Senate Bill S3608

                             
                     S T A T E   O F   N E W   Y O R K
 ________________________________________________________________________
 
                                  3608--A
 
                        2025-2026 Regular Sessions
 
                             I N  S E N A T E
 
                             January 29, 2025
                                ___________
 
 Introduced  by  Sens.  HELMING,  ORTT, C. RYAN -- read twice and ordered
   printed, and when printed to be committed to the  Committee  on  Civil
   Service  and Pensions -- recommitted to the Committee on Civil Service
   and Pensions in accordance with Senate Rule 6,  sec.  8  --  committee
   discharged, bill amended, ordered reprinted as amended and recommitted
   to said committee
 
 AN  ACT  to amend the retirement and social security law, in relation to
   the retirement of county 911 operators
 
   THE PEOPLE OF THE STATE OF NEW YORK, REPRESENTED IN SENATE AND  ASSEM-
 BLY, DO ENACT AS FOLLOWS:
 
   Section 1. The retirement and social security law is amended by adding
 a new section 89-z to read as follows:
   §  89-Z.  OPTIONAL  TWENTY-FIVE YEAR RETIREMENT PLAN FOR COUNTY POLICE
 COMMUNICATIONS OPERATORS, POLICE  COMMUNICATIONS  OPERATOR  SUPERVISORS,
 ASSISTANT BUREAU DIRECTORS (POLICE 911 COMMUNICATIONS) AND BUREAU DIREC-
 TORS  (POLICE  911 COMMUNICATIONS). A. ANY MEMBER WHO IS A COUNTY POLICE
 COMMUNICATIONS  OPERATOR,  POLICE  COMMUNICATIONS  OPERATOR  SUPERVISOR,
 ASSISTANT BUREAU DIRECTOR (POLICE 911 COMMUNICATIONS) OR BUREAU DIRECTOR
 (POLICE  911 COMMUNICATIONS) IN AN ELECTING COUNTY, SHALL BE ELIGIBLE TO
 RETIRE PURSUANT TO THE PROVISIONS  OF  THIS  SECTION.  SUCH  ELIGIBILITY
 SHALL  BE  AN  ALTERNATIVE TO THE ELIGIBILITY PROVISIONS AVAILABLE UNDER
 ANY OTHER PLAN OF THIS ARTICLE TO WHICH  SUCH  MEMBER  IS  SUBJECT.  THE
 COMPTROLLER  SHALL  HAVE  THE AUTHORITY TO INCLUDE POSITIONS HEREIN THAT
 COMPREHEND THE SAME DUTIES AND RESPONSIBILITIES, BUT ARE  NAMED  DIFFER-
 ENTLY.
   B.  SUCH  MEMBER  SHALL  BE  ENTITLED TO RETIRE UPON THE COMPLETION OF
 TWENTY-FIVE YEARS OF TOTAL CREDITABLE SERVICE BY FILING  AN  APPLICATION
 THEREFOR IN THE MANNER PROVIDED FOR IN SECTION SEVENTY OF THIS ARTICLE.
   C.  UPON  COMPLETION  OF  TWENTY-FIVE  YEARS  OF SUCH SERVICE AND UPON
 RETIREMENT, EACH SUCH MEMBER SHALL RECEIVE  A  PENSION  WHICH,  TOGETHER
 WITH AN ANNUITY WHICH SHALL BE THE ACTUARIAL EQUIVALENT OF SUCH MEMBER'S
 
  EXPLANATION--Matter in ITALICS (underscored) is new; matter in brackets
                       [ ] is old law to be omitted.
                                                            LBD01079-07-6
              

