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Testimony Before the PBGC on Proposed Regs Regarding Reportable Events (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] June 20, 2013
"[1] It is not necessary to overhaul the existing regulations' approach to waivers. [2] The proposed regulations essentially eliminate plan funding as a basis for a waiver. [3] The PBGC should focus on the financial soundness of the plan and not the plan sponsor. [4] The proposed safe harbor for financial soundness of a plan sponsor is unworkable and there is no suitable alternative."
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