The group noted that modifying the rules to moderate the funding requirements in times of extreme and unsustainable interest rates would provide much-needed stability. ASPPA said it is critical that the modifications to the funding requirements be adopted in time to be effective for 2012.
However, since it is May, and actuarial calculations for 2012 have already been completed for many plans, the group asked that application of the modifications to 2012 be elective. Employers that can afford to make the contributions based on current interest rates may have already committed those amounts, and would prefer not to incur the additional expense of having the calculations redone, the letter noted.The ASPPA letter is here.
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