 S. 3608--A                          2
 
 ACCUMULATED  CONTRIBUTIONS  AT  THE TIME OF RETIREMENT AND AN ADDITIONAL
 PENSION WHICH  IS  THE  ACTUARIAL  EQUIVALENT  OF  THE  RESERVED-FOR-IN-
 CREASED-TAKE-HOME-PAY TO WHICH SUCH MEMBER MAY THEN BE ENTITLED SHALL BE
 SUFFICIENT  TO  PROVIDE SUCH MEMBER WITH A RETIREMENT ALLOWANCE EQUAL TO
 ONE-HALF OF THEIR FINAL AVERAGE SALARY.
   D. AS USED IN THIS SECTION "CREDITABLE SERVICE" SHALL INCLUDE ANY  AND
 ALL  SERVICES  PERFORMED  AS  A  COUNTY  POLICE COMMUNICATIONS OPERATOR,
 POLICE COMMUNICATIONS OPERATOR  SUPERVISOR,  ASSISTANT  BUREAU  DIRECTOR
 (POLICE  911  COMMUNICATIONS)  AND  BUREAU DIRECTOR (POLICE 911 COMMUNI-
 CATIONS).
   E. CREDIT FOR SERVICE AS A MEMBER OR OFFICER OF THE STATE POLICE OR AS
 A PAID FIREFIGHTER, POLICE OFFICER OR  OFFICER  OF  ANY  ORGANIZED  FIRE
 DEPARTMENT  OR  POLICE FORCE OR DEPARTMENT OF ANY COUNTY, CITY, VILLAGE,
 TOWN, FIRE DISTRICT OR POLICE DISTRICT, OR AS A CRIMINAL INVESTIGATOR IN
 THE OFFICE OF A DISTRICT ATTORNEY, OR AS  A  PROBATION  ASSISTANT  IN  A
 COUNTY  PROBATION  DEPARTMENT,  SHALL  ALSO  BE  DEEMED TO BE CREDITABLE
 SERVICE AND SHALL BE INCLUDED IN COMPUTING YEARS OF  TOTAL  SERVICE  FOR
 RETIREMENT PURSUANT TO THIS SECTION.
   F.  THE  CHIEF  EXECUTIVE  OFFICER IN EACH COUNTY SHALL CERTIFY TO THE
 COMPTROLLER, PERIODICALLY AND AT  SUCH  INTERVALS  OF  TIME  AS  MAY  BE
 REQUIRED  AND  IN SUCH FASHION AS MAY BE PRESCRIBED, THE IDENTITY OF THE
 ELIGIBLE POLICE COMMUNICATIONS OPERATORS, POLICE COMMUNICATIONS OPERATOR
 SUPERVISORS, ASSISTANT BUREAU DIRECTORS (POLICE 911 COMMUNICATIONS)  AND
 BUREAU  DIRECTORS  (POLICE  911  COMMUNICATIONS) IN SUCH CHIEF EXECUTIVE
 OFFICER'S EMPLOY.
   G. A MEMBER CONTRIBUTING ON THE BASIS OF THIS SECTION AT THE  TIME  OF
 RETIREMENT  SHALL  RETIRE  AFTER  THE COMPLETION OF TWENTY-FIVE YEARS OF
 TOTAL CREDITABLE SERVICE. APPLICATION THEREFOR MAY BE FILED IN A  MANNER
 SIMILAR  TO  THAT  PROVIDED  IN  SECTION  SEVENTY  OF THIS ARTICLE. UPON
 COMPLETION OF TWENTY-FIVE YEARS OF SUCH  SERVICE  AND  UPON  RETIREMENT,
 EACH SUCH MEMBER SHALL RECEIVE A PENSION WHICH, TOGETHER WITH AN ANNUITY
 WHICH  SHALL  BE  THE ACTUARIAL EQUIVALENT OF THEIR ACCUMULATED CONTRIB-
 UTIONS AT THE TIME OF RETIREMENT AND AN ADDITIONAL PENSION WHICH IS  THE
 ACTUARIAL  EQUIVALENT  OF  THE  RESERVED-FOR-INCREASED-TAKE-HOME-PAY  TO
 WHICH SUCH MEMBER MAY THEN BE ENTITLED, SHALL BE SUFFICIENT  TO  PROVIDE
 SUCH MEMBER WITH A RETIREMENT ALLOWANCE EQUAL TO ONE-HALF OF THEIR FINAL
 AVERAGE SALARY.
   H.  IN  COMPUTING  THE  TWENTY-FIVE YEARS OF TOTAL SERVICE OF A MEMBER
 PURSUANT TO THIS SECTION FULL CREDIT SHALL BE GIVEN AND  FULL  ALLOWANCE
 SHALL  BE MADE FOR SERVICE OF SUCH MEMBER IN TIME OF WAR AFTER WORLD WAR
 I AS DEFINED IN SECTION TWO OF THIS CHAPTER, PROVIDED SUCH MEMBER AT THE
 TIME OF THEIR ENTRANCE INTO THE ARMED FORCES WAS IN THE SERVICE  OF  THE
 COUNTY OF THEIR EMPLOYER THAT MAKES THE ELECTION PROVIDED FOR HEREIN.
   I. NOTHING HEREIN SHALL BE CONSTRUED TO PREVENT A MEMBER, WHO DOES NOT
 RETIRE  PURSUANT  TO  THE  PROVISIONS  OF  THIS  SECTION, FROM UTILIZING
 SERVICE WHICH IS CREDITABLE SERVICE PURSUANT TO THE PROVISIONS  OF  THIS
 SECTION  FOR SERVICE CREDIT PURSUANT TO THE PROVISIONS OF ANY OTHER PLAN
 OF THIS ARTICLE TO WHICH SUCH MEMBER IS SUBJECT.
   J. 1. EACH COUNTY THAT ELECTS  PURSUANT  TO  THE  PROVISIONS  OF  THIS
 SUBDIVISION SHALL PAY THE COST ATTRIBUTABLE THEREFOR.
   2.  THE  BENEFITS  OF  THIS  SECTION  SHALL BE AVAILABLE ONLY TO THOSE
 MEMBERS DEFINED IN SUBDIVISION A OF THIS SECTION WHOSE  EMPLOYER  ELECTS
 TO  PROVIDE  SUCH  BENEFITS  BY ADOPTING A RESOLUTION TO SUCH EFFECT AND
 FILING A CERTIFIED COPY THEREOF WITH THE  COMPTROLLER.  SUCH  RESOLUTION
 SHALL  BE ACCOMPANIED BY THE AFFIDAVIT OF THE CHIEF EXECUTIVE OFFICER OF
 S. 3608--A                          3
 
