"[C]ourts have now wrestled for eight years with the question of whether the ERISA provision requiring actuarial equivalence in this context includes an implicit requirement that the underlying actuarial assumptions be 'reasonable.' ... This year has started with three rulings for defendants and one for plaintiffs, and one that had a little something for both sides.... For those defendants that have chosen not to settle and instead fight on, there is still much uncertainty. That uncertainty will likely remain until a clear pattern emerges from the circuit courts or the issues reach the Supreme Court"  MORE >>