Effen

Flosfor, I don't think anyone is going to touch your question on this board. Not that your question isn't valid, in fact, I think it is an excellent question, but many actuaries aren't willing to share these thoughts in a public forum. I know that most EA Meetings and ASPA Meetings have sessions related to your question, but they are generally not taped. You may want to check the outlines. The 2nd General Session at the 2002 EA Meeting was taped and dealt with Professionalism. It was a very good session. Also, you may want to contact whatever actuarial organization you belong to. Most would have someone who could offer you some advise or could at least point you in the right direction.

Thank you for your responses. I found the article very helpful. I guess this is an issue that we must continue to "bang the drum" even though no one may be listening.

I have a question that I was a little hesitant to post, but I would really like to hear your opinion. I have been an actuary for close to 20 years and during that time the issue of suspension notices and actuarial increases continues to bother me. Assume the Plan document is silent (I know it can't be silent, but somehow they get approval letters) or that it requires a Suspension Notice to be issued at NRA. I believe, as do most ERISA attorneys, that if you fail to provide the suspension notice at NRA, you must provide the greater of the age/service benefit or the actuarially increased value of the normal retirement benefit when the participant ultimately retires. (Proposed Reg. 1.411(b)). Now, this is where my question comes in. If you come across a client who has "never" given suspension notices and has "never" granted the actuarial increase, and has lots of actives and term vested older than NRA, what are the chances that this ever becomes a "problem" for them. In other words, is this something the IRS is checking on audit? Is this something the Plan or Company auditor should have caught? How do you inform the client that they potentially owe lots of people lots of money? This comment usually generates a blank stare that ends in "your insane if you think we are paying these people those benefits". This can be a bigger problem in the multi-employer world where the plan may have hundreds of terminated vested participants that never came in to collect their benefit and the Trustees have no intention of trying to find them. We are in the position of telling them that they have to find them and not only that, they have to pay them 2 times their original benefit. Has anyone ever had someone outside of the actuary raise this issue? Is this a "real" issue or is it something the IRS doesn't really care about? What would you advise your client?