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96 Matching News Items

1.  American Academy of Actuaries Pension Committee Comment Letter to Actuarial Standards Board on the Exposure Draft of the Proposed ASOP on Modeling (PDF)
Pension Committee, American Academy of Actuaries Link to more items from this source
Oct. 2, 2013
"The exposure draft defines 'model' broadly. Indeed, the last paragraph in the background section says: 'Actuaries generally agree that almost all actuarial work involves modeling of some type....' It is unclear why this ASOP is needed in situations involving straightforward calculations. For instance, in calculating a deterministic present value using a pension valuation system or even using pencil and paper, the actuary seems to be using a model, as defined. In situations such as these, the exposure draft does not seem to have any positive effect and might instead add cost and exposure to routine work. Therefore, we believe the definition of 'model' should be scaled back so that the ASOP only applies where it provides value."
2.  Comment Letter by Pension Committee of American Academy of Actuaries to Actuarial Standards Board, on Revised Exposure Draft of ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions (PDF)
Pension Committee, American Academy of Actuaries Link to more items from this source
June 2, 2013
"There is discussion within the actuarial community over whether it is better to smooth inputs or outputs in order to control the volatility of contributions.... The current draft of ASOP 4 appears to be silent about these methods. While it may be premature to provide any significant guidance on output smoothing methods, we believe ASOP 4 should at least include them within the discussion of 'allocation procedures' and the related required disclosures."
3.  Comment Letter by the Pension Committee of the American Academy of Actuaries, to PBGC on Proposed Regs on Reportable Events Under ERISA Section 4043 (PDF)
Pension Committee, American Academy of Actuaries Link to more items from this source
June 3, 2013
"Perhaps various combinations of a plan sponsor's creditworthiness and a plan's funded status could be made available to satisfy the financial soundness waiver.... Although it is true that PBGC's risk generally increases as funding levels decrease, we believe the proposed thresholds are too high... To allow the plan sponsor to determine whether the waivers apply, the waivers should be modified to allow determination of the information as of a prior date.... We suggest that the plan financial soundness waiver be expanded to also cover plans that could meet the test based on current year premium information, if available, by the event date."
4.  Comment Letter from Pension Committee of American Academy of Actuaries to Actuarial Standards Board, on Proposed Revisions to ASOP No. 4, 'Measuring Pension Obligations and Determining Pension Plan Costs or Contributions' (PDF)
American Academy of Actuaries Link to more items from this source
June 5, 2012
"[The Committee has] concerns ... about classifying a present value as market consistent merely because the discount rate is determined on a market-consistent basis. In addition, [The Committee believes] that basing assumptions on market conditions is an evolving practice and that the single term 'market consistent' is too narrow to encompass its many variations."
5.  Pension Committee of the American Academy of Actuaries Comment Letter to Actuarial Standards Board on Proposed Revision of ASOP No. 35 (PDF)
American Academy of Actuaries Link to more items from this source
Feb. 2, 2014
"The language [of Sections 2.6 and 2.7] regarding a Prescribed Method may be confusing to some actuaries.... Section 3.1 ... should state that an actuary is very often able to identify two or more reasonable assumptions... It is not clear why the language [of Section 3.5.1 and 3.5.2] was changed from 'the actuary should establish an appropriate balance between refined methodology and materiality' to 'the actuary should consider the balance between refined assumptions and materiality'... Section 4.4 ... should include a statement that the Principal is the party that determines what is confidential or what the actuary may disclose[.]"
6.  Comment Letter from by Pension Committee of the American Academy of Actuariesto Actuarial Standards Board, on Proposed Revisions to ASOP No. 27, 'Selection of Economic Assumptions for Measuring Pension Obligations' (PDF)
American Academy of Actuaries Link to more items from this source
June 4, 2012
"[Section 3.8] includes a list of factors that should be considered in determining an investment return assumption. We have some concerns that the described list might not include all of the fundamental elements that actuaries analyze in setting these assumptions, and in fact might include some terms that are either unfamiliar to actuaries or-if familiar-of less practical relevance perhaps than other factors."
