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Pension Committee

The committee's purpose is to bring to the public and the United States actuarial profession expertise regarding public and private retirement plans. Within the scope of this mission, the committee:

Provides independent and objective analysis, advice, and education to stakeholders of public and private retirement plans with respect to:

Funding
Financial reporting
Managing financial risks
Plan design

Actively consults with public policymakers about the effects of legislation and regulations on retirement benefits.
Identifies emerging issues affecting retirement benefit plans.
Comments on pending retirement legislation and regulations.
Coordinates with other Academy committees where appropriate on issues with overlapping interests.
Develops practice notes for the membership.
Comments on actuarial standards of practice related to public and private plans.

Staff liaison: William Applegate

Chairperson:Grace Lattyak
Vice Chairperson: Lloyd Katz
Michael Antoine
Michael Bain
Rachel Barnes
Margaret Berger
Steven Bull
James Burke
Maria Carnovale
Tristan Christ
Jonathan de Lutio
C. David Gustafson
Scott Hittner
Maria Kirilenko
Edward Law
Gerard Mingione
Maria Moliterno
Nadine Orloff
Mary Stone
Thomas Swain
Hal Tepfer
Carolyn Zimmerman

Related Publications

Pension Committee Releases Major Issue Paper on ERISA

The Pension Committee released an issue paper, ERISA: 50 Years of Shaping the Single-Employer Defined Benefit Landscape. It discusses the broad impacts of The Employee Retirement Income Security Act of 1974 on the retirement landscape, focusing specifically on the single-employer space.

(August 28, 2024 )

RPC Comments to Senate HELP Committee on Self-Employed Workers

The Retirement Practice Council’s Social Security and Retirement Policy and Design Evaluation committees sent a joint comment letter to the Senate Committee on Health, Education, Labor and Pensions regarding portable benefits for self-employed workers and other individuals in nontraditional working arrangements.

(July 03, 2024 )

Council Comments on Defined Benefit Pensions RFI

The Retirement Practice Council and Pension Committee responded to a request for information (RFI) by the majority staff of the U.S. Senate Health, Education, Labor, and Pensions (HELP) Committee regarding ways to bolster the defined benefit pension system.

(May 30, 2024 )

Pension Committee Comments on ASOP No. 12 Exposure Draft

The Pension Committee submitted comments to the Actuarial Standards Board regarding the proposed revision of Actuarial Standard of Practice (ASOP) No. 12, Risk Classification (for All Practice Areas).

(May 01, 2024 )

Pension Committee Comments on ASOP No. 12 Exposure Draft

(May 01, 2024 )

Issue Brief Considers PBGC Single-Employer Premium Structure

The Pension Committee released an issue brief, Aligning the PBGC’s Single-Employer Premium Structure With Its Objectives, which discusses options for modifying the Pension Benefit Guaranty Corporation’s (PBGC) single-employer premium structure to better support the single-employer defined benefit system, while preserving a strong level of retirement security. For more information, read here.

(March 05, 2024 )

Pension Committee Publishes Issue Brief on Church-Sponsored Retirement Plans

The Pension Committee released an issue brief, Church-Sponsored Retirement Plans—Overview and Considerations. This issue brief discusses the broad range of church plans and practices. Among other considerations, it discusses the impact on a participant of being in a church plan when the ERISA protections and provisions for U.S. tax-qualified single or multiemployer pension plans generally do not apply.

(January 24, 2024 )

Committees Comment to PBGC on Valuation Assumptions and Methods

The Pension Committee and Multiemployer Plans Committee responded to the Pension Benefit Guaranty Corporation’s (PBGC) request for comments regarding the proposed rule on Valuation Assumptions and Methods.

(October 17, 2023 )

Committee Comments on Secure 2.0 Reporting and Disclosure

The Pension Committee submitted comments in response to the Department of Labor (DOL) Employee Benefits Security Administration’s (EBSA) Request for Information on a number of SECURE 2.0 provisions that impact the reporting and disclosure framework of the Employee Retirement Income Security Act of 1974 (ERISA).

(October 10, 2023 )

Issue Brief Looks at Pension Plan Design Enhancements

The Pension Committee released an issue brief, Enhancing Retirement Security Through Changes in Plan Design and Related Requirements, that examines modifications to defined benefit (DB) plans that would make them more attractive for modern employers, and looks at ways to incorporate some of the more desirable attributes of DB plans into the more common defined contribution (DC) options that many employers are currently offering.

