PBGC Opinion Letter Procedure

[BTG]

Could anyone point me to guidance on the procedure for requesting an opinion letter from the PBGC? This seems like it should be a very simple piece of information to obtain, but I can't find anything on it. Thanks!

[david rigby]

Search www.PBGC.gov for "opinion letter"?

Op ltrs are issued by the Office of General Counsel. You can find a description of the Office of the General Counsel near the bottom of this page:

http://www.pbgc.gov/about/departments.html

[BTG]

Thanks David. I did actually try both of those avenues before putting up my original post. Unfortunately, no luck so far... Still waiting to hear back from the OGC though. I did notice that there are no letters after 2002 in the archive of PBGC Opinion Letters (http://www.pbgc.gov/practitioners/law-regulations-informal-guidance/content/page15645.html). They didn't stop issuing them, did they?

[BTG]

Update: I just got off the phone with the Office of General Counsel. Apparently, there is no official procedure for requesting an opinion letter (I find that odd). Instead a written request should be sent to:

Office of the General Counsel

PBGC

1200 K Street NW

Washington, DC 20005

It should be addressed to the General Counsel (who is currently Judith Starr), and include all of the relevant facts and any legal authority you want them to consider. He also said that it takes "at least several months." I still find it odd that they haven't issued any letters since 2002.

Also, I just got a call from another individual who suggested that, depending on the issue, it might be better to send it to the Office of the Chief Counsel, and that the two departments would coordinate. I suspect that a letter addressed to either would eventually yield the same result.