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Comment Letter by the Pension Committee of the American Academy of Actuaries, to PBGC on Proposed Regs on Reportable Events Under ERISA Section 4043 (PDF)

"Perhaps various combinations of a plan sponsor's creditworthiness and a plan's funded status could be made available to satisfy the financial soundness waiver.... Although it is true that PBGC's risk generally increases as funding levels decrease, we believe the proposed thresholds are too high... To allow the plan sponsor to determine whether the waivers apply, the waivers should be modified to allow determination of the information as of a prior date.... We suggest that the plan financial soundness waiver be expanded to also cover plans that could meet the test based on current year premium information, if available, by the event date."

Pension Committee of the American Academy of Actuaries Comment Letter to Actuarial Standards Board on Proposed Revision of ASOP No. 35 (PDF)

"The language [of Sections 2.6 and 2.7] regarding a Prescribed Method may be confusing to some actuaries.... Section 3.1 ... should state that an actuary is very often able to identify two or more reasonable assumptions... It is not clear why the language [of Section 3.5.1 and 3.5.2] was changed from 'the actuary should establish an appropriate balance between refined methodology and materiality' to 'the actuary should consider the balance between refined assumptions and materiality'... Section 4.4 ... should include a statement that the Principal is the party that determines what is confidential or what the actuary may disclose[.]"

Comment Letter by Pension Committee of American Academy of Actuaries to Actuarial Standards Board, on Revised Exposure Draft of ASOP No. 4, Measuring Pension Obligations and Determining Pension Plan Costs or Contributions (PDF)

"There is discussion within the actuarial community over whether it is better to smooth inputs or outputs in order to control the volatility of contributions.... The current draft of ASOP 4 appears to be silent about these methods. While it may be premature to provide any significant guidance on output smoothing methods, we believe ASOP 4 should at least include them within the discussion of 'allocation procedures' and the related required disclosures."

Comment Letter from by Pension Committee of the American Academy of Actuariesto Actuarial Standards Board, on Proposed Revisions to ASOP No. 27, 'Selection of Economic Assumptions for Measuring Pension Obligations' (PDF)

"[Section 3.8] includes a list of factors that should be considered in determining an investment return assumption. We have some concerns that the described list might not include all of the fundamental elements that actuaries analyze in setting these assumptions, and in fact might include some terms that are either unfamiliar to actuaries or-if familiar-of less practical relevance perhaps than other factors."

Comment Letter from Pension Committee of American Academy of Actuaries to Actuarial Standards Board, on Proposed Revisions to ASOP No. 4, 'Measuring Pension Obligations and Determining Pension Plan Costs or Contributions' (PDF)

"[The Committee has] concerns ... about classifying a present value as market consistent merely because the discount rate is determined on a market-consistent basis. In addition, [The Committee believes] that basing assumptions on market conditions is an evolving practice and that the single term 'market consistent' is too narrow to encompass its many variations."

Comment Letter by the Pension Accounting Committee of the American Academy of Actuaries, to IASB on Exposure Draft 2009/10, Discount Rate for Employee Benefits (Proposed Amendments to IAS 19) (PDF)

2 pages. Excerpt: Because Academy members' practice primarily involves financial reporting under the standards of the Financial AccountingStandards Board, rather than the IASB, we have limited our comments to those areas where our experience might be relevant to the board's deliberations or where there is an opportunity to further the goal of converging standards.

American Academy of Actuaries Pension Committee Comment Letter to Actuarial Standards Board on the Exposure Draft of the Proposed ASOP on Modeling (PDF)

"The exposure draft defines 'model' broadly. Indeed, the last paragraph in the background section says: 'Actuaries generally agree that almost all actuarial work involves modeling of some type....' It is unclear why this ASOP is needed in situations involving straightforward calculations. For instance, in calculating a deterministic present value using a pension valuation system or even using pencil and paper, the actuary seems to be using a model, as defined. In situations such as these, the exposure draft does not seem to have any positive effect and might instead add cost and exposure to routine work. Therefore, we believe the definition of 'model' should be scaled back so that the ASOP only applies where it provides value."

Comment Letter by the Joint Committee on Retiree Health of the American Academy of Actuaries, to Actuarial Standards Board on Revised ASOP No. 6, Measuring Retiree Group Benefit Obligations (PDF)

"[This Committee] commented at considerable length a year ago on the first exposure draft (ED) and are pleased that the second ED effectively addresses many of the concerns expressed.... There are fundamental differences between pension and retiree health, and our comments focus on the need for ASOPs to recognize those differences. We continue to have concerns that ASOP No. 4 language regarding pensions is used more than is needed within ASOP No. 6 and that the problem of implicit subsidies (and age specific costs for groups in pooled health plans) is not sufficiently addressed."

American Academy of Actuaries Comments on Proposed Revision of Actuarial Standard of Practice on Selection of Economic Assumptions for Measuring Pension Obligations (PDF)

"The Pension Committee of the American Academy of Actuaries [provides] comments on the Actuarial Standards Board's proposed revision of ASOP No. 27[.]"

American Academy of Actuaries Letter to House Ways and Means Committee Requesting Technical Corrections to Pension Protection Act (PDF)

3 pages. Excerpt: On behalf of the American Academy of Actuaries, we appreciate this opportunity to address important defined benefit pension plan matters in relation to benefit restrictions under the Pension Protection Act of 2006 (PPA). We are requesting some technical corrections that will clarify the law and alleviate unreasonable burdens on plan participants, plan administrators, and other service providers to the plan, while not affecting the intent of the law.