(September 14, 2023 )

Valuing Gender Expansive Data Issue Brief

Pension Committee issue brief examining issues pension actuaries may consider when performing an actuarial valuation using sex/gender expansive data—data on sex/gender that is either missing or nonbinary.

(August 14, 2023 )

Buy-Out Group Annuity Purchase Primer

Pension Committee issue brief on pension plan sponsor role and considerations regarding “buy-out” annuity contract transactions.

(July 07, 2023 )

Selecting and Documenting Pension Assumptions Other Than Discount Rate, Investment Return, and Mortality

Pension Committee practice note, Selecting and Documenting Pension Assumptions Other Than Discount Rate, Investment Return, and Mortality, updating a 2009 practice note, revised to reflect updated actuarial standards of practice (ASOPs), including changes in ASOP Nos. 27 and 35 that are effective for actuarial reports issued on or after Aug. 1, 2021, and when the measurement date in such reports is on or after Aug. 1, 2021.

(June 21, 2023 )

Comments from Committees on Exposure Draft of Proposed Revision of ASOP No. 27 and Repeal of ASOP No. 35

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the exposure draft of the proposed revision of Actuarial Standard of Practice (ASOP) No. 27, Selection of Assumptions for Measuring Pension Obligations and the repeal of ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations.

(June 16, 2023 )

Practice Note on Modeling for Pension Actuaries

Pension Committee public policy practice note providing background and ideas about how a pension actuary might comply with ASOP No. 56, Modeling.

(January 19, 2023 )

Selecting and Documenting Mortality Assumptions for Pensions

Pension Committee public policy practice note, Selecting and Documenting Mortality Assumptions for Measuring Pension Obligations, updating a 2015 practice note, revised to reflect updated Actuarial Standards of Practice (ASOPs), including changes in ASOP No. 35 that are effective for actuarial reports issued on or after August 1, 2021, and when the measurement date in such report is on or after August 1, 2021.

(January 19, 2023 )

Practice Note on Difficult-to-Value Provisions of Defined Benefit Plans

Pension Committee Practice Note on Measuring Pension Obligations for Difficult-to-Value Plan Provisions.

(December 09, 2022 )

Committee Comments to U.S. House and Senate Leaders on Bipartisan Retirement Legislative Proposals

Comment letter from the Pension Committee and Retirement Policy and Design Evaluation Committee on provisions included in the Securing a Strong Retirement Act of 2022 (SECURE 2.0), the EARN Act, and the RISE & SHINE Act.

(December 07, 2022 )

Cross-Committee Discussion Brief on Actuarial Considerations When Using Augmented Mortality Models

Discussion brief authored by members of Pension, Multiemployer, and Public Plans Committees detailing approaches and complexities of using augmented pension mortality assumptions.

(October 14, 2022 )

Issue Brief on Public Policy Considerations for Funding Rules Proposals

Pension Committee issue brief highlighting key considerations around potential modifications to single employer pension plan funding rules.

(April 20, 2022 )

Issue Brief on Interpreting Pandemic-Related Decreases in Life Expectancy

Pension Committee issue brief explaining complexities involved in the measurement of life expectancy estimates.

(December 22, 2021 )

Comments from Committees on Third Exposure Draft of ASOP No. 4

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the third exposure draft of Actuarial Standard of Practice No. 4, Measuring Pension Obligations and Determining Pension Costs or Contributions.

(October 18, 2021 )

Comment Letter to FASB on Future Standard-Setting Agenda

Pension Committee comment letter responding to Financial Accounting Standards Board’s (FASB) June 2021 Invitation to Comment on its future standard-setting agenda.

(September 22, 2021 )

Comment Letter to Treasury Department and IRS on American Rescue Plan Act Single-Employer Pension Provisions

Pension Committee comments to U.S. Department of the Treasury and Internal Revenue Service (IRS) relating to single-employer pension funding relief provisions enacted under the American Rescue Plan Act of 2021 (ARPA).

(July 23, 2021 )

Comment Letter on Rules for Maintenance and Application of Funding Balances

Pension Committee comment letter to Department of the Treasury and Internal Revenue Service providing suggestions for modification to rules relating to the maintenance and application of funding balances.

