"The PBGC argues that the statute is silent as to whether a participant who requests a lump-sum payment before a plan administrator submits a notice of distress termination is entitled to such a payment after the administrator submits the notice, and that its policy (denying payment under such circumstances) rests on a reasonable interpretation of the statute that is consistent with congressional intent.... The problem for the PBGC is that ... while the policy states that requests submitted before the plan administrator submits a notice of distress termination may be denied after the notice is submitted, in this case the request was not only submitted but also denied before the plan administrator submitted its termination notice to the PBGC." [Fisher v. PBGC, No. 14-1275 (D.D.C. Feb. 25, 2016)]

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