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American Benefits Council Letter to PBGC Urging Review of Early Warning Program
American Benefits Council Link to more items from this source
[Opinion]
Apr. 26, 2017
"Suggested changes to the program ... [1] Suspend the program for six months while it is evaluated and reformed.... [2] Reform the criteria for the program.... [3] Obtain board of directors approval for large plan involuntary terminations based on long-run loss determinations.... [4] Provide safe harbors from the Early Warning Program.... [5] Reform the 'sanctions' under the program.... [6] Preclude PBGC from intervening in company businesses without statutory authorization.... [7] Cease publicizing Early Warning Program agreements."

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