From: Robert W. Ryan, FSA
Sent: August 8, 2006
Subject: File No. S7-03-06

Disclosure of tax qualified defined contribution plans

Would you please tell me how the annual value increase in a tax qualified defined contribution plan is to be discosed in the Summary Compensation Table.

It appears that the amount analgous to that disclosed for a defined benefit plan would be the account balance at the end of the year less the account balance at the begining of the year plus any amounts withdrawn or borrowed during the year.

However, I have seen several opinions that for defined contribution plans, the disclosure DOES NOT include any earnings earned during the year.

Thank you for your assistance.

Robert W. Ryan, FSA
Consulting Actuary