"In evaluating the current [PBGC] premium level and structure, as well as possible changes thereto, primary consideration should be given to the risks inherent in the pension system and the effects on all stakeholders. These issues are not being appropriately considered when premium-increase proposals are added to unrelated legislation as a 'pay-for' to enable other priorities. Further premium increases will increase the cost of plan sponsorship and could accelerate the rate of plan closures, plan terminations, and other sponsor efforts to transfer risks to participants, which include offering lump sum distributions to current retirees."  MORE >>