ERIC Submits Additional Information on Reportable Events Hearing to PBGC

ERIC has submitted a letter to the Pension Benefit Guaranty Corporation (PBGC) in response to questions posed by the PBGC at the recent hearing on the reportable events proposed regulations. A special thanks to Michael Francese of Covington & Burling, who testified on behalf of ERIC and provided valuable input on the follow-up letter.

This letter supplements our prior comment letter and testimony on this issue. In particular, our recent letter discussed in further detail that:

  • Companies will need to restructure their credit agreements as a result of the proposed regulations;
  • Many financially sound companies secure their receivables to reduce financing costs;
  • Complying with the proposed regulations would be costly for companies;
  • 98% of the largest U.S. defined benefit plans will not qualify for the safe harbor for plans that are 120% funded on a premium basis; and
  • The PBGC should not create a new approach whereby it uses a limited number of factors in the company safe harbor.

The letter responding to the PBGC’s questions can be accessed by clicking on the link below. Our June 3 comment letter is available here and our June 18 testimony is available here.

ERIC Letter to PBGC