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  #61  
Old 11-16-2014, 04:28 PM
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Mary Pat Campbell
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fwiw, the direct links to later letters also do not work




blame the intern!
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  #62  
Old 11-16-2014, 08:14 PM
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Thank goodness, I can still read Ken Kent's letter and it's still brilliant from start to finish!
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  #63  
Old 11-18-2014, 02:51 PM
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It's fixed.

http://www.actuarialstandardsboard.o...g_Comments.asp

I'm downloading all the letters now, just in case.
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  #64  
Old 11-18-2014, 02:57 PM
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Okay, I have 31 letters.

For some reason, I thought there were letters after Alberto's. Am I misremembering?
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  #65  
Old 11-18-2014, 02:58 PM
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Yeah. My 11/15 comment letter is not posted yet.
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  #66  
Old 11-18-2014, 03:05 PM
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Okay, that's what I was thinking of.

Of course, there may be others.
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  #67  
Old 11-18-2014, 03:42 PM
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When my letter gets posted, note that the bullet points on page 1 are internal hyperlinks. Adobe doesn't have a back button per se, but Alt-Left Arrow should work on a PC (Ctrl-left arrow on a mac).
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Old 11-18-2014, 04:57 PM
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I was very pleased to read Alberto's preamble:
Quote:
Originally Posted by Alberto Dominguez
Before addressing the specific questions posed, I’d like to comment on the principle underlying my responses. It has long been my observation that the ASOPs codify a “consensus practice” or “current practice” standard, rather than a stronger “best practice” standard. Presumably, the driving force behind this is concern that a stronger standard could be used as a weapon in litigation against actuaries. I believe that ultimately such an approach is short-sighted and will not protect actuaries. If society decides that the practice codified in the ASOPs is not reasonable, then actuaries will become the targets of litigation and the defense that “we followed the ASOPs” won’t protect us. In the long run, only rigorous standards will serve as an adequate shield for our profession. This is of particular and immediate concern in the public plan arena, which is experiencing substantial and well-publicized financial stress.
It has been twelve years since a group of us (I think we were seven) sent this to the ASB: http://users.erols.com/jeremygold/asop_comments_asb.pdf

We were naive and accordingly surprised when everything we had to say was rejected out of hand with the observation that the ASB does not do best practice. I remember thinking "ok, we can use other words, what did you think about the rest of what we had to say?" We know now that identification of market value as the best value even if other values are acceptable is anathema to the ASB (despite comments by Jackson and Hamilton in 1968 to the effect that market value was well understood to be the most economically meaningful value -- btw, Jackson-Hamilton was trying to get rid of the common "book value" approach and they were willing to compromise) and so it was only a continuation of our naivete for us to believe that the ASB would have listened if we had only refrained from cursing ourselves with the dreaded "BP" words.

Ten years ago, we had an opportunity to challenge the consensus approach in favor of a science driven approach. We also had easily gathered 24 signatories from life, health, pensions and property/casualty actuaries: http://users.erols.com/jeremygold/as...mmentsanon.pdf

That went well, don't you think?

Alberto cautions us that only rigorous standards can protect us in the long run. Sooner or later there will be a legal challenge to our standards as shields that protect us when it becomes clear that it is very hard to violate standards that only require us to consider, disclose and document. The pension ASOPs don't actually tell us what to do, only what to consider. It is hard to violate a standard that requires one to consider. And Alberto's point is clear, if standards are difficult to violate (btw, I think the Code of Conduct is stronger), then they are likely to be pretty thin shields when actuaries raise their compliance with the standards as a defense.

So it is 2014 and what has happened since 2004? Alberto nails this too. City and state plans are a disaster area and don't really look like they are yet serious about pension reform. The left doesn't want to take away any benefits -- even benefits not yet earned -- and the right wants the situation to get so bad that the only fix will be DC plans.

When my comments are posted, please note that I challenge the artificial contest between being "principles based" and being "prescriptive." These are not antonyms. FASB writes standards that are based on accounting principles and are far more prescriptive than the ASOPs. Until a better example comes along, FASB stands as the exemplary purveyor of standards with the rigor espoused by Alberto.

Than you Alberto.
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  #69  
Old 11-18-2014, 05:08 PM
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55 and counting

lot to read
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  #70  
Old 11-18-2014, 05:17 PM
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Whoa, there was a backlog. Time to download more letters.
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