The Internal Revenue Service is trying to give pension plan administrators and others the figures they need to calculate defined benefit plan present values and contribution levels in the coming year.
The IRS published final regulations in February that permit plans to use “blended mortality tables” for workers and benefit recipients this year, because of the need to overhaul actuarial systems to cope with the effects of the Pension Protection Act of 2006.
In 2008, the IRS wants plans to use separate tables for “annuitants” and “nonannuitants,” IRS officials write in a preamble to the proposed mortality table regulations, which appeared in the Federal Register.
The IRS uses the term “annuitants” to refer to retirees, and the term “nonannuitant” to refer both to terminated vested participants and to active workers.
Although using separate tables is more complicated, the IRS and the Treasury Department “believe that failing to project mortality improvement in determining the funding target would tend to result in underfunding,” officials write.
The proposed “generally applicable mortality tables” would be based on the RP-2000 Mortality Tables Report, which was developed by the Society of Actuaries, Schaumburg, Ill.
Plan administrators could choose between using a static version of the table and generational mortality tables, which would provide different projected mortality rates for workers of different ages.
Administrators of small plans could continue to use a single blended static table, officials write.
The IRS wants to create separate tables for disabled plan participants, and it is asking for comments about whether it would be desirable to publish a series of static mortality tables for each of a number of years, such as 5 years, along with the final regulations, and to publish the subsequent tables at a later date.
Comments on the proposed mortality table regulations are due Aug. 27.
Executives at the American Benefits Council, Washington, say council members and others accept the fact that, in many cases, the improved mortality expectations incorporated in the new mortality tables will lead to increases in funding requirements.
IRS officials have responded to pension plan professionals’ desire for flexibility by giving plans the ability to use substitute tables that reflect their own plans’ actual mortality, the executives say.
But one concern is that “you have to have 1,000 deaths in 4 years for each of your male and female populations,” says Jan Jacobson, the council’s retirement policy director. “That’s really going to limit use of the substitute mortality tables.”
In addition to increased flexibility for would-be users of substitute tables, the benefits council also would like to see accommodations for plans that have a large percentage of healthy early retirees because of employer early retirement programs, Jacobson says.