Pension Committee 4 30 01 comment letter on RP-2000 mortality table

April 27, 2001Mr. Mark Weinberger Assistant Secretary of the Treasury for Tax PolicyDepartment of the Treasury1500 Pennsylvania Avenue, NWWashington, DC 20220Dear Assistant Secretary Weinberger:On behalf of the American Academy of Actuaries, the Academy Pension Committeewould like to offer assistance to the Department of Treasury (Treasury) in determiningwhich mortality table to use for current liability purposes under the Internal RevenueCode. The RP-2000 Mortality Table was recently developed and approved by theSociety of Actuaries (SoA). As noted on page 4 of the enclosed RP-2000 Mortality Tables Report, data was collectedfor this study for the express purpose of providing a mortality table that could be used forpension plans, particularly for current liability determinations. The RP-2000 MortalityTable, as described below, will come closer than any other mortality table available toachieving the statutory goal to, “take into account results of available independent studiesof mortality of individuals covered by pension plans” (IRC Section 412(l)(7)(C)(ii)(II)).Below is a description of the study’s background and pertinent findings and ourrecommendation for the mortality table(s) to be used for current liability determinations.Throughout the Report, there are references to blue-collar and white-collar employeesand those terms have been used in this letter to be consistent with the terminology in theReport. Depending on the final approach to ...