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American Academy of Actuaries Comment Letter to PBGC on Premium Rates, Payment of Premiums, and Reducing Regulatory Burdens (PDF)
Pension Committee, American Academy of Actuaries Link to more items from this source
[Opinion]
Oct. 3, 2013

"[We] agree that eliminating the estimated filing removes an unnecessary task from plan sponsors with no material detriment to PBGC. We also agree that providing uniform due dates will eliminate confusion and help mitigate the possibility of errors. The PBGC rightly points out the difficulties that timing changes might cause to certain plans. However, the proposal creates new look-back rules that, in the view of the committee, provide a practical and workable way to address the issue."

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