4 pages. "Excerpt: On behalf of the members of the American Academy of Actuaries Pension Committee, I would like to take this opportunity to comment on the recently finalized revisions to Circular 230, which raise questions among pension actuaries regarding how Sections 10.33 and 10.35–10.37 apply to their work. In particular, committee members are concerned over the extent to which a pension actuary's work product may constitute a 'covered opinion.'"  MORE >>