6 pages. Excerpt: It is our understanding that Treasury is considering the publication of guidance that would effectively eliminate smoothing of assets as a viable option. The PPA used the term 'averaging' with respect to asset valuation. We understand that the guidance under consideration may state that averaging is not the same as smoothing, but rather is something very different. The form of averaging under consideration by Treasury would systematically undervalue assets by a very significant amount, thus artificially inflating funding obligations.

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