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Froogled By:
Elias Makere, FSA, MAAA
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ASOP 4
(MEASURING PENSION OBLIGATIONS AND DETERMINING PENSION PLAN COSTS OR CONTRIBUTIONS)
SECTION 4
(COMMUNICATIONS AND DISCLOSURES)

Section 4
Communications and Disclosures

ASOP 4 | §4.1 | REQUIRED DISCLOSURES IN AN ACTUARIAL REPORT

When issuing an actuarial report to which this standard applies, the actuary should refer to ASOP Nos. 23, 27, 35, 41, 44, 51, and 56. In addition, such communication should contain the following disclosures when relevant and material. An actuarial communication can comply with some, or all, of the specific requirements of this section by making reference to information contained in other actuarial communications available to the intended users (as defined in ASOP No. 41), such as an annual actuarial valuation report.
a. a statement of the purpose of the measurement and a statement to the effect that the measurement may not be applicable for other purposes (see section 3.3);

b. the measurement date (see section 3.4);

c. a description of adjustments made for events after the measurement date (see section 3.4.2);

d. a description of adjustments of prior measurements (see section 3.4.3);

e. an outline or summary of the plan provisions reflected in the actuarial valuation, a description of known changes in significant plan provisions reflected in the actuarial valuation from those used in the immediately preceding measurement prepared for a similar purpose, and a description of any significant plan provisions not reflected in the actuarial valuation, along with the rationale for not reflecting such significant plan provisions (see section 3.5);

f. a description of the valuation procedures used to value any significant plan provisions of the type described in section 3.5.3, such that another actuary qualified in the same practice area could make an objective appraisal of the reasonableness of the actuary’s work as presented in the actuarial report (see section 3.5.3);

g. the date(s) as of which the participant and financial information were compiled;

h. a summary of the participant information (see section 3.6.1);

i. if hypothetical data are used, a description of the data (see section 3.6.2);

j. a description of any accounting policies or funding elections made by the principal that are pertinent to the measurement (see section 3.7);

k. a description of known changes in significant assumptions and methods from those used in the immediately preceding measurement prepared for a similar purpose. For assumption and method changes that are not the result of a prescribed assumption or method set by another party or a prescribed assumption or method set by law, the actuary should include an explanation of the information and analysis that led to those changes. The explanation may be brief but should be pertinent to the plan’s circumstances (see section 3.8);

l. a statement indicating whether, in the actuary’s professional judgment, the combined effect of the assumptions other than
1) prescribed assumptions or methods set by law and

2) assumptions that the actuary has not selected and is unable to assess for reasonableness for the purpose of the measurement is expected to have no significant bias (i.e., it is not significantly optimistic or pessimistic), except when provisions for adverse deviation are included or when alternative assumptions are used for the assessment of risk, in accordance with ASOP No. 51 (see section 3.8);
m. a description of the types of benefits regarded as accrued or vested if the actuary measured the value of accrued or vested benefits, and, to the extent the attribution pattern of accrued benefits differs from or is not described by the plan provisions, a description of the attribution pattern (see section 3.9);

n. a description of whether and how benefit payment default risk or the financial health of the plan sponsor was included, if a market-consistent present value measurement was performed (see section 3.10);

o. if applicable, a low-default-risk obligation measure (see section 3.11). In addition to the measure, the actuary should disclose the following:
1. the discount rate or discount rates used and rationale for selection;

2. a description of other significant assumptions, if any, that differ from those used in the funding valuation and rationale for their selection;

3. the immediate gain actuarial cost method used;

4. a description of the valuation procedures that differ from those used in the funding valuation to value any significant plan provisions of the type described in section 3.5.3 such that another actuary qualified in the same practice area could make an objective appraisal of the reasonableness of the actuary’s work; and

5. 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;
p. a description of the actuarial cost method and the manner in which normal costs are allocated, in sufficient detail such that another actuary qualified in the same practice area would be able to understand the significant characteristics of the method (for example, how the actuarial cost method is applied to multiple benefit formulas, compound benefit formulas, or benefit formula changes, where such plan provisions are significant) (see section 3.13);

q. if applicable, a description of the particular measures of plan assets and obligations that are included in the actuary’s disclosure of the plan’s funded status. For funded status measurements that are not prescribed by federal law or regulation, the actuary should accompany this description with each of the following additional disclosures:
1. whether the funded status measure is appropriate for assessing the sufficiency of plan assets to cover the estimated cost of settling the plan’s benefit obligations;

2. whether the funded status measure is appropriate for assessing the need for or the amount of future contributions; and

