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Conference of Consulting Actuaries Solicits Questions for IRS, PBGC, and DOL

"Released at the annual Enrolled Actuaries Meeting, the Gray Book, Blue Book, and Green Book are essential compendiums of questions and answers between actuaries and the IRS/Treasury, PBGC, and DOL respectively. The Gray Book Committee is accepting questions in preparation for their meetings ... covering such areas as funding, nondiscrimination, benefit restrictions, qualification issues, PBGC-related issues, and other areas that are of interest to enrolled actuaries. Please submit any questions [to the Gray Book Committee] by Monday, December 1st."

Selected Materials from 2011 Enrolled Actuaries Meeting

The target page contains links to materials used at some sessions of the recent meeting, such as 'Public Plan Funding -- An Emerging Crisis.' The Enrolled Actuaries Meeting was jointly sponsored by the American Academy of Actuaries and the Conference of Consulting Actuaries in cooperation with the Society of Actuaries.

Notes from Meeting of Actuaries 'Intersector Group' with IRS, May 2021 (PDF)

13 pages. Topics include: [1] Phased retirement and nondiscrimination; [2] Statutory hybrid plan issues; [3] Partial plan termination issues; [4] Lump sums that are the greater of Section 417(e) and some other basis; [5] Applicability of excise taxes on multiemployer plans remaining in critical status after 10-year rehabilitation period; [6] Variable annuity pension plans; [7] Late retirement actuarial increases for cash balance plans; [8] Funding waivers; [9] Nondiscrimination testing; [10] ARPA guidance.

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, May 28, 2020 (PDF)

9 pages. Topics include: Single-employer plans: 4062(e); Uncashed checks for missing participants in a plan termination; plan termination audits; reportable events and Early Warning Program; possible surge in funding waiver requests. Multiemployer Plans: Pending regulations on withdrawal liability; final rule for terminations and insolvencies; guidance on facilitated mergers; guidance on partitions; guidance on two-pool withdrawal liability methods. PBGC asked the Intersector Group about the ability of multiemployer plans to be able to handle an increase in costs related to a mandated cap on the actuarial interest rate assumption.

Notes from Meeting of Actuaries 'Intersector Group' with IRS/Treasury, March 2016 (PDF)

5 pages. Topics include: [1] Reasonable actuarial equivalence; [2] Issues related to uncashed checks at plan terminations (both DB and DC plans); [3] Additional guidance under Code Sections 430 and 436; [4] Automatic approvals for changes in funding method and discount rate election; [5] EPCRS wish list; [6] Mortality basis change and 'partial credibility' rules for use of adjusted mortality tables; [7] Vested terminated participants over normal retirement age, or beyond the required beginning date -- coordination with DOL enforcement initiative; [8] MPRA suspensions; [9] Additional hybrid plan guidance for final market-rate rules and the 'lump sum-based benefit formula' definition; [10] Post-Gray Book interaction with actuarial community and plan sponsors.

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, March 2016 (PDF)

5 pages. Topics include: [1] Experience under new Reportable Events rules; [2] 4010 final regulations; [3] Prospects for 4062 regulations; [4] Regulations on multiemployer partitions; [5] Review of PBGC actuarial assumptions and timing of changes; [6] Issues related to uncashed checks in plan terminations; and [7] 'Proof of payment' guidance/practice.

Notes from Meeting of Actuaries 'Intersector Group' with Treasury and IRS, April 2024 (PDF)

14 pages. Topics include: [1] SECURE 2.0 Cash Balance Guidance (Notice 2024-2, Section H); [2] Related cash balance topics; [3] Funding method changes; [4] 415 limits; [5] Late retirement actuarial equivalence; [6] Closed Plan guidance; [7] Long-term part-time employees; [8] Signature Protocols; [9] IRS Guidance Protocols/Administrative Procedures Act; [10] 417(e) mortality assumption; [11] IRC section 431(b)(7)(G) and an amendment to reinstate suspended benefits for a plan that received special financial assistance.

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, March 7, 2019 (PDF)

6 pages. Topics include: [1] PBGC organizational changes and priorities; [2] Pilot Mediation Program; [3] ERISA Section 4044 assumptions; [4] Is PBGC now using the information collected on de-risking to inform solvency projections? [5] Missing participants: update on any joint efforts among DOL, IRS, and PBGC to standardize what constitutes a diligent search for various purposes; [6] PBGC Guidance Plan; [7] Forms and instructions update; [8] Actuarial equivalence lawsuits; and [9] Proposed guidance on simplified withdrawal liability.

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, May 3, 2017 (PDF)

9 pages. Topics include: ... [1] How does the new administration affect the current priorities? ... [2] What is PBGC's plan with respect to mortality assumptions now that the IRS proposed regulations have been released? ... [3] Is PBGC moving forward with review of all other assumptions (e.g., ERISA Section 4044), and what can be expected on that front? ... [4] Are there any changes in the types of issues PBGC is seeing on audits of plan terminations or premium filings? ... PBGC provided a litany of errors it commonly discovers ... [5] Does PBGC expect to finalize the multiemployer plan merger regulation, and are any changes likely from the proposed regulation?

Notes from Meeting of Actuaries 'Intersector Group' with PBGC, September 2016 (PDF)

4 pages. Topics include: [1] MPRA exclusion of certain contribution increases required by funding improvement and rehabilitation plans from withdrawal liability -- timing and scope of regulations ... [2] MPRA partitions -- evolution of PBGC philosophy on non-impairment provision ... [3] Policy on refunding premiums when sponsor learns a participant died with no spouse/beneficiary entitled to plan benefits several years in the past ... [4] 4010 filings ... [5] Viability of PBGC multiemployer program ... [6] Discussion issues raised by PBGC representatives.