On July 9, 2010, a joint CBF/CGB comment letter was filled with the Office of Federal Procurement Policy.  The letter was in response to the Notice of Proposed Rulemaking issued by the Cost Accounting Standards (CAS) Boards’ regarding the harmonization of CAS 412 and 413 with the Pension Protection Act (PPA) of 2006.  The PPA, which amended the minimum funding requirements for defined benefit pension plans, required the CAS Board to harmonize with PPA the standards that apply to government reimbursement of a contractor's pension costs.