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ASPPA and ACOPA Comment Letter to Actuarial Standards Board on Proposed Revision of ASOP No. 4, 'Measuring Pension Obligations and Determining Pension Plan Costs or Contributions' (PDF)

"[ASPPA and ACOPA] are concerned the proposed changes to ASOP 4 unilaterally and inappropriately expand the typical engagement between plan sponsors and actuaries, and would require calculations beyond the economic value such calculations would provide."

ASPPA and ACOPA Comment Letter to Actuarial Standards Board on Proposed Introductory Actuarial Standard of Practice (PDF)

"While the addition of the 'Terms of Construction' section may add clarity to the meaning of future ASOPs, the addition of the 'Terms of Construction' potentially changes the meaning of all existing ASOPs without providing actuaries an opportunity to comment on those changes. Because these terms were not explicitly defined previously in the ASOPs, an actuary during ASOP comment periods and then while applying the ASOPs would have read these terms using a common sense meaning instead of the meaning the Introductory ASOP currently assigns to them."

ASPPA and ACOPA on Proposed Revisions Comment Letter to ASOP No. 27, 'Selection of Economic Assumptions for Measuring Pension Obligations' (PDF)

"Our comments are predicated on significant modification of the proposed changes to Introductory Actuarial Standard of Practice, most specifically on the definitions of 'must', 'should' and 'should consider.' ... We believe the guidance should be more specific on the nature and extent of a range of reasonable assumptions. Without that specificity, sections 3.5 and 3.6 are difficult if not impossible to implement."

Text of Request from ASPPA and ACOPA to IRS for Updated Guidance on Automatic Approval of Funding Method Changes (PDF)

"ASPPA COPA recommends that automatic approval be provided for the following changes in funding methods: I. Changes in asset valuation method from fair market value to smoothed or smoothed to fair market value. II. Changes in valuation date for small plans which have discretion regarding the choice of such date. III. Changes in the actuarial organization performing the valuation and changes in valuation software. IV. Changes in the valuation interest rate set from segment rates to the full yield curve, or the reverse, as well as changes in the look-back period for determining the interest rates."

Text of Letter from ASPPA and ACOPA to IRS Requesting HTFA Funding Guidance (PDF)

6 pages. "ASPPA and ACOPA recommend that the IRS issue guidance that minimizes the additional time and expense required to comply with the [Highway Transportation Funding Act of 2014 (HTFA)] .... If the schedule SB for a plan year beginning in 2013 has already been filed, no supplemental or amended filing should be required... Rules similar to those in Notice 2012-61 should apply for plans that apply the extended 10% corridor to the 2013 plan year for purposes of Section 430 or Sections 430 and 436 and to all plans for 2014 plan years ... An election to elect out of HTFA segment rates for 2013 must not be considered an election to opt out of using the modified funding target determination period provided in section 2003(d) of HTFA."

ASPPA and ACOPA Comment Letter to IRS on Cash Balance Volume Submitter Provisions (PDF)

"ASPPA and ACOPA recommend that the flexibility contained in traditional defined benefit volume submitter plans should also be available in cash balance volume submitter documents. This flexibility pertains to definitions of classes, formulas based on percentage of compensation or flat dollar credit per year of service and the lesser of these or net self-employment income."

ASPPA/ACOPA Response to Request for Information on Reducing the PBGC Regulatory Burden (PDF)

"ASPPA and ACOPA recommend that the existing exemptions from reporting requirements for small and well-funded plans be expanded and similar exemptions extended to reporting under ERISA Sections 4062(e) and4063(a)."

ASPPA and ACOPA Comment Letter to IRS on Determination Letter Rulings for Plan Amendments Under Code Section 412(d)(2) (PDF)

"IRS ruling policy and, to the extent necessary, guidance (sub-regulatory or otherwise) should affirm the clear statutory language of IRC Section 412(d)(2) and Congressional authority to permit defined benefit plan sponsors to adopt retroactive 'discretionary' amendments.... The IRS should rebuild trust with the employee benefits plan community by engaging in dialogue, rather than using the threat of disqualification, as the vehicle to communicate a change in the Service's ruling policy."

ACOPA Comments to American Academy of Actuaries on Exposure Draft of Public Policy Practice Note on Variable Annuity Plans (PDF)

13 pages. "The scope of the Exposure Draft should be expanded to discuss the application of Code Section 411 (a)(9) and Section 415 to VAPs.... The Exposure Draft should include empirical data and analysis supporting the use of a 'pure' VAP as the baseline for discussion of liability measurement and lump sum determination for a VAP.... The Exposure Draft should encourage actuaries to disclose benefit determination and regulatory uncertainties known to the actuary, the financial implications of such uncertainties, and if the actuary is relying on outside counsel or the plan administrator for plan document and/ or regulatory interpretations."

ACOPA Comment Letter to IRS on Mortality Tables to be Used under Sections 430(h)(3)(A) and 417(e)(3) (PDF)

"ACOPA recommends that IRS continue to publish combined static mortality tables.... [A]lthough the more refined approach to mortality assumptions may be appropriate for large plans, there will be little or no benefit from such refinement for small plans. In fact, static tables work well in the small plan environment and ACOPA respectfully suggests that moving away from static tables for small plans would be form over substance at substantial cost."

Testimony of ACOPA President on PBGC Proposed Regs Relating to Reportable Events and Other Notification Requirements (PDF)

"As with the small plan waivers, the waivers for financially sound plans are sensible and welcome. We also appreciate the goal of further focusing the reporting requirement on plan sponsors that may not have the financial strength to meet future obligations. However, we do have some concerns about the approach to determining whether or not an employer is financially sound, especially as it relates to the self-employed, and other small businesses."