7.  American Academy of Actuaries' Comments on Regulations on Determination of Minimum Required Pension Contributions (PDF)
American Academy of Actuaries Link to more items from this source
Aug. 3, 2008
5 pages. Excerpt: On behalf of the American Academy of Actuaries Pension Committee, we respectfully request your consideration of our comments regarding the proposed regulations on the Determination of Minimum Required Pension Contributions (REG-108508-08). The proposed regulations provide much needed guidance regarding the new contribution rules in the Pension Protection Act of 2006 (PPA). The primary focus of our comments pertain to the means by which the carryover and prefunding balances may be used to satisfy quarterly contribution requirements.
8.  American Academy of Actuaries Letter to Joint Select Committee on Solvency of Multiemployer Pension Plans (PDF)
American Academy of Actuaries Link to more items from this source
Sept. 26, 2018
"[A] loan program could protect participant benefits by helping distressed multiemployer plans return to sound financial footing.... The most direct way for Congress to improve the financial strength of the PBGC would be to increase the current premium level.... Another way to increase funding to PBGC's multiemployer program is to deduct premium payments from benefit payments made to participants in all plans covered by the program.... The Committee could also consider whether the PBGC should have broader authority to proactively restructure distressed plans to enable them to remain solvent.... [T]he Committee might consider whether accrued plan benefits should become adjustable after restructuring."
9.  American Academy of Actuaries Letter to House Ways and Means Committee Requesting Technical Corrections to Pension Protection Act (PDF)
American Academy of Actuaries Link to more items from this source
Nov. 20, 2007
3 pages. Excerpt: On behalf of the American Academy of Actuaries, we appreciate this opportunity to address important defined benefit pension plan matters in relation to benefit restrictions under the Pension Protection Act of 2006 (PPA). We are requesting some technical corrections that will clarify the law and alleviate unreasonable burdens on plan participants, plan administrators, and other service providers to the plan, while not affecting the intent of the law.
10.  American Academy of Actuaries Joint Committee on Retiree Health, on Proposed Revisions Comment Letter to ASOP No. 4, 'Measuring Pension Obligations and Determining Pension Plan Costs or Contributions' (PDF)
American Academy of Actuaries Link to more items from this source
June 4, 2012
"While some of the recommended practices of ASOP No. 4 may have applicability to retiree group benefit measurement, others may not. The interests of practitioners and the ASB will be served best by having separate standards for each practice area[.]"
11.  American Academy of Actuaries Testimony to Joint Select Committee on the Solvency of Multiemployer Pension Plans (PDF)
American Academy of Actuaries Link to more items from this source
Apr. 18, 2018
"Of the more than 10 million people who participate in about 1,400 multiemployer pension plans, in excess of 1 million are in approximately 100 plans that will be unable to pay the full benefits they have been promised under current projections.... If the PBGC fails, participants in these plans could see their benefits cut by 90 percent or more."
12.  Comment Letter by the Pension Accounting Committee of the American Academy of Actuaries, to IASB on Exposure Draft 2009/10, Discount Rate for Employee Benefits (Proposed Amendments to IAS 19) (PDF)
American Academy of Actuaries Link to more items from this source
Oct. 9, 2009
2 pages. Excerpt: Because Academy members' practice primarily involves financial reporting under the standards of the Financial AccountingStandards Board, rather than the IASB, we have limited our comments to those areas where our experience might be relevant to the board's deliberations or where there is an opportunity to further the goal of converging standards.
13.  American Academy of Actuaries Comment Letter to DOL on Lifetime Income Illustration in Pension Benefit Statements (PDF)
Pension Committee, American Academy of Actuaries Link to more items from this source
Aug. 7, 2013
"[T]he committee believes that it is not sufficient for the safe harbor assumption to consist of a single assumed rate of return that applies regardless of the portfolio allocations, investment time horizon, risk tolerance, or current economic conditions.... [W]e believe the inclusion of a draw down illustration would be useful .... The committee suggests that DOL consider allowing the use of the normal retirement age as a safe harbor, while permitting the use of other projection ages if the plan sponsor believes that a different age would be more relevant to the participants."
