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FAQs on 2006/07 Section 179 valuations

These questions deal specifically with Section 179 valuations, and are broken down into the following topics:

ACCOUNTS (section updated 23/5/06)
APPROXIMATIONS
ASSUMPTIONS
BENEFIT INCREASES/REVALUATION (section updated 5/1/06)
BENEFITS TO BE VALUED (section updated 18/8/06)
CASH BALANCE SCHEMES (section added 5/1/06)
CERTIFICATION (section updated 17/7/06)
COMMUTATION (section updated 3/1/06)
COMPENSATION CAP (section updated 29/3/06)
INSURANCE POLICIES (section updated 23/5/06)
MFR TRANSFORMATION FORMULAE questions have been moved to the Underfunding section of the Levy FAQs 06-07
NORMAL PENSION AGE
YIELDS

ACCOUNTS

Will the actuary require a set of audited accounts in order to perform the section 179 valuation?
A valuation of assets for a Section 179 valuation must be based on relevant accounts.  This is required by regulation 5 of the Pension Protection Fund (Valuation) Regulations 2005 (SI 2005/672). Relevant accounts must be audited accounts.  The definition of relevant accounts is as follows (it can be found in regulation 1 of the Pension Protection Fund (Valuation) Regulations):

"relevant accounts" means

(a) audited accounts for the scheme which are prepared in respect of a period ending with the relevant time;

(b) if none are so prepared, the latest such accounts which are available at the relevant time; or

(c) if the appropriate person's opinion is that it is practicable to use them, the latest such accounts which are available on the date the appropriate person signs the section 143 or section 179 valuation.

Preferably relevant accounts would be prepared in respect of a period ending on the Section 179 valuation date, but options (b) and (c) of the “relevant accounts” definition permit the accounting period to end on a different date in certain circumstances.

If an actuary knows that an event like a bulk transfer of assets and liabilities has occurred after the section 179 valuation date, should he make allowance for this on the section 179 valuation certificate? (updated 23/5/2006)
Bulk transfers after the valuation date should be ignored, assuming the assets being transferred in are not incorporated into the asset value to be included on the section 179 valuation certificate. If there are concerns that the section 179 valuation no longer accurately reflects the scheme’s position, you may undertake a subsequent section 179 valuation. As per the valuation guidance, any scheme may complete such a valuation at any time after April 2005 (with an effective date no earlier than 1 November 2004). The most recent valuation information provided by 31 March each year will be used to calculate the risk-based levy.

If you have not been able to undertake a further section 179 valuation, you should complete one of the two block transfer certificates currently available in the risk based levy forms section of the Pension Protection Fund website. The certificate should be completed electronically and submitted to the Pension Protection Fund by 30 June 2006. Either certificate can be used to provide information on a transfer.

One certificate [Certification of valuation results on a section 179 type basis] allows schemes to provide full asset and liability information on a section 179 basis (accepting that audited accounts may not be available); the other [Block transfer certificate] allows the total assets transferred to be declared. The Board will take this information into account when calculating the scheme based levy for 2006/07.  If schemes wish to obtain a reduction in their risk based levy they must complete the first form supplying liability as well as asset information.

The Board reserves the right to request further information where it considers it necessary, and to increase the levies of any schemes accordingly (such as receiving schemes where it is notified by the transferring scheme). The Board can issue a section 191 notice to require further information on the transfer be sent to the Board. In addition, schemes are encouraged voluntarily to notify the Board of any transfers of either more than 5% of scheme assets as at the last valuation or £1.5million if less.

For the 2006/07 levy year, only information provided on transfers which have taken place since the scheme’s last valuation and up to and including 31 March 2006 will be taken into account in the risk based levy calculation.

For the purposes of the Section 179 Valuation Certificate, what is meant by the effective date of the valuation? (updated 23/5/2006)
Where a scheme actuary carries out a section 179 valuation at a valuation date (call it date X) and rolls the results forward to a later date, then this later date is the valuation date for the purposes of the Section 179 Valuation Certificate. Audited accounts should ideally be prepared with an end-date of the later roll forward date, although the definition of “relevant accounts” in regulation 1 of the Valuation Regulations does permit audited accounts with other end-dates in certain circumstances. Liabilities should be prudently rolled forward from date X to the later date and the liabilities at this later date should be reported on the Section 179 Valuation Certificate.

