Venice of America

CITY OF FORT LAJLJDERDALE

POLICE AND FIRE RETIREMENT SYSTEM

September 13, 2010

Director of Research and Technical Activities

Project No. 34
Governmental Accounting Standards Board
401 Merritt 7, PO Box 5116
Norwalk, CT 06856-5116

To Whom It May Concern:

The Fort Lauderdale Police and Firefighters' Retirement System provides pension benefits to
nearly 1,800 active and retired police officers and firefighters (or survivors) who are employed
by the city of Fort Lauderdale, Florida. The plan was created in 1973 and operates using
standard accounting and actuarial methodologies. The plan is funded by employee
contributions, employer contributions, state funds and return on investments.

The plan's actuarial assumed rate of return is 7.75%. It was lowered from 8% to more
accurately reflect the actual rate of return. Over the past 19 years, the plan's average rate of
return has been 8.77%, exceeding the assumed rate of return (both the previous rate and the
current rate). The trustees of the plan work diligently to ensure that the plan's investments
achieve or exceed the assumed rate of return.

We are pleased to provide the Governmental Accounting Standards Board (GASB) our
comments on the Preliminary Views related to Pension Accounting and Financial Reporting by
Employers. As a public pension retirement system, which has a fiduciary duty to our
participants, we use the financial accounting of our fund to help us meet our fiduciary
responsibilities to the plan participants and to the city's taxpayers.

Is the net pension liability measureable with sufficient reliability?

The net pension liability will behave differently from the unfunded actuarial accrued liability
used for funding purposes. Because the net pension liability is based on the market value of
assets and the unfunded actuarial accrued liability is typically based a smoothed value of assets,
they will likely rise and fall at different times. Also, the net pension liability will be more volatile
than the unfunded actuarial accrued liability. This would likely confuse and mislead decision
makers and citizens as to the "true" liability and funded status of benefits. It would give the
888 SOUTH ANDREWS AVENUE, SUITE 2O2
FORT LAUDERDALE, FLORIDA 33316
TELEPHONE: (954) 828-5595
FAX: (954) 828-5532
TOLL FREE: (888) 237-878O
www.ftlaudpfpension.com
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