ERIC Asks Treasury and OMB for Additional Review of Mortality Table Regulations

For Immediate Release

Washington, DC – The ERISA Industry Committee (ERIC) today submitted a letter to the U.S. Department of Treasury and Office of Management and Budget urging the agencies to deem the defined benefit mortality table proposed regulations subject to Executive Orders 12866 and 13771, causing the regulations to receive additional review, including a thorough economic analysis.

As the only national association that advocates exclusively for large employers on health, retirement, and compensation public policies at the state, federal, and local levels, ERIC has a strong interest in proposals like the proposed rule, that would affect our members’ ability to provide predictable and secure pension benefits in an efficient and tax-compliant manner.

“We encourage Treasury and OMB to review the process utilized to determine whether these regulations have a significant impact on the economy,” said Will Hansen, Senior Vice President of Retirement and Compensation Policy, ERIC. “Most regulatory actions that impact employee benefits lead to a substantial financial impact on plan sponsors across America. Subjecting these regulations to further review and an economic analysis will not only assist plan sponsors in providing quality benefit programs, but also the millions of individuals who  receive such benefits.”

Also today, Bruce Cadenhead, Chief Actuary, Mercer testified on ERIC’s behalf before the Internal Revenue Service asking that the agency reconsider the substance and the process of the regulation.

In comments submitted in March, ERIC stressed that the regulatory process should be more rigorous to determine the economic impact on plan sponsors. ERIC is concerned that revisions to mortality improvement rates could make it difficult for plan sponsors to budget for future cash flows and for participants to plan for retirement if such updates are not provided on a timely basis. ERIC also asked that the IRS allow for a sufficient transition time and not impose unnecessarily burdensome data collection requirements for newly acquired plans.

Click here to read ERIC’s letter to the U.S. Department of Treasury and Office of Management and Budget.


All media inquiries to The ERISA Industry Committee should be directed to:

Kelly Broadway, 202.627.1918,

About the ERISA Industry Committee
ERIC is the only national association that advocates exclusively for large employer plan sponsors on health, retirement, compensation, and paid leave public policies at the federal, state, and local levels. With member companies that are leaders in every sector of the economy, ERIC promotes uniformity and flexibility for nationwide benefit plans.