APPROXIMATIONS

Can a scheme actuary certify a Section 179 valuation based on estimated assets and liabilities?
The current Section 179 guidance  permits the scheme actuary to certify that the total protected liabilities are unlikely to be understated. On the assets side, the scheme actuary should comply with the Valuation Regulations (SI 2005/672), which are fairly prescriptive.

ASSUMPTIONS

Which mortality tables should be used in deferment?
The same specified mortality bases should be used for in both deferment and retirement.

BENEFIT INCREASES/REVALUATION

How should non-revaluing pensions be treated between date of valuation and normal retirement age for the Section 179 valuation?
For a Section 179 valuation of a scheme, all pensions (including any non-revaluing pension) should be treated for revaluation purposes in the same way as deferred compensation increases. Between date of leaving and date of valuation, deferred pension increases are as per the scheme rules.

Should statutory late retirement factors be ignored in valuing Guaranteed Minimum Pensions and other scheme benefits for a section 179 valuation? (updated 3/1/2006)
Yes. For a Section 179 valuation of a scheme, all pension (including GMP) should be treated for revaluation purposes in the same way as deferred compensation increases.

How should fixed (ie transferred-in) pensions and pensions based on notional service be allocated to pre and post 1997 service?
These benefits should be allocated in accordance with normal scheme practice.  Where there is no such practice, treat the whole benefit as post 1997 service.  Please note the Board may take a different approach for s143 valuations and the payment of compensation.

The assumptions in the section 179 valuation guidance implicitly allow for increases to be granted to benefits between the relevant date and normal pension age. Is this correct in the case of unrevalued career average schemes?
Yes. Assuming increases from the relevant date to normal pension age in section 179 valuations applies to unrevalued career average schemes as it does to other eligible schemes. Information on section 143 valuations is given in the questions for industry professionals page

Where a pension scheme grants fixed increases in deferment to deferred pensions should I allow for these when carrying out a section 179 valuation? (added 5/1/06)
No. The deferred pension at the relevant date (the effective date of the section 179 valuation) should be calculated according to the scheme rules subject to the adjustments listed in paragraph 4.1 of our section 179 valuation guidance. The discount rate to use in deferment for valuing this deferred pension is the net yield specified in section 1 of appendix 1 in the guidance. As this net yield implicitly allows for increases to normal pension age no further allowance should be made for increases to benefits between the relevant date and normal pension age.

BENEFITS TO BE VALUED

How should benefits for an active member be calculated for Section 179 valuation purposes?
For Section 179 valuation purposes, benefits for an active member should be calculated as though he had become a deferred pensioner immediately before the valuation date. In practice PPF compensation may be calculated slightly differently.

What level of spouse's pension should be taken into account for a section 179 valuation? (updated 6/1/06)
A Section 179 valuation is designed deliberately to be a simplified version of a Section 143 valuation. The benefits (including the spouses’ pensions) to be valued for Section 179 valuation purposes are the same as the scheme benefits, but with the adjustments detailed in paragraph 4.1 of the guidance. This may well be different from the compensation that would actually be paid from the Pension Protection Fund to the spouse of an existing pensioner. (Note that where the member’s benefits are restricted by the compensation cap and the spouse’s benefit is a proportion of the member’s pension, the spouse’s benefit to be valued in a section 179 valuation is equal to the spouse’s proportion multiplied by the member’s pension as restricted by the cap.)

Do post-retirement guarantee periods qualify as a PPF benefit?
Allowance for a post-retirement guarantee period should be made in a Section 179 valuation for a scheme which provides a post-retirement guarantee period.

Which decrements should be taken into account?
Mortality and retirement at normal pension age.

How should individuals be treated for hybrid schemes offering DB benefits with a DC underpin or DC benefits with a DB underpin? (updated 3/1/2006)
For each individual, consider whether the underpin bites as at the valuation date using the current scheme methodology and only those members for whom the DB benefits exceed DC benefits are to be included in the liability calculations. Members with purely defined contribution benefits (i.e. defined benefits do not exceed defined contribution benefits) would be excluded from both assets and liabilities for a Section 179 valuation. The compensation cap and 90% level are applied to the DB members subsequent to the assessment. For a DC scheme with a DB underpin that only applies for a particular period of service, the member’s fund in relation to that period of service needs to be compared to the underpin using current scheme methodology. For those members for whom DB benefits exceed DC benefits, the assets and liabilities in relation to that period of service should be included in the section 179 valuation. For all other periods where a DB underpin does not apply, the corresponding assets and liabilities should be excluded from the valuation.

