Comment Letters

2017

On February 23, 2017, ACOPA submitted comments on a proposed update to IRC 417(e) regulations.  Primary concerns were the potential impact on most valuable benefit rules, and SSLI calculations. [Comment]


2016

On October 31, 2016, the ASPPA College of Pension Actuaries (ACOPA) filed comments with the ASB regarding the second exposure draft of the proposed ASOP on Modeling.     [Letter]

On October 31, 2016 the ASPPA College of Pension Actuaries (ACOPA) filed comments with the ASB regarding the second exposure draft of the proposed ASOP on Assessment and Disclosure of Risk. [Letter]

On July 14, 2016, ACOPA joined other Pension Coalition organizations in thanking Senator Enzi (R-WY) for his leadership in introducing legislation to address the use of PBGC premiums as a budgetary gimmick. The Pension Coalition has been working to educate Congress on the damage done recent increases in single employer PBGC premiums. [Letter]

On Feburary 25, 2016, ACOPA filed brief comments with the ASB regarding the Exposure Draft of the Proposed Revision to Actuarial Standard of Practice No. 23: Data Quality. [Letter]

On February 16, 2016, ACOPA submitted comments on the Exposure Draft of the Public Practice Note on Variable Annuity Plans prepared by the Pension Committee of the American Academy of Actuaries. ACOPA commends the Committee for issuing an exposure draft, and presenting alternate approaches to the valuation of liabilities and the calculation of equivalent lump sum payments for benefits provided under a variable annuity plan. ACOPA then suggests the Exposure Draft would be improved by providing more substance regarding views potentially contrary to the “consistent with discount rate” valuation approach. [Letter]


2015

On December 30, 2015, the ASPPA College of Pension Actuaries submitted a comment letter to the Actuarial Standards Board on an exposure draft of Actuarial Standard of Practice (ASOP) No. 21, Responding to or Assisting Auditors or Examiners in Connection with Financial Audits, Financial Reviews, and Financial Examinations. [Letter]

On November 17, 2015 ACOPA joined over 100 other organizations and companies in asking Congress to oppose future PBGC premium increases. [Letter]

On July 7, 2015, the ASPPA College of Pension Actuaries sent a letter to the Department of Labor regarding the small plan audit notice and the final Annual Fundign Notice regulations. [Letter]

On May 22, 2015, ACOPA submitted comments on the Exposure Draft on Assessment and Disclosure of Risk Associated with Pension Obligations, Plan Costs, and Plan Contributions. ACOPA had submitted comments on a discussion draft of the proposed ASOP in October 2012.    [Letter]

On February 27, 2015, the ASPPA College of Pension Actuaries submitted a comment letter to the Actuarial Standards Board on an exposure draft of the Actuarial Standard of Practice (ASOP) on Modeling. [Letter]

On January 30, 2015, the ASPPA College of Pension Actuaries submitted a comment letter to the Actuarial Standards Board on the exposure draft of the Proposed Revision to Actuarial Standard of Practice (ASOP) 34 on Actuarial Practice Concerning Retirement Benefits in Domestic Relations Actions.[Letter]


2014

On August 13,2014, ASPPA and ASPPA College of Pension Actuaries submitted a letter to the IRS requesting guidance regarding the application of the funding stabilization provisions in the section 2003 of the Highway and Transportation Funding Act of 2014. [Letter]

On June 19, 2014, ASPPA and the ASPPA College of Pension Actuaries filed comments with IRS regarding options for defining benefits that should be available under the new cash balance volume submitter program in order for the program to be successful. [Comment]

On June 9, 2014, ASPPA and ACOPA submitted a comment letter that recommended that IRS ruling policy and, to the extent necessary, IRS guidance affirm the statutory language of IRC Section 412(d)(2) and permit a defined benefit plan sponsor to adopt a retroactive “discretionary” amendment within 2 ½ months after the end of a plan year and deem it to be effective as the beginning of the plan year. [Letter] [Appendices]

On June 3, 2014, ACOPA joined the American Benefits Council; the Committee on Benefits Finance, Financial Executives International; and The Committee on Investment of Employee Benefit Assets in writing to PBGC’s Board of Directors regarding concerns about PBGC’s enforcement of ERISA section 4062(e). The letter was delivered through delivered through the office of the Participant and Plan Sponsor Advocate of the PBGC. [Letter]

On February 28, 2014, ASPPA and ACOPA submitted comments to IRS/Treasury in response to a request in Notice 2014-5 regarding possible alternatives to the current rules for DB/DC plans tested on the basis of equivalent benefits.[Letter]

