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]