Note that to the extent further assumptions are required in order to determine whether the underpin bites as at the valuation date using the current scheme methodology, the actuary should have regard to those assumptions used for funding.

Should pre-retirement lump sum death benefits be valued?
Yes. Note that the benefits (including pre-retirement lump sum death benefits) to be valued for Section 179 valuation purposes are the same as the scheme benefits, but with the four adjustments detailed in paragraph 4.1 of the guidance.

How should I value a non-pensioner over MFR pension age?
Assume he retired immediately before the valuation date.

Which benefits are money purchase?
This question is answered in the FAQs for Industry Professionals section

How should the lump sum benefit on death before retirement be valued and how should the cap apply? (updated 18/8/2006)
The pre-retirement lump sum death benefits to be valued are those payable on death in deferment under the scheme rules irrespective of whether a member is an active or deferred at the valuation date. Benefits which do not accrue are ignored. Please note that a refund of contributions is regarded as an accruing benefit for these purposes. Lump sum death benefits should not be included when comparing benefit levels against the compensation cap.

Should GMP step-ups be valued for section 179 valuations? (updated 3/1/2006)
For section 179 purposes, a GMP step-up would only be valued for those pensioners under state pension age whose current pension is made up of excess over GMP only. Note that GMP step-ups and anti-franking increases do not need to be valued for other pensioners and non-pensioners for section 179 purposes.

Should late retirement factors that would have been incorporated into the MFR value of a tranche of pension (payable before MFR Pension Age) be incorporated into a section 179 valuation?
No. The section 179 net interest rate in deferment implies a revaluation rate in deferment without late retirement increases.

Section 4.1 of the Guidance for undertaking the risk based levy valuation in accordance with Section 179 of the Pensions Act 2004 says that valuations should be "disregarding any indexation applicable to pre 6 April 1997 service on a pro-rata basis". What method should be used for valuations for schemes with non-uniform accrual of benefits?
A proper split into pre-97 and post-97 pension allowing for different accrual rates and different pensionable earnings definitions should be done. The PPF will accept approximate Section 179 valuations based on a less precisely calculated split if the actuary certifies that, in his opinion, the approximate valuation is unlikely to understate the “accurate” Section 179 liabilities. The PPF intends to update its guidance shortly to make this point clear.

How is a fixed pension payable from NPA valued?
For s179 valuation purposes, a fixed pension at NPA is valued as though it is subject to revaluation in deferment. Although the scheme rules may stipulate no revaluation, the pre-retirement discount rate implicitly allows for deferred pension increases to NPA.

The section 179 valuation guidance states that benefits for an active member should be calculated as though he had become a deferred pensioner immediately before the valuation date. A lot of schemes do not grant a deferred pension to leavers with less than 2 years service.  It would seem sensible not to value a deferred pension in such cases. Is this correct? (added 3/1/2006)
Yes. The benefits that should be valued for section 179 purposes will depend on the member’s entitlement under the rules of the scheme (subject to the adjustments detailed in paragraph 4.1 of the guidance). So, for example, if he is entitled to a refund of contribution he will get 90% of his contribution, if he is entitled to a cash transfer value he would get 90% of that, and if he had a choice between a refund of contributions and a cash transfer value he will get 90% of whichever is the greater of the two.

CASH BALANCE SCHEMES

Are cash balance schemes covered by the PPF? (added 5/1/06)
Yes.

How do you value a cash balance scheme, and in particular take into account the compensation cap? (added 5/1/06)
Consider a member under NPA aged x who is a member of a cash balance scheme with a normal pension age of y. The member’s cash balance amount is (£A1 + £A2) at the valuation date, where £A1 and £A2 are the cash balance amounts accrued in relation to pre and post 97 service respectively.

To value this benefit for section 179 valuation purposes:

1.Apply a cap if under NPA to (£A1 + £A2) of the compensation cap at age y multiplied by the annuity at age y. The annuity at age y is derived from two annuities at age y, weighted by pre and post 97 service, using from the appropriate yield in payment as defined in section 1 of Appendix 1 of the section 179 guidance. The annuity at age y should also contain an element in respect of a contingent spouse’s pension unless the scheme does not provide such a benefit.