(June 21, 2021 )

Comments from Committee on Third Exposure Draft of Proposed Assumption Setting ASOP

Comments from the Academy’s Pension Committee to the Actuarial Standards Board regarding the third exposure draft of the proposed Actuarial Standard of Practice, Setting Assumptions.

(April 14, 2021 )

Issue Brief on the Impact of PBGC Premiums on Single-Employer Plan Sponsorship

Pension Committee issue brief on Pension Benefit Guaranty Corporation (PBGC) single-employer premiums and their impact on pension plan sponsorship.

(October 08, 2020 )

Exposure Draft of Practice Note on ASOP No. 56

Exposure draft of a Pension Committee practice note providing background and ideas about how a pension actuary might comply with ASOP No. 56, Modeling. Please send comments to the pension policy analyst of the American Academy of Actuaries at pensionanalyst@actuary.org by January 31, 2021.

(October 06, 2020 )

Issue Brief on the Impact of COVID-19 for Pension Plans

Pension Committee issue brief on near-term and long-term effects of COVID-19 on pension plans, mortality, and other assumptions.

(September 22, 2020 )

ASOP No. 51: Risk Assessment in Practice

Pension Committee practice note providing information to actuaries on current or emerging practices affected by ASOP No. 51, Assessment and Disclosure of Risk Associated with Measuring Pension Obligations and Determining Pension Plan Contributions.

(July 29, 2020 )

Comments from Committees on Second Exposure Draft of ASOP No. 4

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board regarding the second exposure draft of Actuarial Standard of Practice No. 4, Measuring Pension Obligations and Determining Pension Costs or Contributions.

(July 20, 2020 )

Pension Committee Comment Letter to IRS on Updated Mortality Tables

Pension Committee comment letter to the Internal Revenue Service on updated mortality improvement rates and static mortality tables for defined benefit pension plans for 2021.

(March 09, 2020 )

Committee Practice Note on Working with Auditors

Pension Committee practice note Working With Auditors of Pension and OPEB Plans providing insights to actuaries on engaging with auditors.

(December 11, 2019 )

Pension Committee Releases Variable Annuity Practice Note

Practice note prepared by Pension Committee addressing current and emerging practices for measuring obligations of defined benefit pension plans, with respect to variable annuity benefits.

(November 01, 2019 )

Comments from Committees on ASOP 27 and 35 Exposure Drafts

Comments from the Pension Committee, Multiemployer Plans Committee, and Public Plans Committee to the Actuarial Standards Board on the exposure drafts of Actuarial Standards of Practice 27 and 35.

(September 09, 2019 )

Committee Comments to SOA on Pri-2012 Exposure Draft

Pension Committee comments to Society of Actuaries Retirement Plans Experience Committee regarding the Pri-2012 exposure draft.

(August 12, 2019 )

Comments on Second Exposure Draft of the Setting Assumptions ASOP

Pension Committee comment letter to the Actuarial Standards Board regarding the second exposure draft of the Setting Assumptions ASOP.

(July 31, 2019 )

Selecting Investment Return Assumptions: Considerations When Using Arithmetic and Geometric Averages

Pension Committee practice note providing discussion and background information on the determination of investment return assumptions with a focus on considerations relating to the use of the return assumption as a discount rate.

(July 31, 2019 )

Academy Comments to ASB on Modeling ASOP

Pension Committee comment letter to ASB on fourth exposure draft of the Modeling ASOP.

(May 15, 2019 )

Valuing Benefits Payable as a Lump Sum

Pension Committee practice note discussing the valuation of lump sum benefits for financial accounting purposes. (February 21, 2019 )

Alternatives for Pension Cost Recognition

Pension Committee practice note covering topics related to the implementation of the spot rate approach to determining benefit obligations, service cost, and interest cost under accounting standards and other granular approaches. (September 23, 2018 )

Valuing Benefits Payable As A Lump Sum

Pension Committee exposure draft of practice note on current and emerging practices in the development of liabilities and cost estimates for pension plans with benefits paid as a lump sum. The comment deadline for this exposure draft is November 15, 2018. (September 20, 2018 )

Academy Comments to ASB on ASOPs 4, 27, and 35

Pension Committee, Public Plans Committee and Multiemployer Plans Committee comment letter to ASB on exposure drafts of proposed revisions to ASOPs 4, 24, and 35. (July 30, 2018 )

The Pension Protection Act: Successes, Shortcomings, and Opportunities for Improvement

