Testimony 

Before the Committee on Finance, 

United States Senate

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Tuesday, June 7, 2005 PRIVATE PENSIONS

Revision of Defined Benefit 

Pension Plan Funding Rules 

Is an Essential Component 

of Comprehensive Pension 

Reform 

Statement of David M. Walker 

Comptroller General of the United States 

GAO-05-794T 
Page 1 GAO-05-794T 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss our recent report on the rules that 

govern the funding of defined benefit (DB) plans and the implications of 

those rules for the problems facing the Pension Benefit Guaranty 

Corporation (PBGC) and the DB pension system generally.1 In recent 

years, the PBGC has encountered serious financial difficulties. Prominent 

companies, such as Bethlehem Steel, U.S. Airways, and United Airlines, 

have terminated their pension plans with severe gaps between the assets 

these plans held and the pension promises these plan sponsors made to 

their employees and retirees. These terminations, and other unfavorable 

market conditions, have created large losses for PBGC’s single-employer 

insurance program—the federal program that insures certain benefits of 

the more than 34 million participants in over 29,000 plans. The singleemployer program has gone from a $9.7 billion accumulated surplus at the 

end of fiscal year 2000 to a $23.3 billion accumulated deficit as of 

September 2004, including a $12.1 billion loss for fiscal year 2004. In 

addition, financially weak companies sponsored DB plans with a 

combined $96 billion of underfunding as of September 2004, up from $35 

billion as of 2 years earlier. Because PBGC guarantees participant benefits, 

there is concern that the expected continued termination of large plans by 

bankrupt sponsors will push the program more quickly into insolvency, 

generating pressure on the Congress, and ultimately the taxpayers, to 

provide financial assistance to PBGC and pension participants. 

Given these concerns, we placed the PBGC’s single-employer program on 

GAO’s high-risk list of agencies and programs that need broad-based 

transformations to address major challenges. In past reports, we identified 

several categories of reform that the Congress might consider to 

strengthen the program over the long term. We concluded that the 

Congress should consider comprehensive reform measures to reduce the 

risks to the program’s long-term financial viability and thus enhance the 

retirement income security of American workers and retirees.2

 1

See GAO, Private Pensions: Recent Experiences of Large Defined Benefit Plans Illustrate 

Weaknesses in Funding Rules, GAO-05-294 (Washington, D.C.: May 31, 2005). 

2

See GAO, Pension Benefit Guaranty Corporation: Single-Employer Pension Insurance 

Program Faces Significant Long-Term Risks, GAO-04-90 (Washington, D.C.: Oct. 29, 

2003). 
Page 2 GAO-05-794T 

More broadly, pension reform represents a real opportunity to address 

part of our long-term fiscal problems and reconfigure our retirement 

security systems to bring them into the 21st century.3

 This opportunity has 

many related pieces: addressing our nation’s large and growing long-term 

fiscal gap; deciding on the appropriate role and size of the federal 

government—and how to finance that government—and bringing the wide 

array of federal activities into line with today’s world. Continuing on our 

current unsustainable fiscal path will gradually erode, if not suddenly 

damage, our economy, our standard of living, and ultimately our national 

security. We therefore must fundamentally reexamine major spending and 

tax policies and priorities in an effort to recapture our fiscal flexibility and 

ensure that our government can respond to a range of current and 

emerging security, social, economic, and environmental changes and 

challenges. The PBGC’s situation is an excellent example of the need for 

the Congress to reconsider the role of government organizations, 

programs, and policies in light of changes that have occurred since 

PBGC’s establishment in 1974. 

PBGC’s challenges bear many similarities to the challenges facing our 

Social Security system. Both programs have adequate current revenues 

and assets to pay promised benefits for a number of years; yet, both face 

large and growing accumulated deficits on an accrual basis. As a result, 

timely action to address both private pension and Social Security reform is 

needed. In pursuing such reforms, consideration should be given to the 

interactive effects of any such reforms and how they contribute to 

addressing our nation’s large and growing fiscal challenge, key 

demographic, economic and workforce trends, and the economic security 

of Americans in their retirement years. 

