35 pages. "One unfortunate underlying theme in both participant and plan sponsor encounters with the agency is an overall sense of mistrust by agency personnel who interface with the regulated community on a routine basis.... The agency has an extraordinary $44.6 billion surplus that is far in excess of anything that the agency needs.... [T]he agency has not shown leadership to help policymakers and legislators come to terms with options to relieve this extraordinary financial burden that is driving plan sponsors from the defined benefit structure, threatening the retirement security of upcoming generations who lack the economic security of a lifetime income in retirement. "

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