"While there is reference to 'relative' creditworthiness, rating should be based on the fiscal environment of each jurisdiction. Moody's is proposing to assess pension obligations through a comparative lens that does not adequately consider factors specific to an entity. These factors include funding policy, changes in plan design, contribution sources and/or contribution history. In addition, Moody's has indicated that the application of these adjustments will not only be used when assessing creditworthiness, but it will make the adjusted liabilities and cost for all states and localities public even when not determining credit ratings. NCPERS believes that such comparisons will lead to the release of flawed information."  MORE >>