Pension Committee issue brief that analyzes the Pension Protection Act of 2006 (PPA) and its subsequent amendments against the principles underlying funding reform. (April 05, 2018 )

Comments to the American Institute of Certified Public Accountants on ASC 960 Calculations

Pension Committee comments to the AICPA Employee Benefit Expert Panel on the current ASC 960 reporting standards for defined benefit pension plans. (October 27, 2017 )

Comments to ERISA Advisory Council on Annual Funding Notice Under ERISA Section 101(f)

Pension Committee comment letter to the ERISA Advisory Council on the Annual Funding Notice Under ERISA Section 101(f). (August 16, 2017 )

Comments to Congressman on Incentives for Annuities

Pension Committee comment letter to Rep. Devin Nunes regarding incentives to provide annuity payouts from qualified plans. (August 11, 2017 )

Comments to IRS and Treasury on Projection of Cash Balance Benefits

Pension Committee comment letter to the IRS and Treasury on the projection of benefits under cash balance plans with variable interest credits. (May 12, 2017 )

Comments to ASB on Setting Assumptions ASOP Draft

Pension Committee comment letter to the Actuarial Standards Board (ASB) on the proposed Actuarial Standard of Practice (ASOP), Setting Assumptions.
(May 02, 2017 )

Comments to IRS on Proposed Update to Mortality Tables

Pension Committee comment letter to the IRS on the proposed update to mortality tables for determining the present value for defined benefit pension plans. (March 30, 2017 )

Comments to Treasury Requesting Guidance on Variable Annuity Plans

Pension Committee comments to the U.S. Treasury Department requesting guidance from the IRS and Treasury to resolve uncertainties that exist as to how variable annuity plans should be valued for minimum funding and Internal Revenue Code (IRC) §417(e) purposes.
(March 09, 2017 )

Comments to IRS on Present Value Requirements for DB Plan Distributions

Pension Committee comment letter to the IRS on proposed regulations to the minimum present value requirements for defined benefit (DB) plan distributions. (February 24, 2017 )

Alternative Pension Cost Bond Models Issue Brief

Pension Committee issue brief that explores five different approaches used in developing a yield curve, and associated spot rates, from a bond model.
(December 30, 2016 )

Academy Groups Comment Letter to ASB on Risk Assessment and Disclosure ASOP

Pension Committee, Multiemployer Plans Subcommittee, and Public Plans Subcommittee comments to the Actuarial Standards Board (ASB) on a draft actuarial standard of practice (ASOP) on risk assessment and disclosure. (October 31, 2016 )

PC Comments to ASB on Proposed Modeling ASOP

Pension Committee (PC) comments to the Actuarial Standards Board (ASB) on the third exposure draft of a proposed actuarial standard of practice (ASOP) on modeling. (October 21, 2016 )

Pension Risk Transfer

Pension Committee issue brief that explores risk transfers by defined benefit pension plans from the perspectives of plan sponsors, beneficiaries, and policymakers. (October 11, 2016 )

Comments to Senate Aging Committee on Open Multiple Employer Plans

Pension Committee comments to U.S. Senate Special Committee on Aging Chairman Susan Collins on efforts to encourage open multiple employer plans.
(September 01, 2016 )

Pension Committee Comments on Improving Availability of IRS Actuaries with the Profession

Pension Committee comment letter on the decision by the Internal Revenue Service (IRS) to limit the pension actuaries’ potential to interact with IRS actuaries and other experienced employee-benefits personnel.
(July 15, 2016 )

Pension Committee Comments on Late Premium Payment Relief

Pension Committee comment letter to the Pension Benefit Guarantee Corporation (PBGC) expressing appreciation for proposed regulations providing a reduction or partial waiver of the penalty due upon the late payment of premiums to the single employer and multiemployer insurance programs.
(June 22, 2016 )

Pension Committee Comments on 2017 Applicable Mortality Tables

Pension Committee comment letter to the IRS and Treasury requesting that the 2017 Applicable Mortality Tables be issued as soon as possible. (June 10, 2016 )

Comments to IRS on Nondiscrimination Regulations

Pension Committee comments to the Internal Revenue Service regarding the proposed regulations for nondiscrimination relief for closed defined benefit plans.
(April 28, 2016 )

