"PBGC has taken a preliminary position that we believe runs counter to sound actuarial practice, and that will lead in some cases to inappropriately large retirement benefits.... PBGC is interpreting plan provisions governing actuarial equivalence in a manner that results in benefits that are not actuarially equivalent.... Plans that specify pre- and post-retirement mortality assumptions separately -- rather than implicitly using the same assumption for both -- are being singled out for an interpretation that was never intended, never followed in practice, and actuarially incorrect."  MORE >>