Our recent work on DB pension funding rules provides important insights 

in understanding the problems facing PBGC and the DB system. To 

summarize our findings, while pension funding rules are intended to 

ensure that plans have sufficient assets to pay promised benefit to plan 

participants, significant vulnerabilities exist. Although from 1995 to 2002 

most of the 100 largest DB plans annually had assets that exceeded their 

current liabilities, by 2002 over half of the 100 largest plans were 

underfunded, and almost one-fourth of plans were less than 90 percent 

 3

See GAO, 21st Century Challenges: Re-Examining the Base of the Federal Government, 

GAO-05-325SP (Washington, D.C.: Feb. 2005). 
Page 3 GAO-05-794T 

funded.4 Further, because of leeway in the actuarial methodology and 

assumptions that sponsors may use to measure plan assets and liabilities, 

underfunding may actually have been more severe and widespread than 

reported. Additionally, on average over 60 percent of sponsors of these 

plans made no annual cash contributions to their plans. One key reason 

for this is that the funding rules allow a sponsor to satisfy minimum 

funding requirements without necessarily making a cash contribution each 

year, even though the plan may be underfunded. 5

 Further, very few 

sponsors of underfunded plans were required to pay an additional funding 

charge (AFC), a funding mechanism designed to reduce severe plan 

underfunding. Finally, our analysis confirms the notion that plans 

sponsored by financially weak firms pose a particular risk to PBGC, as 

these plans were generally more likely to be underfunded, to be subject to 

an additional funding charge, and to use assumptions to minimize or avoid 

cash contributions than plans sponsored by stronger firms. 

In DB plans, formulas set by the employer determine employee benefits. 

DB plan formulas vary widely, but benefits are frequently based on 

participant pay and years of service, and typically paid upon retirement as 

a lifetime annuity, or periodic payments until death. Because DB plans 

promise to make payments in the future and because tax-qualified DB 

plans must be funded, employers must use present value calculations to 

estimate the current value of promised benefits.6

 The calculations require 

making assumptions about factors that affect the amount and timing of 

 4

We analyzed DB pension data for the 100 largest plans as ranked by current liabilities 

reported on Schedule B of the Form 5500 for the years 1995 to 2002. The Form 5500 is a 

disclosure form that private sector employers with qualified pension plans are required to 

file with the Internal Revenue Service (IRS), Labor’s Employee Benefit Security 

Administration (EBSA), and PBGC. While our sample of plans represented only a small 

portion of the total plans in the single-employer program, it constitutes approximately 50 

percent of the total liabilities and about 28 percent of the total participants among DB plans 

that filed a Form 5500 in 2002. For more information on our methodology, see appendix I of 

GAO-05-294. 

5

An underfunded plan does not necessarily indicate that the sponsor is unable to pay 

current benefits. Underfunding means that the plan does not currently have enough assets 

to pay all accrued benefits, the majority of which will be paid in the future, under the given 

actuarial assumptions about asset rate of return, retirement age, mortality, and other 

factors that affect the amount and timing of benefits. 

6

Present value calculations reflect the time value of money—that a dollar in the future is 

worth less than a dollar today, because the dollar today can be invested and earn interest. 

Using a higher interest rate will lower the present value of a stream of payments because it 

implies that a lower level of assets today will be able to fund those future payments. 

Background 
Page 4 GAO-05-794T 

benefit payments, such as an employee’s retirement age and expected 

mortality, and about the expected return on plan assets, expressed in the 

form of an interest rate. The present value of accrued benefits calculated 

using mandated assumptions is known as a plan’s “current liability.” 

Current liability provides an estimate of the amount of assets a plan needs 

today to pay for accrued benefits. 

The Employee Retirement Income Security Act of 1974 (ERISA), and 

several amendments to the law since its passage, established minimum 

funding requirements for sponsors of pension plans in order to try to 

ensure that plans have enough assets to pay promised benefits. 

Compliance with the minimum funding requirements is recorded through 

the plan’s funding standard account (FSA). The FSA tracks events that 

affect the financial health of a plan during that plan year: credits, which 

reflect improvements to the plan’s assets, such as contributions, amortized 

experience gains, and interest; and charges, which reflect an increase in 

the plan’s financial requirements, such as the plan’s normal cost and 

amortized charges such as the initial actuarial liability, experience losses, 

and increases in a plan’s benefit formula.7,8

ERISA and the Internal Revenue Code (IRC) prescribe rules regarding the 

assumptions that sponsors must use to measure plan liabilities and assets. 

