EA7: Regulatory Climate Change

If there was an underlying theme to the 2017 Enrolled Actuaries meeting it was uncertainty – as to what the tax laws will be and how the current laws would be interpreted and regulated. From session 701: Dialogue with the IRS/Treasury here are my notes on issues not previously covered:

The policies of the new administration are “not well-defined.”

Guidance process slowed down – no regulations.

No policy direction.

Trump’s ‘Two-for-One’ Executive Order on regulations is difficult to implement since there is confusion as to the definition of a ‘regulation’ that would be counted as one of the two that had to be repealed in order to implement a new one.

Unreliable Determination letters (DL):

  • Have facts changed?
  • Has law changed?
  • Were facts hidden?

Average DL takes three hours of review so some DLs may not have been correct (like those church plan letters?)

Project is underway to update Top-Heavy regulations for statutory changes since their effective date in 1983.


One response to this post.

  1. Posted by Now Retired Pat on April 18, 2017 at 2:25 pm

    Funny how my Prudential Deferred “guaranteed” account is 2.31% (not bad, actually),but the expected rate of return is 7.5%?


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