ACOPA Comments to Actuarial Standards Board on Proposed Revision to ASOP No. 21: Responding to or Assisting Auditors or Examiners in Connection with Financial Audits, Financial Reviews and Financial Examinations (PDF)

"The scope of the proposed revision is not clear with regard to pension audits that are attachments to the Form 5500.... [T]he proposed revision reflects that the responding actuary is responding to the auditor or examiner, not directly to the reviewing actuary. The proposed revision does not similarly reflect that the reviewing actuary often will not be communicating directly with the responding actuary."

The American Retirement Association: A New Name for an Expanding Mission

"For nearly half a century, the American Society of Pension Professionals and Actuaries (ASPPA) and its affiliated organizations have been working for America's retirement. As of today, it does so under a new name as broad and expansive as the members it represents: the American Retirement Association.... [T]he American Retirement Association is a nonprofit professional organization with two major goals: to educate all retirement plan and benefits professionals, and to create a framework of policy that gives every working American the ability to have a comfortable retirement.... The American Retirement Association is composed of four premier retirement industry associations: [1] the American Society of Pension Professionals & Actuaries (ASPPA); [2] the ASPPA College of Pension Actuaries (ACOPA) ; [3] the National Association of Plan Advisors (NAPA); and [4] the National Tax-deferred Savings Association (NTSA)"

In Memoriam: Tom Finnegan

"Tom Finnegan, the first American Retirement Association President, has passed away.... [He] also served as president of both ASPPA and the ASPPA College of Pension Actuaries (ACOPA), now the American Society of Enrolled Actuaries (ASEA).... He was a recipient of ASPPA's Educator of the Year Award and just this past year was awarded ASPPA's Harry T. Eidson Founders Award named after ASPPAs first president, Harry T Edison. Finnegan also was a recipient of the ASPPA Educators Award, as well as the 2020 recipient of the Edward E. Burrows Distinguished Achievement Award.... Tom's service to our industry and to [ASPPA] was without peer."

Notes from Meeting of Actuaries 'Intersector Group' with IRS, May 2021 (PDF)

13 pages. Topics include: [1] Phased retirement and nondiscrimination; [2] Statutory hybrid plan issues; [3] Partial plan termination issues; [4] Lump sums that are the greater of Section 417(e) and some other basis; [5] Applicability of excise taxes on multiemployer plans remaining in critical status after 10-year rehabilitation period; [6] Variable annuity pension plans; [7] Late retirement actuarial increases for cash balance plans; [8] Funding waivers; [9] Nondiscrimination testing; [10] ARPA guidance.

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, October 2023 (PDF)

8 pages. Topics include: [1] Pension Risk Transfer (PRT) Report update; [2] PBGC coverage with retro amendments; [3] Final premium filing deadline for terminating plans; [4] Technical Update 23-1; [5] Allocation of prior year contributions to spun-off plans; [6] Multiemployer plans: Benefit reductions and amount of SFA; Amounts eligible to be paid by SFA assets; and Lock-in application and census data. 

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, January 2023 (PDF)

4 pages. Topics include: [1] Special Financial Assistance (SFA) for multiemployer pension plans:Priority Group 5, Lock-in application, Post-MPRA contribution rate increases and withdrawal liability, and Use of SFA assets following a plan merger; [2] Schedule SB benefit payments; [3] ERISA 4010.

Notes from Meeting of Actuaries 'Intersector Group' with IRS, October 11, 2017 (PDF)

8 pages. Topics include: [1] Mortality tables opt-out: plan sponsor's determination; [2] Partial lump sums: total benefits vs. bifurcation rules; [3] Spinoff issues for plans subject to section 436 restrictions; [4] Multiemployer plan issues; [5] Closed plans/discrimination; [6] Hurricane relief issues; [7] Phased retirement; [8] Pension Equity Plans; [9] Risk sharing designs.

Notes from Meeting of Actuaries 'Intersector Group' with IRS, September 2016 (PDF)

5 pages. Topics include: [1] Guidance timing and priorities ... [2] Instructions for 2015 Form 5500 Schedule H/I line 4L and Form 5500-SF line 10f ... [3] Updating outdated mortality tables ... [4] Current processing time for approvals of shortfall and other funding method requests ... [5] Valuation of variable-annuity plans for funding, 417(e), etc.... [6] Multiemployer Pension Reform Act (MPRA) suspensions ... [7] Church plan litigation ... [8] Treating early retirement factors as benefits, rights, and features for nondiscrimination testing ... [9] Intersector Group suggestion to offer a special one-time determination letter opportunity within the next two years, solely for hybrid plans forced to change their interest crediting rate to comply with the final rules

Notes from Meeting of Actuaries 'Intersector Group' with Treasury and IRS, April 2024 (PDF)

14 pages. Topics include: [1] SECURE 2.0 Cash Balance Guidance (Notice 2024-2, Section H); [2] Related cash balance topics; [3] Funding method changes; [4] 415 limits; [5] Late retirement actuarial equivalence; [6] Closed Plan guidance; [7] Long-term part-time employees; [8] Signature Protocols; [9] IRS Guidance Protocols/Administrative Procedures Act; [10] 417(e) mortality assumption; [11] IRC section 431(b)(7)(G) and an amendment to reinstate suspended benefits for a plan that received special financial assistance.