MD&A, International Paper Company provides historical returns on pension plan assets over the preceding ten years. However, the vast majority of firms do not provide near this level of detail nor this long a time-series of actual pension asset returns in MD&A. While financial statement users could assemble a time-series of expected and actual pension asset returns from 10-K pension footnote data, this requires more effort and would fall short of the SEC’s desire to enhance MD&A disclosure. In sum, the evidence suggests considerable room for improvement in MD&A disclosures useful in assessing the past accuracy of critical pension estimates.