where the second-most deep defender is positioned to see if it was breached by a pass-recipient at that moment.
VAR technology wasn’t incorporated into the World Cup until 2018. Before that, the referee’s on-field ruling was final. A similar technology is also used to determine whether the ball has completely crossed the goal line into the net. VAR is used in other matters, such as possible expulsion for serious misconduct (red cards), fouls committed in course of actual/potential goal-scoring, and penalty kick awards. VAR is advisory-only; the game referee decides after viewing any suggested footage provided by the VAR officials. Yes, VAR causes delays and hiccups in game continuity, leading to aborted or delayed goal celebrations. While once controversial, all major leagues and tournaments now use it.
What about actuarial offside—how is it enforced?
While we don’t have a precise means of detection akin to VAR offside or goal-line technology, the five U.S.-based actuarial organizations have determined that possible “offside” violations—generally related to the Code—should be handled, at least initially, by the Actuarial Board for Counseling and Discipline (ABCD) as an essential part of our self-regulating regime. Is this body equivalent to soccer referees for the U.S. actuarial profession, or more like VAR?
Formal complaints can be lodged by actuaries under Precept 13, or by the principals and clients we serve. In my experience, complaints are often initiated by a successor actuary, or one hired to review the actuary’s work. The ABCD follows a well-defined investigative and deliberative process, which takes a lot longer than a VAR review! After a complaint goes through initial and secondary reviews, a subject actuary deemed to have committed a possible material violation is entitled to an in-person hearing before the full board.
The result of an ABCD hearing may be formal guidance, counseling, or various forms of discipline. While the latter—ranging from a private reprimand to expulsion—can be recommended by ABCD, only the actuarial organizations of which the actuary is a member (the ultimate referees) impose discipline—after their own review of the ABCD proceedings, and possibly their own hearing. So, perhaps the ABCD functions more like VAR’s advisory role with respect to possible red cards (expulsion being the harshest form of discipline in both environments), rather than like our on-field referees.
Another important ABCD role is the handling of requests for guidance (RFGs); here, an individual ABCD member provides confidential consultation and advice to help an actuary work through any concerns involving their obligations under the Code. The ABCD stands ready to assist, responding to more than 100 requests per year. No such consultation is available to help a player avoid being offside in soccer!
On the new ABCD website (abcdboard.org), actuaries can learn more about the ABCD, submit an RFG, or learn how to file a complaint involving alleged violations of the Code. The website also includes resources such as informative prior “Up to Code” columns from Contingencies and information on the ABCD’s structure, jurisdiction, and processes, including how to request a professionalism speaker at actuarial events. Check it out, and don’t miss the opportunity to see World Cup—either in person, at a Fan Festival in the host cities, or on TV. Visit fifa.com for full details about the World Cup.
Special Note for Enrolled Actuaries
Of special note for enrolled actuaries, given the new three-year enrollment cycle starting in 2026:
If you were not renewed by March 31, 2026, you’re offside (subbed out of the team?) and are prohibited from using the enrolled actuary (EA) credential; you must wait until the JBEA confirms renewal to resume use of the EA. As mentioned above, there are separate compliance and suspension rules in play—be sure to file your federal taxes!
ELI GREENBLUM is a member of the Actuarial Board for Counseling and Discipline, and previously served as an officer on the boards of the American Academy of Actuaries and the Conference of Consulting Actuaries. He retired in June 2024 as senior vice president and actuary for Segal, based in the Washington, D.C. office. He has over 40 years of managerial and actuarial consulting experience serving multiemployer, single-employer, and public-sector clients.