The Internal Revenue Service has released updates to the static mortality tables actuaries use to determine contribution requirements and funding levels of defined benefit pension plans.
The IRS allows plan sponsors to use static mortality tables, which are updated annually, as one of two ways to calculate projected mortality improvements. The use of so-called generational tables is also allowed.
This year’s updated static tables are based on the mortality assumptions determined by the Society of Actuaries in 2000.
They do not include revisions to base mortality rates first released by the Society of Actuaries in 2014. Those tables reflected improved longevity in life expectancy: the average 65-year old male was projected to live to 86.6 years of age, an increase of two years over the 2000 tables, and the average female was expected to live to be 88.8, and increase of 2.4 years from 2000 projections.
In September of 2015, the IRS announced it was delaying implementation of the Society of Actuaries’s 2014 mortality tables, given the substantial criticism from actuaries and plan sponsors that the organization’s 2014 tables used incomplete data, resulting in exaggerated improvements in longevity that ultimately would require unnecessarily high contributions from plan sponsors to fund their pension plans.
In response to those criticisms, the Society of Actuaries released adjustments to the 2014 tables in October of 2015, reflecting a tempered assessment of increased longevity: for men, average lifespan projections remained at 86.6, but for women it was revised downward to 88.2.
Final regulations to apply in 2018
In last year’s annual update of static mortality tables, the IRS said it was considering stakeholders’ input to the Society of Actuaries’s latest mortality tables, and that it expected to have them implemented by 2017.
But in releasing this year’s static table updates, the IRS said it is still considering the effect of the organization's revised base mortality tables, and that it expects final issued regulations on the updated base mortality tables to begin applying in 2018.
In May of 2016, the American Benefits Council, which represents the interests of the largest sponsors of defined benefit plans, wrote the IRS urging them to delay implementation of the updated base mortality tables for at least one year after final rules were issued.
Sponsors need adequate time “in order to adjust business plans to take into account the new assumptions,” argued the council’s general counsel, Lynn Dudley, in the letter to officials at the U.S. Department of Treasury. “This process cannot be squeezed into a short period of time in the case of very significant and complicated changes.”
In delaying implementation of the new base tables until 2018, the Treasury Department said it still expects to issue proposed regulations that include the revised mortality tables, but it did not say when those proposals would be released.
Any delay in implementation of the updated tables will come as a relief to plan sponsors. Analysts at ratings agency Moody’s said the companies it tracks saved a collective $18 billion in pension funding requirements in 2016 by not having to account for the updated base mortality tables.
Go to the IRS site for a link to the updated static mortality tables for 2017.
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