For example, for plan years 2004 and 2005, the IRC specifies that the 

interest rate used to calculate a plan’s current liability must fall within 90 

to 100 percent of the weighted average of the rate on an index of long-term 

investment-grade corporate bonds during the 4-year period ending on the 

last day before the beginning of the plan year.9

 Similarly, rules dictate that 

sponsors report an “actuarial” value of assets that must be based on 

reasonable assumptions and must take into account the assets’ market 

value. This value may differ in any given year, within a specified range, 

 7

Normal cost is the cost of pension benefits allocated to a specific plan year. 

8

Plans may amortize experience gains or losses over a 5-year period. Changes in the terms 

of the plan arising from plan amendments may be amortized over a 30-year period. Thus, 

these events continue to affect the FSA and plan funding for several years after they occur. 

9

The rate used to calculate current liability has usually been based on the 30-year Treasury 

bond rate, with the allowable range above and below the 4-year weighted average varying 

in different years. The Pension Funding Equity Act of 2004 replaced the Treasury bond rate 

with the corporate index for plan years 2004 and 2005. See IRC section 412(b)(5)(B)(ii)(II). 

For further discussion of rates used to discount pension liabilities, see GAO, Private 

Pensions: Process Needed to Monitor the Mandated Interest Rate for Pension 

Calculations, GAO-03-313 (Washington, D.C.: Feb. 27, 2003). 
Page 5 GAO-05-794T 

from the current market value of plan assets, which plans also report. 

While different methodologies and assumptions will change a plan’s 

reported assets and liabilities, sponsors eventually must pay the amount of 

benefits promised; if the assumptions used to compute current liability 

differ from the plan’s actual experience, current liability will differ from 

the amount of assets actually needed to pay benefits.10

Funding rules generally presume that the plan and the sponsor are ongoing 

entities, and plans do not necessarily have to maintain an asset level equal 

to current liabilities every year. However, the funding rules include certain 

mechanisms that are intended to keep plans from becoming too 

underfunded. One such mechanism is the AFC, introduced by the Omnibus 

Budget Reconciliation Act of 1987 (OBRA ‘87). The AFC requires sponsors 

of plans with more than 100 participants that have become underfunded to 

a prescribed level to make additional plan contributions in order to 

prevent funding levels from falling too low. With some exceptions, plans 

with an actuarial value of assets below 90 percent of current liabilities are 

affected by the AFC rules. 11

In addition to setting funding rules, ERISA established PBGC to guarantee 

the payment of the pension benefits of participants, subject to certain 

limits, in the event that the plan could not.12 Under ERISA, the termination 

of a single-employer DB plan may result in an insurance claim with the 

single-employer program if the plan has insufficient assets to pay all 

 10A plan’s current liability may differ from its “termination liability,” which measures the 

value of accrued benefits using assumptions appropriate for a terminating plan. For further 

discussion of current versus termination liability, see GAO-04-90, appendix IV. 

11A single-employer plan may be subject to an AFC in a plan year if plan assets fall below 90 

percent of current liabilities. However, a plan is not subject to an AFC if the value of plan 

assets (1) is at least 80 percent of current liability and (2) was at least 90 percent of current 

liability for at least 2 consecutive of the 3 immediately preceding years. To determine 

whether the AFC applies, the IRC requires sponsors to calculate current liabilities using the 

highest interest rate allowable for the plan year. See 26 U.S.C. 412(l)(9)(C). 

12Some DB plans are not covered by PBGC insurance; for example, plans sponsored by 

professional service employers, such as physicians and lawyers, with 25 or fewer active 

participants. 
Page 6 GAO-05-794T 

benefits accrued under the plan up to the date of plan termination.13 PBGC 

may pay only a portion of a participant’s accrued benefit because ERISA 

places limits on the PBGC benefit guarantee. For example, PBGC generally 

does not guarantee benefits above a certain amount, currently $45,614 

annually per participant at age 65.14 Additionally, benefit increases arising 

from plan amendments in the 5 years immediately preceding plan 

termination are not fully guaranteed, although PBGC will pay a portion of 

these increases.15 Further, PBGC’s benefit guarantee amount is limited to 

the monthly straight life annuity benefit the participant would receive if 

she were to commence the annuity at the plan’s normal retirement age.16

Sponsors of PBGC-insured DB plans pay annual premiums to PBGC for 

their coverage. Premiums have two components: a per participant charge 

paid by all sponsors (currently $19 per participant) and a “variable-rate” 