3. if applicable, a statement that the funded status measure would be different if the measure reflected the market value of assets rather than the actuarial value of assets;
r. funded status based on an immediate gain actuarial cost method if the actuary discloses a funded status based on a spread gain actuarial cost method (see section 3.13). A description of the immediate gain actuarial cost method used for this purpose should be disclosed;

s. the remaining balance to be amortized, the remaining amortization period, and the amortization payment included in the periodic cost or actuarially determined contribution for each amortization base along with a disclosure if the unfunded actuarial accrued liability is not expected to be fully amortized (see section 3.14);

t. a description of any output smoothing method used. If an output smoothing method is used, the actuary should also disclose the corresponding actuarially determined contribution without output smoothing (see section 3.16);

u. a description of the cost allocation procedure or contribution allocation procedure including a description of the amortization method and any pay-asyou-go funding (i.e., the intended payment by the plan sponsor of some or all benefits when due) (see section 3.17);

v. a description of all changes in cost allocation procedures or contribution allocation procedures that are not a result of a prescribed assumption or method set by law, including the resetting of an actuarial asset value. The actuary should disclose the reason for the change and the general effects of the change on relevant periodic cost, actuarially determined contribution, funded status, or other measures by words or numerical data, as appropriate. The disclosure of the reason for the change and the general effects of the change may be brief but should be pertinent to the plan’s circumstances (see section 3.17);

w. a qualitative description of the implications of the contribution allocation procedure or plan’s funding policy on future expected plan contributions and funded status (see section 3.19[a]), if applicable. The actuary should disclose the significant characteristics of the contribution allocation procedure or plan’s funding policy, and the significant assumptions used in the assessment;

x. if applicable, an estimate of how long before any contribution as determined by the contribution allocation procedure or the plan’s funding policy is expected to exceed the normal cost, plus interest on the unfunded actuarial accrued liability (see section 3.19[b]);

y. an estimate of the period over which the unfunded actuarial accrued liability, if any, is expected to be fully amortized (see section 3.19[c]);

z. if applicable, a statement indicating that the contribution allocation procedure or funding policy is significantly inconsistent with the plan accumulating adequate assets to make benefit payments when due, as well as an estimate of the approximate time until assets are depleted (see section 3.19[d]);

aa. if applicable, a reasonable actuarially determined contribution, the corresponding funded status, and any material assumptions or methods that were used in the calculation that are not otherwise disclosed. The actuary should include a description of how pertinent conditions discussed in section 3.17 have been taken into account in determining the reasonable actuarially determined contribution (see section 3.21). The disclosure may be brief but should be relevant to the plan’s circumstances;

bb. if applicable, the results of the gain and loss analysis separating the total gain or loss into investment gain or loss and other gain or loss. The actuary may meet the disclosure requirements of this section by providing more detailed results of the gain and loss analysis performed (see section 3.22). For example, the actuary could separate the non-investment gain or loss into demographic and economic gains or losses, or could identify gains or losses caused by individual decrements (for example, withdrawal, retirement, mortality) and other economic factors (for example, salary growth, inflation);

cc. if, in the actuary’s professional judgment, the actuary’s use of approximations and estimates could produce results that differ materially from results based on a detailed calculation, a statement to this effect (see section 3.25); and

dd. a statement, appropriate for the intended users, indicating that future measurements (for example, of pension obligations, periodic costs, actuarially determined contributions, or funded status, as applicable) may differ significantly from the current measurement. For example, a statement such as the following could be applicable: “Future actuarial measurements may differ significantly from the current measurements presented in this report due to such factors as the following:
plan experience differing from that anticipated by the economic or demographic assumptions;

changes in economic or demographic assumptions;

increases or decreases expected as part of the natural operation of the methodology used for these measurements (such as the end of an amortization period or additional cost or contribution requirements based on the plan’s funded status); and

changes in plan provisions or applicable law.” (See section 3.23)

In addition, the actuarial communication should include one of the following:
1. if the scope of the actuary’s assignment included an analysis of the range of such future measurements, disclosure of the results of such analysis together with a description of the factors considered in determining such range; or

2. a statement indicating that, due to the limited scope of the actuary’s assignment, the actuary did not perform an analysis of the potential range of such future measurements.

ASOP 4 | §4.2 | DISCLOSURES IN AN ACTUARIAL REPORT ABOUT ASSUMPTIONS OR METHODS NOT SELECTED BY THE ACTUARY

The actuary should include disclosures in an actuarial report stating the source of any material assumptions or methods that the actuary has not selected.

With respect to any assumption or method that the actuary has not selected, other than prescribed assumptions or methods set by law, the actuary’s report should identify the following, if applicable:
a. any assumption or method that the actuary has not selected that, individually or in combination with other assumptions or methods, significantly conflicts with what, in the actuary’s professional judgment, is reasonable for the purpose of the measurement (see section 3.24); or

b. any assumption or method that the actuary has not selected and is unable to assess for reasonableness for the purpose of the measurement.

ASOP 4 | §4.3 | ADDITIONAL DISCLOSURES IN AN ACTUARIAL REPORT

ASOP 4 | §4.4 | CONFIDENTIAL INFORMATION


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