2.Discount the capped cash balance amount payable at retirement at age y by a factor of (1+i)x-y where i is the yield in deferment defined in section 1 of Appendix 1 of the section 179 guidance.

3.Discount the capped cash balance amount payable on death before retirement in n years’ time by a factor of (1+i)-n.

4.Sum all the discounted capped cash balance amounts over all the various contingencies.

5.Apply a multiplier of 90%

If over NPA and not yet a pensioner, the s179 liabilities would be equal to cash balance amount in relation to that particular member.

CERTIFICATION
These FAQs are about the Section 179 Valuation certificate.

Must I submit the S179 Valuation Certificate online, or can I print it out and post it? (added 20/12/2005)
Please submit the certificate by completing the online form on our website, clicking the “Submit by e-mail” button and then Send in your e-mail program.

Adobe Reader version 7 or later will open the form. If you have an earlier version of Reader, the latest version can be downloaded without charge from the Adobe website. You may need to check with your organisation’s IT department before installing new software on your computer. You can see which version of Adobe Reader you are currently using by clicking Help – About Adobe Reader.

The Section 179 Valuation Certificate asks for the “Amount of external liabilities deducted to reach [the total assets] figure”. What sort of things might constitute external liabilities? (added 23/12/2005)
External liabilities might include, for example, professional advisers’ fees which have been incurred prior to the date of the section 179 valuation but had not been paid from the pension scheme’s assets by that date. External liabilities may be zero if there are no such items. Double counting should be avoided, for example it would be inappropriate to include incurred but unpaid advisers’ fees as external liabilities if the asset value on the certificate was already net of a current liability deduction for those same advisers’ fees.

Paragraph 1.4.2 of the s179 valuation guidance (version 2) says section 179 valuations must be submitted within one year of the effective date. What happens if this deadline is missed? (updated 17th July 2006)
There is a statutory requirement on the trustees to provide the 179 valuation within one year of the relevant time (regulation 2 of the Pension Protection Fund (Valuation) Regulations 2005) to either the Board of the Pension Protection Fund or to the Pensions Regulator.

You may be able to use a later valuation date, and so put back the one year deadline. For liabilities, our guidance permits a roll-forward (provided the actuary can certify the protected liabilities are unlikely to have been understated) and we would not expect the actuary to incur significant extra costs for a roll-forward over a short period of time. For assets, it is best practice to use audited accounts ending on the valuation date. However it should be noted that the Valuation Regulations (SI 2005/672) permit audited accounts of a different date to be used in certain circumstances – see the Accounts section of these FAQs.


COMMUTATION

The valuation guidance does not refer to options which may be exercised by members. An ongoing valuation for a scheme might allow for members to commute pension for cash, if they had a right to do so and the cash factors were such as to place a strain on the fund.  Would such a scheme be expected to make a similar allowance for commutation when carrying out the s179 valuation?
For the risk-based levy valuation under section 179 of the Pensions Act, scheme actuaries should assume that none of the member’s pension is commuted. This is so, irrespective of how generous or otherwise the scheme’s own commutation factors are.

On commutation of a member's pension, do the pre and post 97 commutation factors apply in the same proportion as the member's pension relates to pre and post 97 service, or does a member have the facility to choose? (added 3/1/2006)
The pension attributable to pre and post 97 service should remain in the same proportion both pre and post commutation.

How is pension split between pre and post 97 service for those pensioners who have previously commuted part of their pension for a lump sum but whose the scheme did not distinguish whether pre/post 97 pension was commuted? (added 3/1/2006)
For pensioners who have previously commuted part of their pension for a lump sum and where the scheme makes no distinction between pre and post 97 benefits, the member’s pension should be pro-rated by service into pre and post 97 pension.

COMPENSATION CAP

How should the compensation cap be increased for deferred members not yet at their normal retirement age for a section 179 valuation?
Accrued pension is calculated for section 179 valuations in accordance with part 4.1. of the section 179 Guidance document.  The compensation cap applying at the scheme's normal pension age should be applied as at the valuation date and  therefore no increase to it is required.  The yield in deferment, net of deferred pension increases, is calculated in accordance with part 1 of Appendix 1. Also it is noted there that “As this yield implicitly allows for increases to normal pension age no allowance should be made for increases to benefits between the relevant date and normal pension age”. Benefits increase in deferment at the lesser of 5% per annum and the increase in the Retail Prices Index over the deferment period. Effectively therefore the compensation cap is also assumed to increase in deferment at this rate, too.