14.  Text of Letter from American Academy of Actuaries to Actuarial Standards Board on Coordinating ASOPs Involving Retirement Benefits (PDF)
Pension Committee, Joint Committee on Retiree Health, and Pension Finance Task Force of American Academy of Actuaries Link to more items from this source
Nov. 6, 2013
"To effectively coordinate the two standards, we recommend the [Actuarial Standards Board (ASB)] look at the retirement benefit standards holistically, with detailed attention from both pension and [retiree group benefit (RGB)] specialists in drafting the concepts and language. The differences between the pension practice and the RGB practice (primarily retiree health benefits) need to be examined, with an understanding that below-standard work in any practice is a disservice to the public and our profession. Given the differences in pension and RGB practice, the ASB should review the process that placed the ASB Pension Committee in the position of editing an RGB ASOP."
15.  American Academy of Actuaries Comments on Proposed Revision of Actuarial Standard of Practice on Selection of Economic Assumptions for Measuring Pension Obligations (PDF)
American Academy of Actuaries Link to more items from this source
May 10, 2011
"The Pension Committee of the American Academy of Actuaries [provides] comments on the Actuarial Standards Board's proposed revision of ASOP No. 27[.]"
16.  American Academy of Actuaries Urges Treasury to Use New RP-2000 Mortality Table for Pension Calcs (PDF)
American Academy of Actuaries Link to more items from this source
May 14, 2001
7 pages. In its April 27 letter, the Academy's Pension Committee recommends that the tables' base rates be adopted as the basis that pension plans use to determine current mortality liability. But the committee also suggests that the base tables be adjusted first to reflect the higher blue-collar mortality rates. Excerpt: Below is a description of the study's background and pertinent findings and our recommendation for the mortality table(s) to be used for current liability determinations.
17.  American Academy of Actuaries' Answers to Questions Posed by Joint Select Committee on Multiemployer Plans (PDF)
American Academy of Actuaries Link to more items from this source
June 8, 2018
39 pages. "On behalf of the Pension Practice Council of the American Academy of Actuaries, I appreciate the opportunity to provide the following responses for the record to questions provided us pursuant to [April 18, 2018 hearing on] The History and Structure of the Multiemployer Pension System[.] ... The Pension Practice Council ... stands ready to help you at each step of the way with objective and nonpartisan input." [Editor's note: Includes more than 40 questions from legislators, with detailed answers.]
18.  American Academy of Actuaries Comment Letter to EBSA Regarding Proposed Asset-Question Addition to Form 5500 (PDF)
American Academy of Actuaries Link to more items from this source
Oct. 18, 2006
2 pages. Excerpt: On behalf of the American Academy of Actuaries' Pension Committee, [the writer expresses] strong objections to the proposed addition of Question 12 to the Form 5500 Schedule B. This question relates to asset classification and duration calculations of these assets.
19.  American Academy of Actuaries Comment Letter to IRS on Phased Retirement Arrangements in DB Plans (PDF)
American Academy of Actuaries Link to more items from this source
Jan. 13, 2003
8 pages. Dec. 30, 2002. Excerpt: The American Academy of Actuaries' Pension Committee appreciates the opportunity to comment on the importance of phased retirement as a means to address some of the issues faced by companies as they deal with shrinking labor supplies and the aging of the workforce. Facilitating phased retirement is now more important than ever, as employees face increased life expectancy and the desire to remain active.
20.  American Academy of Actuaries Comment Letter to IRS on Communication Under Relative Value Regulations (PDF)
American Academy of Actuaries Link to more items from this source
May 12, 2005
6 pages. Excerpt: "On behalf of the American Academy of Actuaries' Pension Committee, I thank you for this opportunity to suggest further refinements to the relative value regulations. [W]e would like to highlight some concerns and offer suggestions for simplifying the benefit communication material that must be offered to participants under the relative value rules."
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