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Solicitation for Comments on the Regulations Governing the
Performance of Actuarial Services Under the
Employee Retirement Income Security Act of 1974 by the
Joint Board for the Enrollment of Actuaries
September 27, 2004
The American Society of Pension Actuaries (ASPA) offers these comments in response to
the Solicitation for Comments on the Regulations Governing the Performance of Actuarial
Services Under the Employee Retirement Income Security Act of 1974 by the Joint Board for
the Enrollment of Actuaries (JBEA).
ASPA is a national society of retirement plan professionals. ASPA’s mission is to educate
pension professionals and to preserve and enhance the private pension system. Its
membership consists of more than 5,000 actuaries, plan administrators, attorneys, CPAs and
other retirement plan experts who design, implement and maintain qualified retirement plans.
ASPA’s membership includes more than 700 enrolled actuaries.
ASPA commends the JBEA for engaging in this review of its current regulations in regard to
the enrollment and monitoring of enrolled actuaries. At this time when retirement security is
foremost on the minds of many Americans, as well as members of Congress and the
Administration, ASPA supports the JBEA’s efforts to ensure that the provision of actuarial
services meets appropriate standards.
ASPA’s comments on the existing regulations and our recommendations for modifications
are outlined below. The following is a general summary of the items discussed:
Actuarial Discipline. ASPA believes that the JBEA has not taken a sufficiently
strong role in the supervision of the provision of actuarial services and the discipline
of enrolled actuaries who do not conform to the prevailing standards of conduct.
ASPA encourages the JBEA to become more active in this process, and to modify its