Search the News Archive

ASPPA and ACOPA Comment Letter to Actuarial Standards Board on Proposed Revision of ASOP No. 4, 'Measuring Pension Obligations and Determining Pension Plan Costs or Contributions' (PDF)

"[ASPPA and ACOPA] are concerned the proposed changes to ASOP 4 unilaterally and inappropriately expand the typical engagement between plan sponsors and actuaries, and would require calculations beyond the economic value such calculations would provide."

ASPPA and ACOPA Comment Letter to Actuarial Standards Board on Proposed Introductory Actuarial Standard of Practice (PDF)

"While the addition of the 'Terms of Construction' section may add clarity to the meaning of future ASOPs, the addition of the 'Terms of Construction' potentially changes the meaning of all existing ASOPs without providing actuaries an opportunity to comment on those changes. Because these terms were not explicitly defined previously in the ASOPs, an actuary during ASOP comment periods and then while applying the ASOPs would have read these terms using a common sense meaning instead of the meaning the Introductory ASOP currently assigns to them."

ASPPA and ACOPA on Proposed Revisions Comment Letter to ASOP No. 27, 'Selection of Economic Assumptions for Measuring Pension Obligations' (PDF)

"Our comments are predicated on significant modification of the proposed changes to Introductory Actuarial Standard of Practice, most specifically on the definitions of 'must', 'should' and 'should consider.' ... We believe the guidance should be more specific on the nature and extent of a range of reasonable assumptions. Without that specificity, sections 3.5 and 3.6 are difficult if not impossible to implement."

Text of Request from ASPPA and ACOPA to IRS for Updated Guidance on Automatic Approval of Funding Method Changes (PDF)

"ASPPA COPA recommends that automatic approval be provided for the following changes in funding methods: I. Changes in asset valuation method from fair market value to smoothed or smoothed to fair market value. II. Changes in valuation date for small plans which have discretion regarding the choice of such date. III. Changes in the actuarial organization performing the valuation and changes in valuation software. IV. Changes in the valuation interest rate set from segment rates to the full yield curve, or the reverse, as well as changes in the look-back period for determining the interest rates."

Text of Letter from ASPPA and ACOPA to IRS Requesting HTFA Funding Guidance (PDF)

6 pages. "ASPPA and ACOPA recommend that the IRS issue guidance that minimizes the additional time and expense required to comply with the [Highway Transportation Funding Act of 2014 (HTFA)] .... If the schedule SB for a plan year beginning in 2013 has already been filed, no supplemental or amended filing should be required... Rules similar to those in Notice 2012-61 should apply for plans that apply the extended 10% corridor to the 2013 plan year for purposes of Section 430 or Sections 430 and 436 and to all plans for 2014 plan years ... An election to elect out of HTFA segment rates for 2013 must not be considered an election to opt out of using the modified funding target determination period provided in section 2003(d) of HTFA."

ASPPA and ACOPA Comment Letter to IRS on Cash Balance Volume Submitter Provisions (PDF)

"ASPPA and ACOPA recommend that the flexibility contained in traditional defined benefit volume submitter plans should also be available in cash balance volume submitter documents. This flexibility pertains to definitions of classes, formulas based on percentage of compensation or flat dollar credit per year of service and the lesser of these or net self-employment income."

ASPPA/ACOPA Response to Request for Information on Reducing the PBGC Regulatory Burden (PDF)

"ASPPA and ACOPA recommend that the existing exemptions from reporting requirements for small and well-funded plans be expanded and similar exemptions extended to reporting under ERISA Sections 4062(e) and4063(a)."

ASPPA and ACOPA Comment Letter to IRS on Determination Letter Rulings for Plan Amendments Under Code Section 412(d)(2) (PDF)

"IRS ruling policy and, to the extent necessary, guidance (sub-regulatory or otherwise) should affirm the clear statutory language of IRC Section 412(d)(2) and Congressional authority to permit defined benefit plan sponsors to adopt retroactive 'discretionary' amendments.... The IRS should rebuild trust with the employee benefits plan community by engaging in dialogue, rather than using the threat of disqualification, as the vehicle to communicate a change in the Service's ruling policy."

ACOPA Comments to American Academy of Actuaries on Exposure Draft of Public Policy Practice Note on Variable Annuity Plans (PDF)

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."

ACOPA Comments to Actuarial Standards Board on Proposed Revision to ASOP No. 21: Responding to or Assisting Auditors or Examiners in Connection with Financial Audits, Financial Reviews and Financial Examinations (PDF)

"The scope of the proposed revision is not clear with regard to pension audits that are attachments to the Form 5500.... [T]he proposed revision reflects that the responding actuary is responding to the auditor or examiner, not directly to the reviewing actuary. The proposed revision does not similarly reflect that the reviewing actuary often will not be communicating directly with the responding actuary."