premium that some underfunded plans pay based on the level of unfunded 

benefits.17

 13The termination of a fully funded DB plan is called a standard termination. Plan sponsors 

may terminate fully funded plans by purchasing a group annuity contract from an insurance 

company, under which the insurance company agrees to pay all accrued benefits, or by 

paying lump-sum benefits to participants if permissible. The termination of an underfunded 

plan, termed a distress termination, is allowed if the plan sponsor requests the termination 

and the sponsor satisfies other criteria. Alternatively, PBGC may initiate an “involuntary” 

termination. PBGC may institute proceedings to terminate a plan if the plan has not met the 

minimum funding standard, the plan will be unable to pay benefits when due, a reportable 

event has occurred, or the possible long-run loss to PBGC with respect to the plan may 

reasonably be expected to increase unreasonably if the plan is not terminated. See 29 

U.S.C. 1342(a). 

14This guarantee level applies to plans that terminate in 2005. The amount guaranteed is 

adjusted (1) actuarially for the participant’s age when PBGC first begins paying benefits 

and (2) if benefits are not paid as a single-life annuity. Because of the way ERISA allocates 

plan assets to participants, certain participants can receive more than the PBGC 

guaranteed amount. 

15The guaranteed amount of the benefit amendment is calculated by multiplying the 

number of years the benefit increase has been in effect, not to exceed 5 years, by the 

greater of (1) 20 percent of the monthly benefit increase calculated in accordance with 

PBGC regulations or (2) $20 per month. See 29 C.F.R. 4022.25(b). 

16For more on PBGC guarantee limits, see Pension Benefit Guaranty Corporation, Pension 

Insurance Data Book 1999 (Washington, D.C., Summer 2000), pp. 2-14. 

17The additional premium equals $9.00 for each $1,000 (or fraction thereof) of unfunded 

vested benefits. However, no such premium is charged for any plan year if, as of the close 

of the preceding plan year, contributions to the plan for the preceding plan year were not 

less than the full funding limitation for the preceding plan year. 
Page 7 GAO-05-794T 

The recent decline of PBGC’s single-employer program has occurred in the 

context of the long-term stagnation of the DB system. The number of 

PBGC-insured plans has decreased steadily from approximately 110,000 in 

1987 to about 29,000 in 2004. While the number of total participants in 

PBGC-insured single-employer plans has grown approximately 25 percent 

since 1980, the percentage of participants who are active workers has 

declined from 78 percent in 1980 to 50 percent in 2002. Unless something 

reverses these trends, PBGC may have a shrinking plan and participant 

base to support the program in the future. 

From 1995 to 2002, while most of the 100 largest plans had sufficient 

assets to cover their plan liabilities, many did not. Furthermore, because of 

leeway in the actuarial methodology and assumptions sponsors can use to 

measure plan assets and liabilities, underfunding may actually have been 

more severe and widespread than reported at the end of the period. 

Because of flexible funding rules permitting the use of accounting credits 

other than cash contributions to satisfy minimum funding obligations, on 

average 62.5 of the 100 largest plans each year received no cash 

contributions from their sponsors. 

Although as a group, funding levels among the 100 largest plans were 

reasonably stable and strong from 1996 to 2000, by 2002, more than half of 

the largest plans were underfunded (see fig. 1). Two factors in the 

deterioration of many plans’ finances were the decline in stock prices and 

prevailing interest rates. From 2000 to 2002, stock prices declined sharply 

each year, causing a decline in the value of many plans’ pension assets. In 

addition, over the sample period, 30-year Treasury bond rates, which 

served as the benchmark for the rate used by plans to calculate pension 

liabilities, generally fell steadily, raising current liabilities. The 

combination of lower asset values and higher pension liabilities had a 

serious, adverse effect on overall DB plan funding levels. 

Many of the 100 

Largest Plans’ 

Liabilities Exceeded 

Plan Assets from 1995 

to 2002, and Few 

Sponsors Were 

Required to Make 

Cash Contributions 
Page 8 GAO-05-794T 

Figure 1: Almost One-Fourth of the Largest Pension Plans Were Less than 90 

Percent Funded on a Current Liability Basis in 2002 

Accurate measurement of a plan’s liabilities and assets is central to the 

sponsor’s ability to maintain assets sufficient to pay promised benefits, as 

well as to the transparency of a plan’s financial health. Because many 

plans chose allowable actuarial assumptions and asset valuation methods 

that may have altered their reported liabilities and assets relative to 

market levels, it is possible that funding over our sample period was 

actually worse than reported for a number of reasons. These include the 

use of above-market rates to calculate current liabilities and actuarial 

measurement of plan assets that differ from market values. 

