ERIC Submits Comments on Funding Regulations

ERIC submitted comments on proposed regulations regarding the measurement of assets and liabilities for pension funding purposes, highlighting primary issues on asset smoothing, ancillary disability benefits, identifying at-risk plans, publication of the full yield curve, and transition issues.

The Treasury Department and Internal Revenue Service on December 31, 2007, published in the Federal Register the proposed regulations, which would implement changes made by the Pension Protection Act of 2006 that made extensive changes to the minimum funding requirements. The proposed regulations address the determination of funding target and target normal cost, valuation date and value of plan assets, interest rates, and plans in at-risk status.

ERIC urged substantial revision and clarification of the regulations, that if the proposed regulations take effect in their current form, they will unnecessarily increase the size and volatility of employers’ funding obligations, and will further weaken a defined benefit retirement system that is already under severe stress.

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