For the purposes of a section 179 valuation how is the compensation cap applied to early retirees who have not reached normal pension age?
For members in receipt of an early retirement pension the cap should be applied for the appropriate age of the member at the valuation date.

For the purposes of a section 179 valuation is the compensation cap applied to a member who had retired on ill health grounds?
The compensation cap is not applied to members who retired on ill health grounds.

Which cap is applicable to a member's benefit on death prior to normal pension age?
The compensation cap, for death in the year after the valuation date, would be that applicable to the member's last birthday at the date of valuation. For death in subsequent years up to normal pension age, the compensation cap is assumed to be the first-year compensation cap increased at the rate of the lesser of 5% per annum and the increase in the Retail Prices Index. This increase rate is the same rate as the death benefit increases in deferment. Additional compensation cap factors down to 16 years will be available in due course.

Where the spouse's benefit is based on the member's pension, should the proportion be applied to the member's pension as restricted by the cap?  In particular, if the member's pension is restricted where there is a separate retirement lump sum, will the spouse's pension be lower than it would have been if there had not been a separate retirement lump sum? (updated 6/1/06)
Yes and yes.

How do you cap the benefit if the spouse's pension is not based on the member's pension?
You do not.

When checking whether the benefits of a pensioner below normal pension age exceed the compensation cap for a Section 179 valuation, does the actuary need to consider cash lump sum benefits taken at retirement? Which compensation cap should be used for this test – the cap at the normal pension age of the pensioner or the cap at his age at the valuation date?
The actuary does not need to consider previously taken cash lump sums in this situation. This contrasts with Section 143 valuations where the actuary would need to consider such lump sums, the difference in approach reflecting Section 179 valuations being simpler than 143 valuations. In both Section 143 and Section 179 valuations the compensation cap relevant to pensioners below their normal pension age is the compensation cap for the pensioner’s age at the valuation date.

How should a spouse’s pension be valued when the member’s pension is restricted by the cap?
Under a section 179 valuation, the spouse’s benefit to be valued is the spouse’s proportion (as per the scheme rules) of member’s benefits (reduced to 90% if the member is under NPA). If the member’s benefit were to exceed the compensation cap, then this too would need to be taken into account i.e. spouse’s proportion x cap x 90% reduction factor (if below NPA). Note that for a section 143 valuation (entry into the Pension Protection Fund) a 50% spouse’s proportion should be used because that is the compensation provided by the Pension Protection Fund where a spouse’s pension is payable.

Some schemes have bridging (or temporary) pensions which cease to be paid upon a member reaching a certain age (normally SPA). Please would you confirm whether bridging pensions are to be included in the test against the compensation cap. (added 3/1/2006)
For the purposes of a section 179 valuation, bridging pensions should be included in the valuation of the liabilities, but should not be included in the test against the compensation cap.

How do you determine whether to apply the 10% reduction and compensation cap to a dependent who is currently in receipt of a pension which is being paid following the death of a member? (added 3/1/2006)
Neither the 10% reduction nor the compensation cap should be applied to survivors benefits (or ill-health benefits) which are in payment at the valuation date.

In schemes where cash lump sum benefits based on service and salary accrue separately alongside pension benefits, how should the cash benefits for non-pensioners below normal pension age be incorporated into the comparison of benefit levels with the compensation cap? (added 29/3/2006)
By converting the lump sum into a pension equivalent using the “Factors to calculate the annualised value of a lump sum”. The factors are available via a link on the Compensation Cap Factors page of our website

INSURANCE POLICIES

Can you advise how any benefits secured under contracts of insurance should be valued for s179 valuations?  Would any approximations be acceptable? (updated 23/5/06)
The scheme’s section 179 liabilities should include the liabilities being covered by the insurance policies where those policies are in the name of the trustees. The liabilities are valued in line with the guidance issued for undertaking a section 179 valuation, i.e. scheme benefits with the adjustments listed under section 4.1 of the section 179 guidance.