Reported current liabilities are calculated using a weighted average of 

rates from the 4-year period before the plan year. While this allows 

sponsors to smooth fluctuations in liabilities that sharp swings in interest 

Rules May Allow Reported 

Funding Levels to 

Overstate Current Funding 

Levels 

0

20

40

60

80

100

1995 1996 1997 1998 1999 2000 2001 2002

Percentage of 100 largest DB plans

Source: GAO analysis of PBGC Form 5500 research data.

Year

Less than 80% funded 

80% to less than 90% funded

90% to less than 100% funded

100% to less than 110% funded

110% funded or above
Page 9 GAO-05-794T 

rates would cause, thereby reducing volatility in minimum funding 

requirements, it also reduces the accuracy of liability measurement 

because the rate anchoring reported liabilities is likely to differ from 

current market values. To the extent that the smoothed rate used to 

calculate current liabilities exceeds current rates, the 4-year smoothing 

could reduce reported liabilities relative to those calculated at current 

market values. Further, rules allowed sponsors to measure liabilities using 

a rate above the 4-year weighted average.18 The 4-year weighted average of 

the reference 30-year Treasury bond rate exceeded the current market rate 

in 76 percent of time in the months between 1995 and 2002, and the 

highest allowable rate for calculating current liabilities exceeded the 

current rate in 98 percent of those months. Sponsors of the plans in our 

sample chose the highest allowable interest rate to value their current 

liabilities 62 percent of the time from 1995 to 2002. For example, an 

interest rate 1 percentage point higher than the statutorily required 

interest rate would decrease the reported value of a typical plan’s current 

liability by around 10 percentage points. 

As with liabilities, the actuarial value of assets used for funding may also 

differ from current market values. Under the IRC, actuarial asset values 

cannot be consistently above or below market, but in a given year may be 

anywhere from 80 to 120 percent of market asset levels. Among the plans 

we examined, on average each year, 86 percent reported a different value 

for actuarial and market assets. On average, using the market value 

instead of the actuarial value of assets would have raised reported funding 

levels by 6.5 percent each year. However, while the market value exceeded 

the actuarial value of assets during the late 1990s, when plan funding was 

generally strong, in the weaker funding year of 2002 market assets dipped 

below actuarial assets. In 2001 and 2002, calculating plan funding levels 

using market assets would have greatly increased the number of plans 

below 90 percent funded each year. A similar calculation for 2002 would 

have drastically increased the number of large plans below 80 percent 

 18In 1987, the permissible range was not more than 10 percent above, and not more than 10 

percent below, the weighted average of the rates of interest on 30-year Treasury bond 

securities during the 4-year period ending on the last day before the beginning of the plan 

year. The top of the permissible range was gradually reduced by 1 percent per year, 

beginning with the 1995 plan year, to not more than 5 percent above the weighted average 

rate effective for plan years beginning in 1999. The top of the permissible range was 

increased to 20 percent above the weighted average rate for 2002 and 2003. For 2004 and 

2005, the Congress changed the reference rate from the 30-year Treasury bond rate to a 

rate based on long-term investment-grade corporate bonds, and reset the allowable range 

for plans to 90 to 100 percent of this rate. 
Page 10 GAO-05-794T 

funded, from 6 to 24. Thus, we see some evidence that using actuarial 

asset values lowered the volatility of reported funding levels relative to 

those using market asset values. However, the use of the actuarial value of 

assets also may have disguised plans’ funded status as their financial 

condition worsened. 

Two large plans that terminated in 2002 illustrate the potential effects of 

discrepancies between reported and actual funding. The Bethlehem Steel 

Corporation in 2002 reported that its plan was 85.2 percent funded on a 

current liability basis; yet, the plan terminated later that year with assets of 

less than half of the value of promised benefits. The PBGC single-employer 

program suffered a $3.7 billion loss as a result of that termination, its 

largest ever at the time. Similarly, LTV Steel Company reported that its 

pension plan for hourly employees was over 80 percent funded on its 

Form 5500 filing for plan year 2001. When this plan terminated in March, 

2002, it had assets equal to 52 percent of benefits, a shortfall of $1.6 billion. 

