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Froogle 1.1.1.7
Froogled By:
Elias Makere, FSA, MAAA
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ASOP 4 | §3.11 | LOW-DEFAULT-RISK OBLIGATION MEASURE

When performing a funding valuation, the actuary should calculate and disclose a low-default-risk obligation measure of the benefits earned (or costs accrued if appropriate under the actuarial cost method used for this purpose) as of the measurement date. The actuary need not calculate and disclose this obligation measure more than once per year.

When calculating this measure, the actuary should use an immediate gain actuarial cost method.

When calculating this measure, the actuary should select a discount rate or discount rates derived from low-default-risk fixed income securities whose cash flows are reasonably consistent with the pattern of benefits expected to be paid in the future. Examples of discount rates that may meet these requirements include, but are not limited to, the following:
a. US Treasury yields;

b. rates implicit in settlement of pension obligations including payment of lump sums and purchases of annuities from insurance companies;

c. yields on corporate or tax-exempt general obligation municipal bonds that receive one of the two highest ratings given by a recognized ratings agency;

d. non-stabilized ERISA funding rates for single employer plans; and

e. multiemployer current liability rates.
When plan provisions create pension obligations that are difficult to appropriately measure using traditional valuation procedures, such as benefits affected by actual investment returns, movements in a market index, or other similar factors, the actuary should consider using alternative valuation procedures such as those described under section 3.5.3 to calculate the low-default-risk obligation measure of those benefits earned or costs accrued as of the measurement date.

For purposes of this obligation measure, the actuary should consider reflecting the impact, if any, of investing plan assets in low-default-risk fixed income securities on the pattern of benefits expected to be paid in the future, such as in a variable annuity plan.

When calculating this measure, the actuary should not reflect benefit payment default risk or the financial health of the plan sponsor.

Other than the discount rate or discount rates, the actuary may use the same assumptions used in the funding valuation for this measure. Alternatively, the actuary may select other assumptions that are consistent with the discount rate or discount rates and reasonable for the purpose of the measurement, in accordance with ASOP Nos. 27 and 35.

The actuary should provide commentary to help the intended user understand the significance of the low-default-risk obligation measure with respect to the funded status of the plan, plan contributions, and the security of participant benefits. The actuary should use professional judgment to determine the appropriate commentary for the intended user.
ASOP 4 | Commentary Section 3.11 | COMMENT ON SECTION 3.11
Section 3.11, Low-Default-Risk Obligation Measure
CommentResponse
Several commentators suggested changing “...should calculate...” to “...should consider calculating...” in first paragraph of section 3.11.The reviewers disagree and made no change in response to this comment.
Several commentators provided alternative language for the variable annuity plan language in section 3.11.The reviewers modified the guidance to read, “For purposes of this obligation measure, the actuary should consider reflecting the impact, if any, of investing plan assets in low-default-risk fixed income securities on the pattern of benefits expected to be paid in the future, such as in a variable annuity plan.”
One commentator felt the ASB should include an explanation about why and how including LDROM disclosure provides appropriate and useful information for the intended user for inclusion in all funding valuations.The reviewers believe the guidance is appropriate and note the transmittal memorandum of the ASOP states, “...this additional disclosure provides a more complete assessment of a plan’s funded status and provides additional information regarding the security of benefits that members have earned as of the measurement date.”
One commentator stated it is not clear what “costs accrued” means in the context of section 3.11.The reviewers agree and clarified the guidance in response to this comment.
One commentator suggested modifying the language in the fourth paragraph of section 3.11 to state,
“When plan provisions create pension obligations that are difficult to appropriately measure using traditional valuation procedures, such as benefits affected by actual investment returns, movements in a market index, or other similar factors, the actuary should consider using alternative valuation procedures such as those described under section 3.5.3, including the use of alternative discount rates if indicated by such procedures, to calculate the low-default-risk obligation measure of those benefits earned or costs accrued as of the measurement date.”
The reviewers disagree and made no change in response to this comment. The reviewers note modifications were made to the fifth paragraph as follows: “For purposes of this obligation measure, the actuary should consider reflecting the impact, if any, of investing plan assets in lowdefault-risk fixed income securities on the pattern of benefits expected to be paid in the future, such as in a variable annuity plan.”
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