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CIEBA Comment Letter to FASB on Employers' Accounting for Defined Benefit Pension and Other Postretirement Plans (PDF)
Committee on Investment of Employee Benefit Assets [CIEBA] 
[Opinion] July 13, 2006
5 pages; May 31, 2006. Excerpt: Piecemeal Accounting Reform -- Pension accounting is, by its nature, complex. While it may appear that Phase I represents a 'simple' movement of information from the notes to the balance sheet, it is a major change. Such an action seems premature and counterproductive when the Financial Accounting Standards Board (FASB) indicated that it will undertake a comprehensive review of pension accounting, including measurement issues.
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