For the 1995 to 2002 period, the sponsors of the 100 largest plans each 

year on average made relatively small cash contributions to their plans. 

Annual cash contributions for the top 100 plans averaged approximately 

$97 million on plans averaging $5.3 billion in current liabilities, with 

figures in 2002 dollars.19 This average contribution level masks a large 

difference in contributions between 1995 and 2001, during which period 

annual contributions averaged $62 million, and in 2002, when 

contributions increased significantly to almost $395 million per plan. 

Further, in 6 of the 8 years in our sample, a majority of the largest plans 

made no cash contribution to their plan (see fig. 2). On average each year, 

62.5 plans received no cash contribution, including an annual average of 41 

plans that were less than 100 percent funded. 

 19 For the 100 largest plans that we examined, all dollar figures are reported in constant 

2002 dollars. 

Most Sponsors of Large 

Plans Did Not Make 

Annual Cash 

Contributions, but 

Satisfied Funding 

Requirements through Use 

of Accounting Credits 
Page 11 GAO-05-794T 

Figure 2: Most Large Plans Received No Annual Cash Contribution, 1995-2002 

Note: Average contributions for 2002 are largely driven by one sponsor’s contribution to its plan. 

Disregarding this $15.2 billion contribution reduces the average plan contribution for 2002 from $395 

million to $246 million. 

The funding rules allow sponsors to meet their plans’ funding obligations 

through means other than cash contributions. If a plan has sufficient FSA 

credits from other sources, such as an existing credit balance or large 

interest or amortization credits, to at least match its FSA charges, then the 

plan does not have to make a cash contribution in that year.20 Because 

meeting minimum funding requirements depends on reconciling total 

 20If FSA credits exceed charges in a given plan year, the plan’s FSA registers a net “credit 

balance” that may be carried forward to the next plan year; conversely, a prior year’s 

funding deficiency also carries forward. The FSA credit balance at year-end is equal to the 

FSA credit balance at the beginning of the year plus FSA credits less FSA charges. 

Compliance with the minimum funding standard requires that the FSA balance at the end 

of the year is non-negative. An existing credit balance accrues interest and may be drawn 

upon to help satisfy minimum funding requirements for future plan years, and it, therefore 

may offset the need for future cash contributions. 
Page 12 GAO-05-794T 

annual credits and charges, and not specifically on cash contributions, 

these other credits can substitute for cash contributions. 

From 1995 to 2002, it appears that many of the largest plan sponsors relied 

more heavily on other FSA credits than on cash contributions to meet 

minimum funding obligations. The average plan’s credit balance carried 

over from a prior plan year totaled about $572 million (2002 dollars) each 

year, and 88 percent of plans on average carried forward a prior credit 

balance into the next plan year from 1995 to 2002. Not only could these 

accumulated credit balances help a plan to meet minimum funding 

obligations in future years, but they also accrue interest that augments a 

plan’s FSA credits and further helps meet minimum funding requirements. 

In contrast, annual cash contributions averaged only $97 million, in 2002 

dollars. On average each year, cash contributions represented 90 percent 

of the minimum required annual funding (from cash and credits).21

However, this average figure was elevated by high levels of contributions 

by some plans in 1995, 1996, and 2002. From 1997 to 2000, when funding 

levels were generally strong, cash contributions averaged only 42 percent 

of minimum required annual funding. During these years, a majority of 

plans in our sample received no cash contribution. 

Cash contributions represented a smaller percentage of annual minimum 

required funding during years when plans were generally well funded, 

indicating that in these years more plans relied more heavily on credits to 

meet minimum funding obligations. In addition to large credit balances 

brought forward from prior years, sponsors were able to apply funding 

credits from other sources, such as net interest credits ($42 million per 

plan per year, on average), and credits from the excess of a plan’s 

calculated minimum funding obligation above the plan’s full funding 

limitation ($47 million).22 Other plan events result in plan charges, which 

reflect events that increase the plan’s obligations. For example, plans 

reported annual amortization losses, which could result from actual 

investment rates of return on plan assets below assumed rates of return 

(including outright losses) or increases in the generosity of plan benefits; 

these net amortization charges averaged almost $28 million in our sample. 

Funding credits, offset by charges, may help satisfy a plan’s minimum 

 21Minimum required annual funding equals annual total FSA charges, less net amortization 

credits and interest applied to these amortization credits. 