 THE COUNTY THAT THE COUNTY HAS RECEIVED AN ESTIMATE FROM THE  RETIREMENT
 SYSTEM OF THE COST OF THE BENEFIT PROVIDED BY THIS SECTION.
   K. THE PROVISIONS OF THIS SECTION SHALL BE CONTROLLING NOTWITHSTANDING
 ANY OTHER PROVISION IN THIS ARTICLE TO THE CONTRARY.
   § 2. Subdivision a of section 445 of the retirement and social securi-
 ty  law, as amended by section 2 of part TT of chapter 55 of the laws of
 2025, is amended to read as follows:
   a. No member of a retirement system who is subject to  the  provisions
 of this article shall retire without regard to age, exclusive of retire-
 ment  for  disability, unless they are a police officer, an investigator
 member of the New York city employees' retirement  system,  firefighter,
 correction  officer,  a  qualifying member as defined in section eighty-
 nine-t, as added by chapter six hundred fifty-seven of the laws of nine-
 teen hundred ninety-eight, of this chapter, sanitation worker, a special
 officer (including persons employed by the city of New York in the title
 urban park ranger or associate urban park ranger), school safety  agent,
 campus peace officer or a taxi and limousine commission inspector member
 of  the  New York city employees' retirement system or the New York city
 board of education retirement system, a dispatcher  member  of  the  New
 York  city  employees' retirement system, a police communications member
 of the New York city employees' retirement system, an EMT member of  the
 New  York  city employees' retirement system, a deputy sheriff member of
 the New York city employees' retirement system, a correction officer  of
 the  Westchester  county  correction  department  as  defined in section
 eighty-nine-e of this chapter or employed in Suffolk county as  a  peace
 officer,  as  defined in section eighty-nine-s, as added by chapter five
 hundred eighty-eight of the laws of nineteen  hundred  ninety-seven,  of
 this  chapter,  employed  in  Suffolk county as a correction officer, as
 defined in section eighty-nine-f of this chapter, or employed in  Nassau
 county as a correction officer, uniformed correction division personnel,
 sheriff,  undersheriff  or deputy sheriff, as defined in section eighty-
 nine-g of this chapter, or employed in Nassau  county  as  an  ambulance
 medical  technician,  an  ambulance  medical  technician/supervisor or a
 member who performs ambulance medical technician related services, or  a
 police  medic,  police  medic supervisor or a member who performs police
 medic related services, as defined in section eighty-nine-s, as  amended
 by  chapter  five  hundred seventy-eight of the laws of nineteen hundred
 ninety-eight, of this chapter, or employed in Nassau county as  a  peace
 officer,  as  defined in section eighty-nine-s, as added by chapter five
 hundred ninety-five of the laws of  nineteen  hundred  ninety-seven,  of
 this  chapter,  or employed in Albany county as a sheriff, undersheriff,
 deputy sheriff, correction officer or identification officer, as defined
 in section eighty-nine-h of this chapter or is employed in St.  Lawrence
 county as a sheriff, undersheriff, deputy sheriff or correction officer,
 as  defined  in  section eighty-nine-i of this chapter or is employed in
 Orleans county as a sheriff, undersheriff, deputy sheriff or  correction
 officer,  as  defined  in  section  eighty-nine-l  of this chapter or is
 employed in Jefferson county as a sheriff, undersheriff, deputy  sheriff
 or correction officer, as defined in section eighty-nine-j of this chap-
 ter  or is employed in Onondaga county as a deputy sheriff-jail division
 competitively appointed or  as  a  correction  officer,  as  defined  in
 section  eighty-nine-k  of this chapter or is employed in a county which
 makes an election under subdivision j of section eighty-nine-p  of  this
 chapter as a sheriff, undersheriff, deputy sheriff or correction officer
 as defined in such section eighty-nine-p or is employed in Broome County
 as  a  sheriff,  undersheriff,  deputy sheriff or correction officer, as
 S. 3608--A                          4
 
