Older Comments
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]
On November 11, 2010, the ASPPA College of Pension Actuaries joined the American Benefits Council, the Committee on Investment of Employee Benefit Assets (“CIEBA”), The ERISA Industry Committee, the Financial Services Roundtable, the National Association of Manufacturers, and the U. S. Chamber of Commerce in submitting a comment letter regarding the proposed regulations under ERISA section 4062(e) to PBGC. [Joint letter]
On October 12, 2010, ASPPA and ACOPA submitted comments to PBGC on proposed substantial cessation of operations rules under ERISA 4062(e).[Comment]
On January 22, 2010, ASPPA and ACOPA submitted comments to PBGC on the proposed rule relating to reportable events and other notice requirements. [Comment]
On November 20, 2009, ACOPA submitted comments on JBEA proposed amendments to the regulations relating to performance of actuarial services under ERISA.[Comment]
On October 14, 2009, ASPPA and ACOPA submitted comments to Treasury and IRS regarding possible DB(k) issues in need of guidance.[Comment]
On May 8, 2009, the ASPPA College of Pension Actuaries participated in group comments submitted to Treasury asking for additional regulatory funding relief [Comments]
On April 8, 2009 ASPPA COPA submitted comments to the Treasury and IRS requesting guidance on matters related to end of year valuations and certain issues pertaining to application of benefit restrictions under IRC §436. [Comments]
On March 24, 2009, the ASPPA College of Pension Actuaries submitted comments to PBGC asking for reconsideration of the reporting requirements for small plans that fail to make required quarterly contributions. [Comments]
On October 28, 2008, the ASPPA College of Pension Actuaries participated in group comments submitted to the House Ways and Means Committee in response to the Committee’s Oct. 29 hearing on economic recovery, asking for consideration of certain PPA technical corrections and other funding relief. [Group Comments]
On August 1, 2008, ASPPA and COPA responded to the ASB’s request for comments on ASOP 27. [ASOP27 RFC Letter]
On July 21, 2008, ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed regulations regarding minimum required contributions. [Comment]
On March 31, 2008 ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed funding regulations, and requested revised proposed regulations be issued on both IRC 430 and 436. [Comment]
On March 27, 2008, ASPPA, in cooperation with COPA, submitted comments to Treasury and the IRS on their proposed regulations regarding hybrid defined benefit plans.[Comment]