I learned a lot (and some of it may be true):
- My new Microsoft Surface 4 holds a charge for only about 3 hours.
- Because large new comparability plans did not want to put in gateway minimums they got the IRS to burden small plans who will likely wind up having to put in higher gateways to maintain their plans under proposed regulations.
- It may be 2018 before the IRS opens the document approval process for Defined Benefit plans.
There was also a lot missing (and some of it may be for good):
- no speaker or entertainment at the first-day luncheon
- no recording of meetings
- no IRS participation
But the main takeaway for me came from the opening plenary session of the 41st Enrolled Actuaries meeting (are there any guarantees in life?).
The job of Enrolled Actuary was created by ERISA in 1974 primarily to assure that promised benefits under Defined Benefit plans were adequately funded.
Now at the 2016 EA meeting the kickoff session examined how the three main segments of the Defined Benefit world were cutting benefits (primarily because they were not going to be able to fund them):
- Single-employer plans: though the session focused on litigation involving anti-cutback rules it could have been noted that there are so few substantial plans who have not yet frozen benefit accruals that, aside from being tax deduction vehicles for small employers, they barely register.
- Multiemployer (union) plans: where a mechanism is in place (MEPRA 2014) to cut accrued benefits.
- Public plans: where benefit cuts are only slowed by the speed bumps (where they exist) of contracts clauses and constitutional pension protection clauses.
Enrolled Actuaries need to take some (if not most) of the responsibility for these failures.