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Old 07-22-2014, 02:39 PM
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Mary Pat Campbell
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Default Actuarial Standards Board Request for Comment on Public Pension Practice

Here:
http://www.actuarialstandardsboard.o...C_July2014.pdf

Quote:
This document contains a request for comments concerning the application of the
Actuarial Standards of Practice (ASOPs) in regards to actuarial valuations and other
analyses used for determining public pension and other postemployment plan funding
and accounting (“public plan actuarial valuations”). Please review this letter and provide
the ASB the benefit of your comments and suggestions. Each written response and each
response sent by e-mail to the address below will be acknowledged, and all responses
will receive appropriate consideration by the ASB.
......
Request for Comments
The ASB intends to undertake a comprehensive review of the ASOPs as they pertain to
public plan actuarial valuations. As it begins its review, the ASB would like to solicit the
views of actuaries and others who are interested in the application of the ASOPs to public
plan actuarial valuations. The ASB welcomes comments on any issues relevant to this
matter, and would like to draw readers’ attention to the following questions in particular:

1. Public plan funding and associated actuarial valuations are less uniformly
regulated than those of private sector pension plans. Actuaries may be asked by
their principal to advise on funding levels. Is additional guidance needed, beyond
that in the recently revised pension ASOPs, regarding appropriate public plan
actuarial valuation practice to assist actuaries in performing their work and
advising their principal? Why or why not?

2. If yes to question 1, in what areas is additional guidance needed?

3. If yes to question 1, should that guidance take the form of a separate public plan
actuarial valuation standard or be incorporated within the existing ASOPs? Why
or why not?

4. In general, the ASOPs are principles based and not rules based. As a result, the
ASOPs are generally not highly prescriptive. Should the ASOPs related to public
plan actuarial valuations be more prescriptive? If so, in what areas?

5. The ASOPs have provided guidance that has been applicable to all areas of
practice in the pension community (for example, private sector, multiemployer,
public sector). If you believe that additional guidance is needed for public plan
actuarial valuations, should any of that additional guidance also apply to non-public
sector plans? Why or why not?

6. The current definition of an “intended user” of an actuarial communication is
“any person who the actuary identifies as able to rely on the actuarial findings”
(ASOP No. 41, Actuarial Communications, section 2.7). Should the ASOPs
require the actuary for public pension plans to perform additional, significant
work (which would be incorporated in the guidance provided in the ASOPs) that
is not requested by the principal if that work provides useful information to
individuals who are not intended users? Why or why not? If so, should this
requirement be extended to all pension practice areas? Why or why not?
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Old 10-23-2014, 03:08 PM
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Mary Pat Campbell
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Default

I have a draft letter, but I'd like other people to review before I send.

Please PM me if you'd like to review. I can send PDF or in Word format (so you can propose edits, stick comments in situ, etc.)
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Old 10-26-2014, 02:21 PM
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Quote:
6. The current definition of an “intended user” of an actuarial communication is “any person who the actuary identifies as able to rely on the actuarial findings” (ASOP No. 41, Actuarial Communications, section 2.7). - ASB
Quote:
First of all, it is imperative that we change the “who” to “whom” in ASOP 41. - Charles E. Chittenden
.
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Old 10-26-2014, 02:31 PM
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Old 10-28-2014, 01:23 PM
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Mary Pat Campbell
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last call (to comment on my comments -- ASB comment period is still open for a while)

I am sending my comments tomorrow.
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Old 10-29-2014, 10:00 AM
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Mary Pat Campbell
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Default

Thanks for the comments!

My comment letter is attached to this post.

I am considering a followup in light of info of the Detroit-related lawsuits against GRS
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File Type: pdf MPC Comments to ASB on Public Pension Funding.pdf (266.6 KB, 222 views)
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Old 10-30-2014, 04:31 PM
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Mary Pat Campbell
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My letter was posted.

Reminder, all the comment letters can be seen here:
http://www.actuarialstandardsboard.o...g_Comments.asp

SOA should be having one up soon:
https://www.soa.org/News-and-Publica...s-Meeting.aspx

Quote:
SOA Response to ASB: The Board reviewed and approved a letter to be sent to the Actuarial Standards Board in response to their request to the profession and the public for comments on public pension plan-related standards (Request for Comments – ASOPs and Public Pension Plan Funding and Accounting). Once the letter is sent to the ASB, it will be posted on SOA.org.

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Old 10-30-2014, 06:47 PM
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The letter from the SOA has now been posted.
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Old 10-30-2014, 09:57 PM
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Quote:
Originally Posted by SOA
ASOPs ensure the purchaser of actuarial services (organizations) receive consistent and thorough actuarial work; they are not written to protect the product’s end user (e.g. public sector plan participants) or the general public. Contrast this with the role of Financial Accounting Standards, which do have a purpose to protect shareholders and bondholders.
Why not? I thought we were a profession. What separates a profession from a skill set are standards and duties to protect the product's end user, including, in the case of public plans, the general public.

Shame on us.
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Old 10-30-2014, 10:03 PM
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Quote:
Originally Posted by exactuary View Post
Why not? I thought we were a profession. What separates a profession from a skill set are standards and duties to protect the product's end user, including, in the case of public plans, the general public.

Shame on us.
That is a mind boggling idiotic statement by the SoA.

Quote:
Originally Posted by Precept 1
An Actuary shall act honestly, with integrity and competence, and in a manner to fulfill the profession's responsibility to the public and to uphold the reputation of the actuarial profession.
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