13 pages. "The scope of the Exposure Draft should be expanded to discuss the application of Code Section 411 (a)(9) and Section 415 to VAPs.... The Exposure Draft should include empirical data and analysis supporting the use of a 'pure' VAP as the baseline for discussion of liability measurement and lump sum determination for a VAP.... The Exposure Draft should encourage actuaries to disclose benefit determination and regulatory uncertainties known to the actuary, the financial implications of such uncertainties, and if the actuary is relying on outside counsel or the plan administrator for plan document and/ or regulatory interpretations."

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