M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension · ¶35

But petitioners' argument is based on a fawed understanding of actuarial assumptions. These assumptions are not factual inputs. Instead, they are predictive judgments about a plan's anticipated future performance—tools actuaries use to calculate the plan's UVBs. The distinction between tool and fact is clear from the text of ERISA: Section 1393 groups actuarial assumptions together with “methods” in prescribing how withdrawal liability must be calculated. See § 1393(a)(1). The relevant similarity between assumptions and methods is that both are tools used to make actuarial valuations. See, e. g., § 1393(a) (referring to actuarial assumptions as something “used” to determine UVBs); § 1401(a)(3)(B)(i) (same).

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