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Comment Letter by Actuary Kenneth A. Steiner to EBSA on Benefit Statement Proposals (PDF)
Ken Steiner, FSA Retired Link to more items from this source
[Opinion]
May 13, 2013

"EBSA has decided that the safe harbor disclosure of the monthly payment associated with the Current Balance should be determined by converting the current balance to a life annuity equivalent assuming the participant has reached his or her normal retirement age ... under the plan on the date of calculation, even if the participant is much younger on such date. EBSA explains the rationale for this calculation as the payment the participant would receive today for life if he/she were old enough today (i.e., [had] reached the normal retirement date). The result of this methodology is to effectively assume no investment return on the current account balance between current age and normal retirement date.... [T]his is not the accrued benefit associated with the current balance; it is potentially misleading and not particularly helpful to someone who is trying to plan for retirement."  MORE >>

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