 defined in section eighty-nine-m of this chapter or is a  Monroe  county
 deputy  sheriff-court  security,  or deputy sheriff-jailor as defined in
 section eighty-nine-n, as added by chapter five hundred ninety-seven  of
 the  laws of nineteen hundred ninety-one, of this chapter or is employed
 in  Greene  county  as  a  sheriff,  undersheriff,  deputy  sheriff   or
 correction  officer, as defined in section eighty-nine-o of this chapter
 or is a traffic officer with the town of Elmira as  defined  in  section
 eighty-nine-q of this chapter or is employed by Suffolk county as a park
 police  officer,  as defined in section eighty-nine-r of this chapter or
 is a peace officer employed by a county probation department as  defined
 in  section  eighty-nine-t, as added by chapter six hundred three of the
 laws of nineteen hundred ninety-eight, of this chapter or is employed in
 Rockland county as a deputy sheriff-civil as defined in section  eighty-
 nine-v of this chapter as added by chapter four hundred forty-one of the
 laws of two thousand one, or is employed in Rockland county as a superi-
 or  correction officer as defined in section eighty-nine-v of this chap-
 ter as added by chapter five hundred fifty-six of the laws of two  thou-
 sand one or is a paramedic employed by the police department in the town
 of  Tonawanda  and retires under the provisions of section eighty-nine-v
 of this chapter, as added by chapter four  hundred  seventy-two  of  the
 laws  of two thousand one, or is a county fire marshal, supervising fire
 marshal, fire marshal, assistant  fire  marshal,  assistant  chief  fire
 marshal,  chief  fire marshal, division supervising fire marshal or fire
 marshal trainee employed by the county of Nassau as defined  in  section
 eighty-nine-w of this chapter or is employed in Monroe county as a depu-
 ty  sheriff-civil  as  defined in section eighty-nine-x of this chapter,
 employed as an emergency medical technician, critical  care  technician,
 advanced  emergency  medical technician, paramedic or supervisor of such
 titles in a participating Suffolk county fire  district  as  defined  in
 section  eighty-nine-ss of this chapter, or is a firefighter apprentice,
 airport firefighter I, airport firefighter II, airport firefighter  III,
 or  training and safety officer employed by the division of military and
 naval affairs as defined in section eighty-nine-y of this chapter, OR IS
 A COUNTY POLICE COMMUNICATIONS OPERATOR, POLICE COMMUNICATIONS  OPERATOR
 SUPERVISOR,  ASSISTANT  BUREAU  DIRECTOR (POLICE 911 COMMUNICATIONS) AND
 BUREAU DIRECTOR (POLICE 911 COMMUNICATIONS) AS DEFINED IN SECTION EIGHT-
 Y-NINE-Z OF THIS CHAPTER and  is  in  a  plan  which  permits  immediate
 retirement  upon  completion  of  a  specified period of service without
 regard to age. Except as provided  in  subdivision  c  of  section  four
 hundred  forty-five-a  of  this  article,  subdivision c of section four
 hundred forty-five-b of this article,  subdivision  c  of  section  four
 hundred  forty-five-c  of  this  article,  subdivision c of section four
 hundred forty-five-d of this article,  subdivision  c  of  section  four
 hundred  forty-five-e  of  this  article,  subdivision c of section four
 hundred forty-five-f of this article and subdivision c of  section  four
 hundred  forty-five-h  of this article, a member in such a plan and such
 an occupation, other than a police officer or investigator member of the
 New York city employees' retirement system or a firefighter,  shall  not
 be  permitted  to retire prior to the completion of twenty-five years of
 credited service; provided, however, if such a member in such an occupa-
 tion is in a plan which permits retirement  upon  completion  of  twenty
 years  of  service regardless of age, they may retire upon completion of
 twenty years of credited service and prior to the completion of  twenty-
 five years of service, but in such event the benefit provided from funds
 other  than  those  based on such a member's own contributions shall not
 S. 3608--A                          5
 
