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American Academy of Actuaries Comment Letter to GASB on Exposure Draft on Reporting for Pension Plans Not Administered Through Certain Trusts, and Amendments to Certain Provisions of GASB Statements 67 and 68 (PDF)
Public Plans Subcommittee, American Academy of Actuaries Link to more items from this source
Sept. 1, 2014
"For pension plans that are not administered through trusts, the pay-as-you-go benefit payments can increase rapidly due to retirements. Consequently, we suggest that the Notes to the financial statements include a disclosure of the projected benefit payments for current members for the next ten years.... Given an objective of preventing the use of a discount rate equal to the long-term expected return when assets are not actually expected to accumulate significantly in advance of paying the benefits, we recommend GASB develop appropriate additional parameters to the crossover test while retaining the basic structure established in GASB 67 and 68."

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