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Text of Letter to PBGC Concerning Overly Expansive Interpretation of ERISA Section 4062(E) (PDF)
American Benefits Council; ASPPA College of Pension Actuaries [ACOPA]; Committee on Benefits Finance, Financial Executives International; and the Committee on Investment of Employee Benefit Assets [CIEBA] 
[Opinion] June 5, 2014
"[T]he PBGC's enforcement of section 4062(e) reflects a policy position that in our view is not consistent with the law.... This enforcement is costing businesses hundreds of millions of dollars, diverting assets from business investments and jobs.... [In] some cases, the PBGC's actions are preventing important business transactions from occurring at all, stopping companies from selling unneeded or unprofitable facilities and from achieving efficiencies by consolidating operations."
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