 exceed two per centum of final average salary per each year of  credited
 service.
   §  3. Section 603 of the retirement and social security law is amended
 by adding a new subdivision x to read as follows:
   X. THE SERVICE RETIREMENT BENEFIT SPECIFIED  IN  SECTION  SIX  HUNDRED
 FOUR  OF THIS ARTICLE SHALL BE PAYABLE TO MEMBERS WITH TWENTY-FIVE YEARS
 OF CREDITABLE SERVICE, WITHOUT REGARD TO AGE,  WHO  ARE  EMPLOYED  AS  A
 COUNTY  POLICE  COMMUNICATIONS  OPERATOR, POLICE COMMUNICATIONS OPERATOR
 SUPERVISOR, ASSISTANT BUREAU DIRECTOR (POLICE  911  COMMUNICATIONS)  AND
 BUREAU DIRECTOR (POLICE 911 COMMUNICATIONS) AS DEFINED IN SECTION EIGHT-
 Y-NINE-Z  OF  THIS  CHAPTER  IF:  (I)  SUCH MEMBERS HAVE MET THE MINIMUM
 SERVICE REQUIREMENTS UPON RETIREMENT; AND (II) IN THE CASE OF  A  MEMBER
 SUBJECT  TO  THE  PROVISIONS  OF  ARTICLE FOURTEEN OF THIS CHAPTER, SUCH
 MEMBER FILES AN ELECTION THEREFOR  WHICH  PROVIDES  THAT  THEY  WILL  BE
 SUBJECT  TO THE PROVISIONS OF THIS ARTICLE AND TO NONE OF THE PROVISIONS
 OF SUCH ARTICLE FOURTEEN. SUCH ELECTION,  WHICH  SHALL  BE  IRREVOCABLE,
 SHALL  BE  IN  WRITING,  DULY EXECUTED AND SHALL BE FILED WITH THE COMP-
 TROLLER WITHIN ONE YEAR OF THE EFFECTIVE DATE  OF  THIS  SUBDIVISION  OR
 WITHIN  ONE  YEAR  AFTER  ENTERING  THE EMPLOYMENT WITH SUCH COUNTY UPON
 WHICH ELIGIBILITY IS BASED, WHICHEVER COMES LATER. FOR THE  PURPOSES  OF
 THIS  SUBDIVISION,  THE TERM "CREDITABLE SERVICE" SHALL HAVE THE MEANING
 AS SO DEFINED IN BOTH SECTIONS EIGHTY-NINE-Z AND SIX HUNDRED ONE OF THIS
 CHAPTER.
   § 4. Section 604 of the retirement and social security law is  amended
 by adding a new subdivision x to read as follows:
   X.  THE  EARLY SERVICE RETIREMENT BENEFIT FOR A MEMBER WHO IS EMPLOYED
 AS A COUNTY POLICE COMMUNICATIONS OPERATOR, POLICE COMMUNICATIONS OPERA-
 TOR SUPERVISOR, ASSISTANT BUREAU DIRECTOR  (POLICE  911  COMMUNICATIONS)
 AND  BUREAU  DIRECTOR  (POLICE 911 COMMUNICATIONS) AS DEFINED IN SECTION
 EIGHTY-NINE-Z OF THIS CHAPTER SHALL BE A PENSION EQUAL  TO  ONE-FIFTIETH
 OF  FINAL  AVERAGE  SALARY  TIMES  YEARS  OF  CREDITED  SERVICE  AT  THE
 COMPLETION OF TWENTY-FIVE YEARS OF SERVICE AS SUCH POLICE COMMUNICATIONS
 OPERATOR, POLICE COMMUNICATIONS OPERATOR  SUPERVISOR,  ASSISTANT  BUREAU
 DIRECTOR  (POLICE  911  COMMUNICATIONS)  AND BUREAU DIRECTOR (POLICE 911
 COMMUNICATIONS), BUT NOT EXCEEDING ONE-HALF OF THEIR FINAL AVERAGE SALA-
 RY; FOR SERVICE BEYOND TWENTY-FIVE YEARS THE BENEFITS SHALL INCREASE  BY
 ONE-SIXTIETH OF FINAL AVERAGE SALARY FOR EACH YEAR OF ADDITIONAL SERVICE
 CREDIT  PROVIDED,  HOWEVER, THAT THE TOTAL ALLOWANCE PAYABLE PURSUANT TO
 THIS SECTION SHALL NOT EXCEED THREE-FOURTHS OF SUCH MEMBER'S FINAL AVER-
 AGE SALARY.
   § 5. All past service costs incurred with implementing the  provisions
 of  this  act  shall  be  borne by any county that elects to provide the
 benefits provided by this act.
   § 6. This act shall take effect the first of January  next  succeeding
 the date on which it shall have become a law.
   FISCAL NOTE.--Pursuant to Legislative Law, Section 50:
   This  bill  would  allow  counties to elect to provide police communi-
 cations operators and similar titles, the option to retire with  twenty-
 five  years  of  service  credit. The benefit would be one-half of final
 average salary (FAS) plus, for Tiers 3 through 6 only,  one-sixtieth  of
 FAS for each additional year of creditable service, not to exceed three-
 fourths  (75%)  of  FAS.  Additionally, members covered under Article 14
 would be permitted one year to make an irrevocable election to switch to
 the twenty-five-year plan benefit.
   We estimate that the  annual  contribution  required  of  an  electing
 employer will increase by 7% of the salary paid to the affected members.
 S. 3608--A                          6
 
