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The PBGC is trying to have the Schedule SB changed to require reporting the Funding Target for inactives broken down (as is done for actives) into vested and total amounts. 1. Is anyone out there including any non-vested benefits in the Funding Target for non-actives? If so, why? Most plans contain language that treats non-vested participants as forfeiting their benefits immediately upon separation from service (having been "paid" a lump sum of $0 for the "vested" portion of their accrued benefit), and such people are dropped from the Funding Target immediately, without having to wait for a full break in service to occur. True, if rehired the "forfeited" benefits are restored, but is anyone including anything in the Funding Target for people who have not actually been rehired? 2. If a participant terminates with partial vesting and, more than 5 years later, the plan terminates, does anybody think that the non-vested portion of the accrued benefit must be restored and paid out if the participant has not been rehired? 3. If a participant terminates with partial vesting and, after some years elapse without the participant having been rehired, the participant reaches normal retirement age, does anybody think that the non-vested portion of the accrued benefit must become vested and payable? Some of us tried to put our heads together on this but we are having a great deal of difficulty imagining a situation where the Funding Target would include any non-vested benefits for inactives. Are there many plans out there in which people who terminate prior to eligibility for a subsidized early retirement benefit (say unreduced benefits at age 60 with 30 years of service) are able to grow into the subsidy (the way ongoing employees can after a plan has terminated)? Since no further service would be accrued, the only way to grow into eligibility would be to already have enough service before termination of employment and then become old enough and actually claim it. In that case, wouldn't the right to the subsidy, contingent only on remaining alive until early retirement age and then claiming it, be considered vested? What is the PBGC concerned about here?