22Full funding limitation rules set a ceiling for minimum annual funding requirements for a 

plan each year, based on the plan’s liabilities. 
Page 13 GAO-05-794T 

funding obligation, substituting for cash contributions, and may explain 

why a significant number of sponsors made zero cash contributions to 

their plans in many years. 

The FSA credit accounting system provides some advantages to DB plan 

sponsors. Amortization rules require the sponsor to smooth certain events 

that affect plan finances over several years, and accumulated credit 

balances act as a buffer against swings in future funding requirements. 

These features often allow sponsors to better regulate their annual level of 

contributions, compared to annual fluctuations if funding were based 

strictly on yearly differences between the market value of plan assets and 

current liabilities. Similarly, current-law measurement and funding rules 

provide a plan with some ability to dampen volatility in required funding 

caused by economic events that may sharply change a plan’s liabilities or 

assets. Pension experts told us that this predictability and flexibility make 

DB sponsorship more attractive to employers.23

However, the FSA accounting system, by smoothing annual contributions 

and liabilities, may distort a plan’s funding level. For example, suppose a 

sponsor accrues a $1 million credit balance from making a contribution 

above the required minimum in a year. Suppose then that this $1 million 

purchases assets that lose all of their value by the following year. Even 

though the plan no longer had this $1 million in assets, the sponsor could 

still use that credit balance (plus interest on the credit balance) to reduce 

this year’s contribution to the plan. Because of amortization rules, the 

sponsor would have to report only a portion of that lost $1 million in asset 

value as a plan charge the following year. Similarly, sponsors are required 

to amortize the financial effect of a change in a plan’s benefit formula, 

which might result in increased benefits and therefore a higher funding 

obligation, over a 30-year period. Thus, even though higher benefits would 

immediately raise a plan’s obligation to fund, the sponsor must spread this 

effect in the plan’s FSA over 30 years. This disconnection between the 

reported and current market condition of plan finances raises the risk that 

plans will not react quickly enough to deteriorating plan conditions. 

Further, it reduces the transparency of plan financial information to 

stakeholders, such as participants, and investors. 

 23There are investment techniques, such as purchasing fixed income assets whose payouts 

match the plan’s expected payouts, which could make pension funding relatively 

predictable, even without FSA smoothing. One possible reason that such techniques are 

not widely used may be they are believed to be more expensive, over the long term than an 

asset allocation with significant equity investment exposure. 
Page 14 GAO-05-794T 

The experience of two large plans that terminated in a severely 

underfunded state help illustrate the potential disconnection between FSA 

accounting and the plan’s true funded status. As stated earlier, the 

Bethlehem Steel Corporation and LTV Steel Company both had plans 

terminate in 2002, each with assets approximately equal to 50 percent of 

the value of benefits. Yet each plan was able to forgo a cash contribution 

each year from 2000 to 2002 by using credits to satisfy minimum funding 

obligations, primarily from large accumulated credit balances from prior 

years. Despite being severely underfunded, each plan reported an existing 

credit balance in 2002, the year of termination. 

Another possible explanation for the many instances in which sponsors 

made no annual cash contribution regards the full funding limitation 

(FFL). The FFL is a cap on minimum required contributions to plans that 

reach a certain funding level in a plan year.24 However, the FFL does not 

represent the contribution that would raise plan assets to the level of 

current liability. The FFL represents a “maximum minimum” contribution 

for a sponsor in a given year—a ceiling on the sponsor’s minimum funding 

obligation for the plan. Between 1995 and 2002, rules permitted some 

plans with assets as low as 90 percent of current liability to reach the FFL, 

meaning that a plan could be considered fully funded without assets 

sufficient to cover all accrued benefits. The FFL is also distinct from the 

plan’s annual maximum tax-deductible contribution. Because sponsors 

may be subject to an excise tax on contributions above the maximum 

deductible amount, the annual maximum contribution can act as a real 

constraint on cash contributions. 