 Annual  costs  will vary as the billing rates and salary of the affected
 members change.
   In  addition,  there  will  be an immediate past service cost borne by
 each electing employer as a one-time payment. This  cost  will  vary  by
 employer but is expected to average approximately 30% of the salary paid
 to the affected members.
   Further,  we  anticipate  additional administrative costs to implement
 the provisions of this legislation.
   The exact number of current members as  well  as  future  members  who
 could  be  affected  by  this  legislation cannot be readily determined.
 Prior to electing to  provide  these  benefits,  an  employer  would  be
 required  to  submit  a roster of eligible members to the New York State
 and Local Retirement System. This roster would be used to  determine  an
 exact  cost  to  the individual employer electing to provide these bene-
 fits.
   Summary of relevant resources:
   Membership data as of March 31, 2025 was used to measure the impact of
 the bill, the same data used in the Actuarial Valuations dated April  1,
 2025. Distributions and other statistics can be found in the 2025 Report
 of  the  Actuary and the 2025 Annual Comprehensive Financial Report. The
 actuarial assumptions and methods used are described in the 2025  Annual
 Report to the Comptroller on Actuarial Assumptions, and the Codes, Rules
 and  Regulations  of  the State of New York: Audit and Control. The fair
 value of assets and GASB disclosures can be found in the 2025  Financial
 Statements and Supplementary Information.
   Assumptions,  demographics,  and  other  considerations  may have been
 modified to better reflect specific provisions of any  proposed  benefit
 change(s).
   This  fiscal note does not constitute a legal opinion on the viability
 of the bill, nor is it intended to serve as a substitute for the profes-
 sional judgment of an attorney.
   This estimate, dated February 11, 2026,  and  intended  for  use  only
 during  the  2026 Legislative Session, is Fiscal Note Number 2026-56. As
 Chief Actuary  of  the  New  York  State  and  Local  Retirement  System
 (NYSLRS),  I,  Aaron  Schottin  Young, hereby certify that this analysis
 complies with applicable Actuarial Standards of Practice as well as  the
 Code  of  Professional Conduct and Qualification Standards for Actuaries
 Issuing Statements of Actuarial Opinion of the American Academy of Actu-
 aries, of which I am a member. I am  a  member  of  NYSLRS  but  do  not
 believe it impairs my objectivity.