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American Benefits Council Comment Letter to PBGC on Proposed Regs for Reportable Events and Certain Other Notification Requirements (PDF)
American Benefits Council Link to more items from this source
[Opinion]
June 3, 2013
4 pages. "[W]hile the financial soundness test could decrease the reporting burden on some 'stronger' companies, the proposal has the effect of increasing the burden on 'less strong' companies ... [T]he proposal dramatically increases the amount of information required to be submitted with an initial reportable events notice and tightens reporting waivers based on plan funding status.... In addition, the Council is concerned that once the precedent of evaluating company health is established in the reportable events area, the government could use a similar test for other purposes, such as the calculation of premium payments. We see this trend as constituting a serious threat to the strength of the defined benefit plan system and to the PBGC."

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