Regulation 7(2) of the Pension Protection Fund (Valuation) Regulations 2005 (SI 2005 / 672) says that the value of a contract of insurance in the assets of a section 179 valuation shall be:

(a) the value of the liability secured where the contract of insurance falls within the definition of a relevant contract of insurance in section 161(8) of the Act (effect of Board assuming responsibility for a scheme); or where this is not the case either:

(b )the surrender value of the contract of insurance; or

(c) where it appears to the appropriate person that the surrender value of the contract of insurance does not accurately reflect the actual value at the relevant time; then he shall adopt such a value as appears to him to be appropriate.

Insurance policies held in the name of the trustees should be included in the assets disclosed in the scheme’s accounts. A section 179 valuation should be based on the value of the assets in the relevant accounts and thus should take account of insurance policies held in the name of the trustees. The value of the contracts of insurance in the accounts may need to be replaced with one of (a) (b) or (c) above.

In some circumstances it may be necessary for an actuary to calculate the value of an insurance policy with reference to the value of the liability secured. The Pension Protection Fund accepts that where the pension increases of an annuity contract are not 0% fixed, and are not RPI capped at 2.5%, version 2 of the section 179 guidance does not specify exactly how to derive a yield for valuing the payments. The Board is considering whether it might provide further guidance in the future. In the meantime actuaries are requested to make assumptions which in their view are consistent with those in the latest version of the section 179 guidance.

Note that the value of assets might not be equal to the value of liabilities for section 179 purposes.

The valuation of assets and liabilities must be completed in accordance with the Regulations and the Board cannot waive any obligations in those regulations.  The Board would have concerns about any valuation that overstated assets or understated liabilities.

The scheme holds insured assets in respect of some of its deferred and pensioner membership.  These assets are not shown in the scheme's accounts.  What is the correct way to value these insured assets?  The scheme holds insured assets which do not exactly match members' actual benefits - so for example the scheme may hold a fixed increasing annuity to cover a member's benefits which might increase in line with LPI.
The answer depends on whether the insured policies are assets of the scheme trustees or not. If not, then you would not include them in the assets for Section 179 valuation purposes. If the answer is yes, you should refer to regulation 7(2) of The Pension Protection Fund (Valuation) Regulations 2005 (SI 2005 No. 672 ).

NORMAL PENSION AGE

How should a member’s Normal Pension Age be calculated for Section 179 valuation purposes?
For Section 179 valuation purposes, Normal Pension Age for a scheme member should be assumed to be the same as MFR Pension Age. This is the age at which the member will first become entitled under the provisions of the scheme to receive a full pension on retirement of an amount determined without a reduction to take account of its payment before a later age (but disregarding any entitlement to pension on retirement in the event of illness, incapacity or redundancy). See Regulation 7(10) of the Occupational Pension Schemes (Minimum Funding Requirement and Actuarial Valuations) Regulations 1996.  

Paragraphs 34(1) and 34(2) of Schedule 7 to the Pensions Act 2004 should not be applied for this purpose - reflecting the provisions of the PPF Valuation Regulations which require scheme benefits, not PPF compensation, to be valued for a s179 valuation.

Please note that this is a change of approach resulting from comments received from a number of actuarial firms. It is reflected in the October 2005 version of the section 179 Guidance which applies to all valuations signed off on or after 1 November.

How do you value members with multiple tranches of pension?
For a section 179 levy valuation purposes, MFR pension age should be used in respect of all of a member’s benefits.

YIELDS

The yield to be used for valuing level pensions in payment has no reduction of 0.5%pa shown whereas all the other yields do. Is this correct?
Yes this is correct, the yield to be used for valuing level pensions in payment has no reduction of 0.5% pa shown whereas all the other yields do.

Is it acceptable for non-revaluing pensions to be discounted at a higher rate which does not have implicit allowance for revaluation when submitting a PPF valuation, if the actuary considers to be in line with your prescribed assumptions?
It would not be appropriate for non-revaluing pensions to be discounted at a higher rate which does not have implicit allowance for revaluation. This is because the Pension Protection Fund compensation would be revalued even if the scheme benefits would not.

Please could you advise the level of rounding required on the net yields in deferment and in payment for the PPF levy valuations (eg 1 decimal place, 2 decimal places, etc). Is it open to the discretion of the actuary / trustees?
The yields in payment and in deferment should be calculated to the nearest 0.01%.

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