National Association of State Retirement Administrators


Letters, Comments, & Testimony

2016
  • April 26, 2016 - Joint comments from national public pension organizations on proposed regulations regarding the application of federal normal retirement age regulations to governmental plans. 

  • April 11, 2016 - Response from NASRA to Andrew Biggs article in Forbes Magazine regarding public sector spending on pensions

  • March 14, 2016 - Joint letter from national organizations representing state and local governments, elected officials, public finance professionals, employee organizations, and state and local retirement systems to Members of the U.S. House of Representatives in opposition to legislation that would impose conflicting, costly and inappropriate federal regulations and steep penalties for non-compliance. 

  • February 10, 2016 - Joint letter from national public sector organizations to the Governmental Accounting Standards Board (GASB) in response to their request for comments on the Exposure Draft on Pension Issues, an amendment of GASB Statements No. 67, No. 68, and No. 73
2015
  • December 11, 2015 - Joint letter from national organizations representing state and local governments, officials, employees and retirement systems to members of Congress strongly opposing the public pension provisions contained in the Puerto Rico Assistance Act of 2015 (S. 2381), and urging the exclusion of these costly and burdensome federal mandates from any legislation under consideration.

  • June 12, 2015 - Letter to Actuarial Standards Board from national public employee pension associations regarding Actuarial Standards of Practice (ASOPs).

  • June 3, 2015 - Testimony delivered by Alex Brown, NASRA research manager, before Pennsylvania House State Government Committee on Senate Bill 1, a proposal to replace the current defined benefit pension plans for future state government and school employees.

  • May 27, 2015 - Letter to Governmental Accounting Standards Board (GASB) from national associations requesting a reinstatement of the definition for covered payroll used in Statement No. 25.

  • May 11, 2015 - Joint submission from national organizations representing state and local governments, public officials, public employees and retirement systems to the Internal Revenue Service regarding the treatment of charter schools.

  • April 15, 2015Joint submission from national organizations representing state and local governments, public officials, public employees and retirement systems to the Senate Finance Committee Tax Reform Working Group on Savings & Investment urging any changes to the federal tax code continue to support the ability of state and local governments to successfully design, invest, finance, and manage their public employee retirement system.
  • April 2, 2015 - Letter to Moody’s Investors Services from the National Association of State Retirement Administrators regarding its report, "New Pension Accounting Increases Clarity of Plan Funding Trajectories.”

  • January 26, 2015 - Letter to the editor of the Wall Street Journal affirming that public pensions in most states are in reasonably good shape.

2014
  • November 14, 2014 - Letter signed by members of NASRA, the National Conference of Public Employee Retirement Systems and the National Council on Teacher Retirement, in response to a Request for Comments from the Actuarial Standards Board regarding the application of the Actuarial Standards of Practice (ASOPs) in regard to actuarial valuations and other analyses used for determining public pension and other postemployment plan funding and accounting.

  • October 8, 2014 - Letter to Moody’s Investors Services from the National Association of State Retirement Administrators regarding its report, “US State and Local Government Pensions Lose Ground Despite Meeting Return Targets.”

  • June 16, 2014 - Joint letter from national organizations representing the nation's governors, legislatures and other associations who are members of the Pension Funding Task Force to Commissioner Daniel M. Gallagher of the U.S. Securities and Exchange Commission regarding his remarks before the Municipal Securities Rulemaking Board’s 1st Annual Municipal Securities Regulators Summit.

2013
  • July 17, 2013 - National organizations representing the nation's governors, legislatures and other associations who are members of the Pension Funding Task Force, jointly wrote to the Society of Actuaries' blue ribbon panel, which is exploring the causes of underfunding in public pension plans. The organizations urged the panel to base their conclusions on well-informed, balanced insights and information. They shared the Task Force report, Pension Funding: A Guide for Elected Officials, as well as the recent summary regarding the new and distinct pension numbers for books, bonds and budgets.

  • July 9, 2013 - Joint letter from directors of 42 public retirement systems to the chairman of the Society of Actuaries Blue Ribbon Panel on Pension Underfunding.

  • April 24, 2013 - Joint letter from 21 national public sector organizations to former co-sponsors of the Public Employee Pension Transparency Act (PEPTA; H.R. 1628, S. 779), requesting a meeting to discuss the united view that the bill is imprudent and unnecessary. The bill threatens to tax bonds of state and local governments and impose new federal regulations on their retirement systems. The bill would require federal reporting based on market value of liability calculations projected over 60 years and within 210 days following the end of a governmental plan year.

  • April 15, 2013 - Letter from national organizations representing state and local governments, officials and retirement systems to the House Ways and Means Committee Working Group on Retirement/Pensions, urging them to ensure any federal tax changes support retirement policies and flexibility at the state and local level. The working group is chaired by Reps. Tiberi (R-OH) and Kind (D-WI) and is one of 11 working groups formed to review current tax law in specified areas and seek input from subject matter experts and the general public.

  • April 3, 2013 - Letter from national organizations representing state and local governments, officials and retirement systems to all members of the U.S. House of Representatives expressing strong opposition to the Public Employee Pension Transparency Act (PEPTA) and urging members not to become a cosponsor of this legislation. The bill has been introduced the last two Congresses and the lead sponsor recently circulated a "Dear Colleague" letter soliciting cosponsors for reintroduction this year.

2012
  • September 30, 2012 - Letter to Moody’s Investors Services from state retirement administrator members of National Association of State Retirement Administrators and National Council on Teacher Retirement on its proposed changes.

  • July 30, 2012 - Jointly submitted comments by 14 national public sector associations - representing state and local governments, officials, employees, retirees and retirement systems - to the IRS regarding the application of federal Normal Retirement Age regulations to governmental plans.

  • July 9, 2012 - Testimony for IRS/Treasury hearing on definition of governmental plan by Cynthia Rougeou, exeuctive director of the Louisiana State Employees' Retirement System and then first vice president of National Association of State Retirement Administrators and Meredith Williams, executive director of the National Council on Teacher Retirement.

  • June 15, 2012 - Jointly submitted comments from national public sector organizations to the IRS in response to their Advance Notice of Proposed Rulemaking (ANPRM) on the definition of a governmental plan. The letter focuses on the safe-harbors, grandfathering, transition rules and other issues governmental plans will need in order to be administered properly going forward.

2011
  • February 14, 2011 - Testimony delivered by Keith Brainard, NASRA director of research, before U.S. House of Representatives Judiciary Subcommittee on Courts, Commercial and Administrative Law, on "The Role of Public Employee Pensions in Contributing to State Insolvency and the Possibility of a State Bankruptcy Chapter.