On January 31, 2014, ACOPA submitted comments to the ASB on proposed revisions to ASOP 35, Selection of Demographic and Other Noneconomic Assumptions for Measuring Pension Obligations. [Letter]


2013

On October 21, 2013, ACOPA responded to an IRS request for comments, recommending the continued publication of combined static mortality tables. [Comment]

On September 30, 2013, ACOPA submitted comments to the ASB on the exposure draft of a proposed ASOP on Modeling. [Comments]

On August 19, 2013, ASPPA and ACOPA submitted comments to IRS requesting that IRS issue guidance regarding the deduction limit calculation for single-employer defined benefit plans under IRC Section 404(o).[Comments]

On July 31, 2013 ACOPA submitted comments to the American Academy of Actuaries’ Committee on Qualifications. [Comments]

On June 3, 2013, ASPPA and ACOPA submitted comments to PBGC on their proposed reportable events rules. [Comments]


On May 31, 2013, ACOPA submitted comments to the ASB on the second exposure draft of ASOP 4. [Comments]


2012

On October 12, 2012, ACOPA submitted comments on the Actuarial Standard Board Pension Committee’s discussion draft on Assessment and Disclosure of Pension Risk. [Comments]

On June 1, 2012, ASPPA and ACOPA sent a letter to IRS asking for guidance providing automatic approval for certain changes in funding method similar to the guidance provided in Revenue Procedure 2000-40 before the funding rule changes enacted in the Pension Protection Act of 2006 (PPA) made that procedure obsolete. [Letter]

On May 31, 2012, ACOPA’s ASOP Task Force submitted comment letters on exposure drafts for a new Introductory ASOP, ASOP 4 and ASOP 27 on behalf of ACOPA members. In addition to addressing many specific issues, the task force expressed a general concern that proposed changes to ASOP 4, and certain sections of the introductory ASOP, were too broad, and should be substantially modified in another round of exposure drafts. [intro] [asop4] [asop27]

On May 23, 2012, ASPPA and ACOPA sent a letter to Surface Transportation Act conferees urging them to modify the funding rules to moderate the impact of artificially low interest rates. [Letter]

On May 2, 2012, ASPPA and ACOPA submitted comments on proposed modifications to IRC 417(e) regulations regarding partial annuity distribution options. Issues addressed included implications for past practice, multiple annuity starting dates and notice and election rules for bifurcated benefits. [Comments]


2011

On December 30, 2011, ASPPA and ACOPA submitted comments to the Pension Benefit Guaranty Corporation (PBGC) providing comments on the proposed rule relating to benefit determinations and plan valuations for statutory hybrid plans. ASPPA and ACOPA recommended that: (1) proposed regulations regarding §4022 be temporary, effective only for plan terminations occurring before the effective date of final Treasury regulations regarding market rate of return; and (2) PBGC should re-propose these rules in a manner that is consistent with the final Treasury regulations after the final market rate of return regulations are issued. [Comment]

On November 10, 2011, ASPPA and the ASPPA College of Pension Actuaries sent a letter to IRS requesting that the deadline for amendments required to comply with IRC section 436 be extended to be concurrent with the recently extended deadline for certain hybrid plan amendments. [Letter]

On September 26, 2011, the ASPPA College of Pension Actuaries (ACOPA) joined five other organizations in requesting that PBGC expand relief for filing errors regarding election of the alternative premium funding target. [Letter]

On July 19, 2011, ACOPA submitted a letter to Treasury regarding the treatment of plan amendments under IRC section 412(d)(2). [Letter]

On April 27, 2011, ACOPA submitted comments to the ASB on proposed changes to ASOP 27, Selection of Economic Assumptions for Measuring Pension Obligations. [Comment]

On April 20, 2011, ASPPA and ACOPA submitted comments to PBGC in response to its request for recommendations on how it can improve its regulations. ASPPA and ACOPA’s recommendations relate to: (1) reporting exemptions; (2) the premium filing deadline; (3) My PAA website functionality; and (4) PBGC’s customer service. [Comment]

On January 18, 2011, ASPPA and ACOPA submitted comments to EBSA on proposed rules regarding the Annual Funding Notice for Defined Benefit Plans. [Comment]

On January 12, 2011, ASPPA and ACOPA submitted comments to IRS and Treasury on proposed additional rules regarding hybrid retirement plans. [Comment]