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ABC Comment on Proposed Amendment to PBGC regs on Premium Rates and Payment of Premiums (PDF)
American Benefits Council 
July 31, 2007
Excerpt: Under the proposed rule, the unfunded vested benefits (UVBs) must be determined as of the first day of the plan year, a change from the current snapshot date that is generally the last day of the previous plan year. The Council is concerned that this change will result in an increase in premium payments when a plan is amended to increase benefits retroactively.
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