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Comments by American Academy of Actuaries on Proposed Regs on Suspensions of Benefits (PDF)
American Academy of ActuariesLink to more items from this source
Aug. 19, 2015

"The level of resources required could serve to discourage some plan sponsors from pursuing benefit suspensions, particularly because they cannot be certain that their applications will be approved. This concern would be most acute for small plans.... [The authors] suggest that the final regulations clarify that the actuary should base the projections to certify that the proposed suspensions are sufficient to avoid insolvency on the market asset value as of the end of the calendar year quarter preceding the date of certification."

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