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American Academy of Actuaries Comment Letter to PBGC on Proposed Regs for Annual Financial and Actuarial Information Reporting (PDF)
American Academy of ActuariesLink to more items from this source
Sept. 28, 2015

"[A] higher participant threshold, such as 2,500, would better balance the need for additional information with the cost of providing that information.... Even with a higher threshold on the participant count, the committee does not believe that the $15 million underfunding threshold should be completely eliminated for larger plans.... We suggest that Section 4010 reporting be waived for companies that meet the low-default-risk safe harbor, or alternatively allow the continued use of the $15 million waiver threshold on a stabilized basis for companies that meet the safe harbor."

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