Selecting Investment Return Assumptions Based on Anticipated Future Experience

Pension Committee exposure draft of practice note on current and emerging practices in the selection of investment return assumptions based on anticipated future experience. The comment deadline for this practice note is June 27, 2016. (April 26, 2016 )

Comments to GASB on Pension Issues Exposure Draft

Public Plans Subcommittee comment letter on the exposure draft on Pension Issues—an amendment of GASB Statements No. 67, No. 68 and No. 73.
(February 12, 2016 )

Comments to PBGC on 4010 Reporting Requirements

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

Comments to ASB on Public Pension Plan Funding

Public Plans Subcommittee 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 )

Issue Brief on Alternatives for Pension Cost Recognition

Pension Accounting Committee and Pension Committee issue brief on alternative expense methodologies and their theoretical rationales and implications.

(August 14, 2015 )

Pension Committee Comments on IRS Mortality Table Release Date

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 )

Selecting and Documenting Mortality Assumptions for Pensions

Pension Committee's practice note, “Selecting and Documenting Mortality Assumptions for Pensions,” revised to reflect a new mortality improvement scale (BB) published by the Retirement Plans Experience Committee (RPEC) of the Society of Actuaries in 2012, mortality table RP-2014, and mortality improvement scale MP-2014 published by the Society of Actuaries in 2014. (June 15, 2015 )

Pension Committee Comments on ASB Exposure Draft on Risks in Measuring Pension Obligations and Determining Pension Plan Contributions

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 01, 2015 )

Pension Committee Comment Letter to ASB on Modeling Standards

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 01, 2015 )

Pension Committee Comment Letter to IRS and Treasury on IRC Section 436

Pension Committee comment letter regarding potential improvements in the operation of IRC Section 436 while still protecting the funded status of pension plans.
(February 05, 2015 )

Pension Committee Letter to IRS Regarding Mortality Tables

Pension Committee comment letter to the IRS regarding the use of mortality tables to calculate pension funding requirements for the years after 2015. (February 05, 2015 )

Pension Committee Letter to PBGC Regarding Late Retirement Actuarial Equivalence

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

Pension Committee Letter to IRS Regarding Hybrid Plans

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

Public Plans Subcommittee Sends Comment Letter to GASB Regarding Exposure Draft

The Pension Committee's Public Plans Subcommittee letter to the Governmental Accounting Standards Board commenting on an Exposure Draft on accounting and financial reporting for pension plans that are not administered through trusts and amendments to certain provisions of GASB Statements 67 and 68. (August 29, 2014 )

Pension Committee Letter to IRS and Treasury Regarding HAFTA Guidance

Pension Committee letter to the Internal Revenue Service and Treasury Department on guidance needed regarding the Highway and Transportation Funding Act of 2014. (August 26, 2014 )

Pension Committee Comments on RP-2014 Mortality Tables

Pension Committee comments to the Society of Actuaries’ Retirement Plans Experience Committee on the RP-2014 and MP-2014 exposure drafts. (May 29, 2014 )

Comments on Temporary Nondiscrimination Relief for Closed Defined Benefit Plans

Pension Committee Comments on the Internal Revenue Service Notice 2014-5, Temporary Nondiscrimination Relief for Closed Defined Benefit Plans and Request for Comments. (February 28, 2014 )

Pension Committee Comments on ASOP No. 35

Pension Committee comments to the Actuarial Standards Board on revisions to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. (January 31, 2014 )

Comment on IRS Notice 2013-49 on Updated Mortality Tables

Pension Committee comments on Internal Revenue Service Notice 2013-49: Updated Static Mortality Tables for the Years 2014 and 2015. (December 16, 2013 )

Joint Letter on ASOP Coordination Involving Retirement Benefits

Pension Committee, Joint Committee on Retiree Health, and Pension Finance Task Force letter to the Actuarial Standards Board (ASB) on coordinating Actuarial Standards of Practice (ASOPs) involving retirement benefits. (October 29, 2013 )

Comments to EBSA on Annual Funding Notice for DB Plans

Pension Committee comments to the Employee Benefits Security Administration (EBSA) regarding certain disclosures on the Annual Funding Notice for defined benefit plans. (October 03, 2013 )

Letter on Proposed PBGC Regulations on Premiums and Reducing Regulatory Burden

Pension Committee letter to the Pension Benefit Guaranty Corporation (PBGC) that supports the proposed regulations on premium rates, payment of premiums, and reducing regulatory burdens. (October 02, 2013 )

