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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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