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So we are terminating a PBGC plan and it's taking longer than we anticipated. The PBGC will grant extensions on the final distribution date when there are "compelling reasons" why the distribution deadline cannot be met. I don't want to say the "wrong" thing in my letter to the PBGC. Would the PBGC consider the following reasons to be compelling: delayed receipt of election forms, dealing with missing participants, and plan amendment, drawn out annuity search?

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