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American Academy of Actuaries Comment Letter to PBGC on Proposed Regs for Annual Financial and Actuarial Information Reporting (PDF)
American Academy of Actuaries Link to more items from this source
[Opinion]
Sept. 28, 2015

"[A] higher participant threshold, such as 2,500, would better balance the need for additional information with the cost of providing that information.... Even with a higher threshold on the participant count, the committee does not believe that the $15 million underfunding threshold should be completely eliminated for larger plans.... We suggest that Section 4010 reporting be waived for companies that meet the low-default-risk safe harbor, or alternatively allow the continued use of the $15 million waiver threshold on a stabilized basis for companies that meet the safe harbor."

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