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American Academy of Actuaries Comment Letter to Actuarial Standards Board on ASOPs Pertaining to Public Pension Plan Funding (PDF)

"[A]dditional guidance or disclosure requirements could provide support to actuaries who make appropriate comments or disclosures when the plan or plan sponsor actions may not be consistent with the actuaries' recommendations.... With the new GASB standards, the determination of an appropriate actuarially determined contribution has become of greater importance for public plans and some additional guidance could be helpful ... [To] maintain the consistency of standards applicable to all pension actuaries, any new guidance should not be limited to a sub category based solely on the nature of the plan sponsor."

American Academy of Actuaries Comment Letter to GASB on Exposure Draft on Reporting for Pension Plans Not Administered Through Certain Trusts, and Amendments to Certain Provisions of GASB Statements 67 and 68 (PDF)

"For pension plans that are not administered through trusts, the pay-as-you-go benefit payments can increase rapidly due to retirements. Consequently, we suggest that the Notes to the financial statements include a disclosure of the projected benefit payments for current members for the next ten years.... Given an objective of preventing the use of a discount rate equal to the long-term expected return when assets are not actually expected to accumulate significantly in advance of paying the benefits, we recommend GASB develop appropriate additional parameters to the crossover test while retaining the basic structure established in GASB 67 and 68."

American Academy of Actuaries Comment Letter to California Actuarial Advisors Panel on Model Actuarial Funding Policies and Practices (MAFPP) for Public Pension Plans (PDF)

"The subcommittee recommends that the MAFPP specifically be limited to ... ongoing public pension plans (i.e., plans whose members earn future accruals and that are open to new hires).... [T]he MAFPP would categorize the current Pension Protection Act (PPA) funding method (traditional unit credit) as 'unacceptable'. This seems politically sensitive and potentially highly charged."