16 pages. "A thorough economic analysis is needed, with a focus on at least these four major issues: [1] The need for an 18-month deferred effective date. [2] A review of the speculative assumption that mortality will improve on average 1% indefinitely. [3] The introduction of unprecedented volatility into the mortality tables. [4] The erroneous assumption that Treasury must rely on tables prepared by the Society of Actuaries given that an expanded reliance on other sources is statutorily permitted and very much warranted from a practical perspective. There is a need for an announcement immediately that the new mortality tables will not apply for plan years beginning in 2018."  MORE >>