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Comment Letter on Final Regs on Measurement of Assets and Liabilities for Pension Funding Purposes (PDF)
American Academy of Actuaries 
[Opinion] Mar. 29, 2010 14 pages. "The attribution methodology described in some of the examples in the regulations appears to be inconsistent with the wording of the regulations and give counterintuitive results. The examples are also inconsistent with any approach commonly used by actuaries. We recommend adjusting the examples to conform to the wording of the regulations and standard practice, as described [in the target document]." MORE >> |
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