M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension · ¶21

Actuaries select the assumptions underlying their UVB calculations based on relevant “current and historical data,” ASOP No. 27, § 3.5, including growth in the plan's earnings, infation, yields on securities, and other macroeconomic conditions, id., § 3.7. ERISA imposes few substantive requirements on the selection of these assumptions. Section 1393, which governs the use of actuarial assumptions in calculating withdrawal liability, says only that the actuary must use “actuarial assumptions and methods which, in the aggregate, are reasonable (taking into account the experience of the plan and reasonable expectations) and which, in combination, offer the actuary's best estimate of anticipated experience under the plan.” § 1393(a)(1).

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