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American Academy of Actuaries Comment Letter to IRS on Timing for Release of 2016 Applicable Mortality Tables (PDF)
Pension Committee of the American Academy of ActuariesLink to more items from this source
[Opinion]
July 19, 2015

"[If] the IRS and Treasury decide that it is appropriate and necessary to update to a different underlying assumption basis that reflects a new structure (e.g., a change from static rates to generational projection), it is imperative that the new tables be announced immediately. Even then, many plans will face a significant challenge to implement the new tables in a timely manner and may experience compliance failures if they are unable to do so."

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