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|American Academy of Actuaries Comment Letter to EEOC on Upcoming Erie Guidance (PDF)|
American Academy of Actuaries
Oct. 21, 2002
Excerpt: [Y]ou expressed an interest in learning more about possible issues that might complicate implementation of a safe harbor method [addressing the Erie County court decision].... The following [is a] list of potential issues that could complicate implementation of retiree medical safe harbors ... [in] three categories-- rating and measurement, plan interpretation, and other.
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