"While this policy may provide relief to some credit-worthy companies, the approach presents a number of fundamental challenges to the continued health of the defined benefit pension system ... These proposed regulations -- and the new enforcement policy -- demonstrate a basic misinterpretation of the ERISA statute itself by radically re-defining what is a 'cessation of operations' and introducing vast new requirements that were not contemplated by Congress ... In fact, the enforcement policy itself is flawed, since it is being initiated under proposed regulations that have not yet been finalized or amended with the benefit of comments from the public[.]"

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