Comments on Exposure Draft of Modeling ASOP

Pension Committee comments to the Actuarial Standards Board on its recent modeling ASOP exposure draft that included concerns that the potential ASOP could be applied too broadly. (September 27, 2013 )

Comments to IRS on Form 5500

Pension Committee comments to the Internal Revenue Service regarding the Annual Return/Report of Employee Benefit Plan (Form 5500) that focus on the electronic submission of data on Schedules SB and MB. (September 23, 2013 )

Perspectives on the PBGC Single-Employer Deficit

Issue brief addressing the Pension Benefit Guaranty Corporation’s deficit in its single-employer program. The issue brief concludes that the agency’s methods and assumptions have produced a reasonable representation of the PBGC single-employer program’s current obligation and deficit. (August 22, 2013 )

Pension Committee Comments on Proposed Lifetime Income Benefit Statements

Pension Committee comments on Department of Labor’s advance notice of proposed rulemaking regarding pension benefit statement requirements under section 105 of the Employee Retirement Income Security Act of 1974. (August 07, 2013 )

Pension Committee Comments on PBGC’s Proposed Rule on Reportable Events

Pension Committee comments to the Pension Benefit Guaranty Corporation regarding its proposed rule on reportable events under ERISA Section 4043. (June 03, 2013 )

Pension Committee Comments on ASOP No. 4

Pension Committee comments to the Actuarial Standards Board on revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2013 )

Changing Discount Rates for Determining Lump Sums

Pension Committee paper that discusses the reasons why Congress should alter the discount rate calculation for determining lump-sums given historically low interest rates and provides information on possible transition rules for such a change. (June 17, 2003 )

Testimony on Department of Labor Lifetime Income Options Hearing

Testimony on the Department of Labor hearing on certain issues relating to Lifetime Income Options for participants and beneficiaries in retirement plans. (August 16, 2010 )

Rethinking Normal Retirement Age for Pension Plans

Pension Committee issue brief that recommends allowing private sector defined benefit plans to voluntarily raise their normal retirement age above 65 to align their plans with Social Security. (March 07, 2013 )

Comments on Notice Requirements Under Section 101(j) of ERISA

Pension Committee comments to the Internal Revenue Service regarding notice requirements under section 101(j) of ERISA, as promulgated in Notice 2012-46. (February 05, 2013 )

Comments on Proposed Revisions to ASOP No. 25

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 25, Credibility Procedures. (December 28, 2012 )

Comments on Proposed Regulations on Lump-Sum Distributions When Plan Sponsor Files Bankruptcy

Pension Committee comments to the Internal Revenue Service in response to its proposed regulations concerning the prohibited payment option under single-employer defined benefit plans when a plan sponsor is in bankruptcy. (August 20, 2012 )

Letter on Implementation of MAP-21 Pension Provisions

Pension Committee letter to Department of Treasury officials regarding the implementation of MAP-21 pension provisions. Attached to the letter is an outline of topics discussed by several Pension Committee members at a meeting with Treasury on July 23. (August 02, 2012 )

Pension Committee Letter to SOA on Scale BB

Pension Committee letter to the SOA regarding a new set of mortality tables and projection scales for the valuation of uninsured pension plans. (June 30, 2012 )

Administration’s Retirement Savings Proposals

Pension Committee analysis of retirement savings proposals from the Bush administration.
(August 01, 2005 )

Letter on Proposed Revision to ASOP No. 4

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (May 31, 2012 )

Letter on Proposed Revision to ASOP No. 27

Pension Committee comments to the Actuarial Standards Board regarding proposed revisions to ASOP No. 27, Selection of Economic Assumptions for Measuring Pension Obligations. (May 31, 2012 )

Letter on Proposed Regulations for Longevity Annuity Contracts

Pension Committee comment letter to the Internal Revenue Service responding to proposed regulations for longevity annuity contracts. (May 03, 2012 )

Letter on Proposed Regulations for Partial Annuity Distribution Options

Pension Committee comments to the Internal Revenue Service on proposed regulations for partial annuity distribution options under defined benefit pension plans. (May 03, 2012 )

Analysis of Congressional Pension Funding Reform Proposals

Pension Committee analysis of congressional pension funding reform proposals, updating a previous analysis from February 2005. (March 01, 2006 )

