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active market of insurers selling this product through <br />competitive bids. 11/30/92 Tr. at 15-16 (Gustafson). <br />To determine the cost of a group annuity in the private <br />sector, PBGC relies on a double-blind survey of all major <br />insurance annuity issuers, which is conducted quarterly by the <br />American Council of Life Insurance ("ACLI"). 11/30/92 Tr. at 2- <br />3, 34-35 (Gustafson). The three actuarial factors embodied in <br />PBGC's method together reproduce the price of a group annuity as <br />reflected in the ACLI study. The first factor -- mortality -- is <br />based on a standard table known as Unisex Pension 1984 ("UP 84"). <br />11/30/92 Tr. at 3 (Gustafson). The second factor -- retirement <br />age -- predicts when participants will retire and begin receiving <br />benefits.` 11/10/92 Tr. at 33 (Dezube). The third factor -- the <br />interest factor -- is generally derived by dividing the mortality <br />assumption into the average annuity purchase price as shown by <br />the ACLI survey. 11/30/92 Tr. at 2-3 (Gustafson). The evidence <br />at trial illustrated the interrelationship among these factors. <br />For example, any change in the interest factor would require <br />different mortality assumptions to replicate the same price. <br />at 3-6 (Gustafson); PBGC Exhibit 19. <br />In combination, these assumptions produced a present <br />value of about $254 million for the Plan's benefit liabilities. <br />When Plan assets on hand of approximately $31 million were <br />bebtors challenged PBGC's retirement age assumptions, but <br />abandoned this argument on appeal. In any event, the Court found <br />that PBGC presented "more credible evidence" of the expected <br />retirement age under terminated pension plane. 12/31/92 Mem. <br />Dec. at 14. <br />8 - <br />