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Withdrawal Liability Actuarial Assumptions: Did PBGC's New Proposed Regs Get It Wrong?
Charles C. Shulman, Esq. 
Nov. 10, 2022 "[S]ince ERISA Section 4213(a)(1) does require reasonable actuarial assumptions that can be challenged in court, and the newly proposed regulations under ERISA Section 4213(a)(2) give the plan actuary a permitted range of assumptions, (i.e., plan termination assumptions or ongoing funding assumptions or anything in between) a court could logically read these regulations and Section 4213(a)(2) to require that when an actuary chooses an interest rate in the permitted range, it must be a reasonable choice." |
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