Comments on Increasing Flexibility for Elections to Reduce Funding Balances

Pension Committee letter to the Internal Revenue Service and Department of the Treasury addressing elections to reduce funding balances for defined benefit pension plans. (February 16, 2012 )

Comments on Application of IRC Section 415(b) Limits

Pension Committee letter to the Internal Revenue Service and Department of the Treasury concerning differing interpretations in the application of IRC Section 415(b) limits and requesting guidance. (January 30, 2012 )

Comments to ASB on Proposed Revisions to ASOP No. 27

Pension Committee comments to the Actuarial Standards Board regarding a proposed revision of ASOP No. 27, "Selection of Economic Assumptions for Measuring Pension Obligations." (May 12, 2011 )

Comment to IRS and Treasury on the Definition of 'Plan-Related Expenses'

Pension Committee comments to the IRS and Treasury regarding the potential implications of expected regulatory guidance on the definition of "plan-related expenses expected to be paid from plan assets" under Internal Revenue Code (IRC) Section 430(b). (May 24, 2011 )

Comments to IRS and Treasury on Guidance on Merger, Spinoff Issues under PPA

Pension Committee letter to the Internal Revenue Service and Department of the Treasury with comments and recommendations for future guidance on merger and spinoff issues related to the measurement of assets and liabilities for pension funding purposes and funding ratios. (June 01, 2011 )

Comments to IRS on Preparer Tax Identification Number Registration Requirements

Pension Committee letter to the Internal Revenue Service with concerns about the implications of the proposed modifications to Circular 230 and registration requirements for PTINs and the application of these rules to various reporting requirements for retirement plan professionals. (June 14, 2011 )

Comments to JBEA on Final Regulations and Continuing Education Requirements

Pension Committee comment letter to the Joint Board for Enrollment of Actuaries regarding final regulations and continuing education requirements for enrolled actuaries. (June 29, 2011 )

Comments to PBGC on Unfunded Vested Benefits Calculation

Pension Committee comment letter to the Pension Benefit Guaranty Corporation regarding the calculation of unfunded vested benefits for at risk pension plans. (September 22, 2011 )

Comments to Actuarial Standards Board on ASOP No. 4 Revisions

Pension Committee comment letter to the Actuarial Standards Board regarding the discussion draft of proposed revisions to ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions. (October 12, 2011 )

PBGC Response to Pension Committee’s Inquiry

PBGC response to the Pension Committee’s Oct. 14 inquiry regarding instructions on the Schedule H (Form 5500). (November 02, 2011 )

Comments to IRS and DOL on Form 5500, Schedule H

Pension Committee letter to the IRS and Department of Labor concerning a possible error in the instructions for Form 5500, Schedule H on the reporting of premium payments made to the PBGC from qualified DB plan assets. (October 17, 2011 )

Selecting and Documenting Mortality Assumptions for Pensions

Pension Committee's practice note, revised October 2011, Selecting and Documenting Mortality Assumptions for Pensions to reflect changes to ASOP No. 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations that went into effect in June 2011. (October 01, 2011 )

Administration’s Single-Employer Pension Funding Proposal

Pension Committee analysis of pension funding reform proposal released by Bush administration and that analysis later presented to a House Ways and Means subcommittee. (March 08, 2005 )

Fundamentals of Current Pension Funding and Accounting for Private Sector Pension Plans

Pension Committee policy paper analysis of current funding and accounting fundamentals for
private-sector pension plans. (July 16, 2004 )

Pension Funding Reform for Single Employer Plans

Pension Practice Council and Pension Committee analysis of pension funding reform for single-employer pension plans. (February 01, 2005 )

What’s a Credit Balance? How Does It Affect Pension Funding?

Pension Committee fact sheet examining credit balance options for defined benefit pension funding reform. (March 01, 2005 )

Keeping Employers Responsible for Their (and Only Their) Pension Promises

Pension Committee analysis of possible means by which employers that sponsor defined benefit (DB) pension plans are kept responsible for their pension promises. (May 01, 2006 )

Comments to the Internal Revenue Service regarding proposed regulations for hybrid retirement plans.

Comments to the Internal Revenue Service regarding propose regulations for hybrid retirement plans.
(January 12, 2011 )

Comments to IRS on Proposed Hybrid Plan Reguations

Pension Committee comments to the Internal Revenue Service regarding proposed regulations for hybrid retirement plans. (January 12, 2011 )