9 pages. "[O]ne issue dwarfs all others. It is critical that guidance from Treasury and the Service not undo substantially all the effects of funding stabilization for a very large number of plans by modifying the current-law regulatory rules for valuing lump sum distributions for funding purposes. In this regard, we ask for no guidance, since current law works very well. Any different guidance would have a devastating effect on companies across the country, as explained further below, and be directly inconsistent with [1] Congressional intent, [2] the principles underlying the Pension Protection Act of 2006 ... and [3] the principles underlying the final regulations."  MORE >>