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Comments by NASRA, NCPERS and NCTR on ASB Actuarial Standards of Practice No. 4 Exposure Draft (PDF)
National Association of State Retirement Administrators [NASRA], National Conference on Public Employee Retirement Systems [NCPERS], and National Council on Teacher Retirement [NCTR] 
[Opinion] July 27, 2018 "[1] ASOP 51 already provides a robust framework for the assessment of risk, and the Investment Risk Defeasement Measure (IRDM) is a poor measure of risk ... [2] The intended purpose and application of an IRDM is unclear, particularly for risk-sharing plans ... [3] Requiring pension plans to pay for the calculation of a value that, in many cases, is of marginal utility, is unreasonable and may violate public pension fiduciary duties.... [4] The Investment Risk Defeasement Measure conflicts with the actuarial standard that standards should not be prescriptive ... [5] Requiring calculation of an IRDM may be a result of the ASB not following its traditional processes for proposing ASOP modifications." MORE >> |
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