"Perhaps various combinations of a plan sponsor's creditworthiness and a plan's funded status could be made available to satisfy the financial soundness waiver.... Although it is true that PBGC's risk generally increases as funding levels decrease, we believe the proposed thresholds are too high... To allow the plan sponsor to determine whether the waivers apply, the waivers should be modified to allow determination of the information as of a prior date.... We suggest that the plan financial soundness waiver be expanded to also cover plans that could meet the test based on current year premium information, if available, by the event date."  MORE >>