Pensions

Policy Priorities for 2008

• Urge Congress to enact technical corrections to the Pension Protection Act of 2006 (PPA), ensuring that the agreements and compromises made in the PPA remain intact.
• Aggressively pursue regulatory guidance stemming from the Pension Protection Act of 2006. 

• Work to ensure that overly burdensome requirements for plan fee disclosure, generated in response to attention garnered from lawsuits and Capitol Hill, are not implemented by regulation or statute.

• Monitor and engage with the Financial Accounting Standards Board (FASB) as it evaluates and proposes changes to the accounting standards for measuring pension and other benefit costs, obligations, and assets. Indications are that FASB intends to remove smoothing periods from the measure of liabilities, which will likely be controversial and have significant negative consequences for employers with defined benefit pension plans.

• Continue to address the legal, fiscal, policy, and practical barriers to phased retirement.
• Actively participate in the Phased Retirement Working Group sponsored by Workplace Flexibility 2010. The purpose of the working group is to find common ground among groups that usually have varying opinions about this issue.

• Work to ensure that the Treasury Department issues guidance on asset smoothing in accordance with the intent of the PPA. It is our understanding that Treasury intends to issue guidance stating that "averaging" (the term used in the PPA) differs from smoothing. Such an interpretation could lead to significant unpredictability for defined benefit plans.

• Continue to monitor regulatory and statutory activity to prevent overly burdensome rules and regulations on nonqualified deferred compensation.