"[We] believe it is appropriate to raise the minimum requirements to include assessments and disclosures of risks related to the funding of pension plan ... [T]he proposed standard specifically does not require the actuary to evaluate the ability of the plan sponsor to make contributions when due. As actuaries, we do not have the necessary expertise to make such an evaluation, so we fully support the current position of the standard. Yet, we must also recognize that the health of the pension plan cannot be completely separated from the health of the plan sponsor and the health of the plan sponsor is a key risk to the plan."  MORE >>