Dominic DeMatties, Farhad Saghir, Earl Pomeroy, and David Godofsky spoke during this event hosted by Cheiron.
Dominic DeMatties presented during the sessions:
Missing Participants and Post‐NRA Issues - Finding missing deferred vested participants has been getting more attention over the last year. The Department of Labor finds that some plans are not doing a good job locating missing participants that are due benefits. The IRS recently revised instructions for the Form 5500, Schedule H, Question 4(I) to clarify that failure to provide benefits when due includes failure to timely start payment of required minimum distributions unless reasonable efforts have otherwise been made to find them. Has your plan sponsor been making a reasonable effort? As plan administrators and their actuaries focus more on these missing deferred vested participants, we must often work through requirements around applying late retirement actuarial increases, whether retroactive payments apply, and how to handle payments starting after 70 ½ required minimum distribution. In some cases, we’ve found VCP filings are necessary to correct past practice.The panel explored what reasonable efforts a plan administrator might take, what tools are available to find missing participants, and at what point benefits may be forfeited. We also covered how to determine benefits commencing after NRA, issues with after 70 ½ commencement, and VCP filing experience.
Partitions, Suspensions & Applicants’ Experience - The Multiemployer Pension Reform Act of 2014 modified the rules for partitions (which need PBGC approval) and added the possibility of benefit suspensions (which need Treasury approval). Final regulations have been issued and had important changes from the proposed rules. Presenters reviewed the state of the guidance and provided an overview of the actuarial aspects of applications, analyzing denials and approvals to date (including the Treasury suspension decision on the Central States application).
Farhad Saghir presented during the sessions:
Actuarial Equivalence - In recent years, interest rates have come down, and stayed down, and new mortality studies have confirmed that life expectancies have increased. Many plans have actuarial equivalence definitions for optional form factors, early commencement reductions, and other purposes that were developed in a very different environment. The release by the IRS of proposed updated mortality tables presents a good opportunity for plan sponsors to review their plans’ actuarial equivalence assumptions. Presenters at this session explored the related issues with respect to ERISA compliance, relative value demonstrations, developing annuity benefits at earlier commencement ages under bulk lump sum programs, and IRC §411(d)(6) protections that apply when actuarial assumptions are changed.
4010 Refresher for the Recently Afflicted - With the recent regulation change, many more actuaries are seeing clients affected by 4010 reporting. Panelists at this session provided a comprehensive recap of how to determine who needs to file (including possible waivers), what must be filed, how to determine the actuarial liabilities for the filing, and the actual e-filing process. Whether you are newly involved in 4010 or it’s just been a few years since you had the pleasure, attending this session brought you up to speed.
Earl Pomeroy presented during the session:
We Survived the Election - Now What? - With a new Administration and Congress, what changes can we expect on the benefits and retirement policy front? Is tax reform a real possibility? What would it mean? The panelists discussed likely priorities of the new Administration and the new Congress with respect to overall retirement policy, Social Security reform, taxation, regulation of fiduciaries, and other matters that affect the design and operation of retirement programs. Possible priorities of relevant government agencies were also explored.
David Godofsky presented during the sessions:
Accrual Rule Testing - Panelists provided an overview of the accrual rules and outstanding issues. Concerns that have arisen in IRS audits and determination letter filings were also discussed, as well as experiences with making changes to satisfy IRS auditors. Finally, the speakers explored creative approaches to correcting accrual rule failures.
Ethics - In this highly interactive session, panelists and audience members debated solutions to difficult ethical situations faced by actuaries in their day-to-day practice.
More Ethics - In this highly interactive session, panelists and audience members debate solutions to difficult ethical situations faced by actuaries in their day-to-day practices, including conflicts of interest, disagreements among actuaries, and working with difficult clients.
Reducing Professional Liability Risk - In this interactive session, panelists and audience members discussed practice management issues, such as quality control, work flow, and internal and external communications, that can impact the risk of being sued for malpractice.