Froogle | ASOP 4 | Commentary 3.10

Section 3.10, Market-Consistent Present Values
Comment	Response
One commentator suggested eliminating this section and stated that, if the concept is retained, it should be made clear that ABO and PBO under ASC 715 are likely not market consistent present values.	The reviewers believe the guidance is appropriate and made no change in response to this comment.
One commentator suggested that if section 3.10 is retained, the portion permitting the reflection of payment default risk or the financial health of the sponsor should be eliminated.	The reviewers disagree and made no change in response to this comment.
One commentator stated that in sections 3.10 and 3.11 it is not clear whether “benefits earned as of the valuation date” are the same thing as “accrued benefits” in section 3.9, Measuring the Value of Accrued or Vested Benefits. If so, the ASOP should use the same terminology in all three of these sections. If a distinction is intended, it should be made clear what the difference is.	The reviewers clarified the guidance in section 3.9 in response to this comment.

user comments