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Pension Committee of the American Academy of Actuaries Comment Letter to Actuarial Standards Board on Proposed Revision of ASOP No. 35 (PDF)
American Academy of Actuaries Link to more items from this source
[Opinion]
Feb. 2, 2014

"The language [of Sections 2.6 and 2.7] regarding a Prescribed Method may be confusing to some actuaries.... Section 3.1 ... should state that an actuary is very often able to identify two or more reasonable assumptions... It is not clear why the language [of Section 3.5.1 and 3.5.2] was changed from 'the actuary should establish an appropriate balance between refined methodology and materiality' to 'the actuary should consider the balance between refined assumptions and materiality'... Section 4.4 ... should include a statement that the Principal is the party that determines what is confidential or what the actuary may disclose[.]"

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