Flexibility in the FFL rule has allowed many plan sponsors to take steps to 

minimize their contributions. In our sample, from 1995 to 2002 

approximately two-thirds of the sponsors in each year made an annual 

plan contribution at least as large as the plan’s FFL. However, in 65 

percent of these instances, the sponsor had chosen the highest allowable 

rate to calculate current liability; using a lower rate to calculate current 

 24As with other funding rules, determining a plan’s FFL is complicated. From 1995 to 2002, 

the FFL equaled the higher of (1) 90 percent of the plan’s current liability or (2) the lower 

of (a) the accrued plan liability or (b) 150 to 170 percent (depending on the year) of the 

current liability. As of the 2004 plan year, the 150 to 170 percent measure no longer factors 

in the determination of the FFL. For our sample of plans, an average of 4 plans per year 

were above 150 to 170 percent (depending on the year) of the current liability and had an 

FFL of zero. This means the sponsors of these plans were most likely unable to make 

additional contributions unless they paid an excise tax. 

Full Funding Limitation 

Rule May Have Allowed 

Some Plan Sponsors to 

Forgo Plan Contributions 
Page 15 GAO-05-794T 

liability may have resulted in a higher FFL and, therefore, may have 

required a higher contribution. Further, the FFL was equal to zero for 60 

percent of plans each year, on average. This means that these plans were 

permitted to forego cash contributions as a result of the FFL rule. This 

reflects the fact that if a plan’s FFL equaled zero, that plan had assets at 

least equal to 90 percent of current liabilities that year and would not be 

required to make an additional contribution. 

The interaction between the FFL rule and the annual maximum taxdeductible contribution also has implications on the amount that plan 

sponsors can contribute. In some years, the maximum deductible 

contribution rules truly constrained some sponsors from making any cash 

contribution. In 1998, 50 of the 60 plans that contributed to the maximum 

deductible amount had a maximum deductible contribution of zero (see 

fig. 3). This meant that any cash contribution into those plans that year 

would generally subject the sponsor to an excise tax.25 For 37 of these 

plans, this was the case even if the sponsor had chosen the lowest 

statutorily allowed interest rate for plan funding purposes, which would 

have produced the highest calculated current liabilities. This constraint 

did not apply to as many plans in some other years. For example, in 1996, 

52 plans contributed the maximum deductible amount. Thirty of these 

plans had a maximum deductible contribution of zero. Fourteen of the 

plans in this situation could not have made any additional contributions. 

However, the other 16 could have made at least some contributions by 

choosing a lower interest rate to raise their maximum deductible 

contribution level. 

 25 For years after 2001, an employer may elect not to count contributions as nondeductible 

up to the full-funding limitation that is based on the accrued liability. Therefore, it could be 

possible for a sponsor to contribute more than the maximum deductible amount and still 

avoid the excise tax. See 26 U.S.C. 4972(c)(7). 
Page 16 GAO-05-794T 

Figure 3: For Selected Years from 1996 to 2002, Most Sponsors Contributed the 

Plan’s Maximum Deductible Amount, Which for a Number of Plans Was Zero 

Note: Years of analysis are not continuous, as the PBGC study on maximum deductible contributions 

was conducted for years shown. Information on maximum deductible contributions is missing for 

between 7 and 17 plans each year. Data for these plans were either missing or incomplete to 

calculate the plan contributions with respect to the maximum deductible contribution. 

Funding rules dictate that a sponsor of a plan with more than 100 

participants in which the plan’s actuarial value of assets fall below 90 

percent of liabilities, measured using the highest allowable interest rate, 

may be liable for an AFC in that year. More specifically, a plan that is 

between 80 and 90 percent funded is subject to an AFC unless the plan 

was at least 90 percent funded in at least 2 consecutive of the 3 previous 

plan years. A plan with assets below 80 percent of liabilities, calculated 

Very Few Sponsors of 

Underfunded Large 

Plans Paid an AFC 

from 1995 to 2002 

0

10

20

30

40

50

60

70

Percentage of 100 largest DB plans

Source: GAO analysis of PBGC Form 5500 research data matched to PBGC study on maximum deductible cash contributions.

Year

Plans that contributed the maximum deductible amount with some cash contributions 

1996 1998 2000 2001 2002

Plans that contributed the maximum deductible amount with zero cash contributions but could have 

used a lower interest rate to increase cash contributions

Plans that contributed the maximum deductible amount with zero cash contributions and could not

use a lower interest rate to increase cash contributions
Page 17 GAO-05-794T 

using the highest allowable rate, is assessed an AFC regardless of its 

funding history.26

Despite the statutory threshold of a 90 percent funding level for some 

plans to owe an AFC, in practice a plan needed to be much more poorly 

funded to become subject to an AFC. While about 10 plans in our sample 

each year had funding below 90 percent on a current liability basis, on 

average fewer than 3 plans each year owed an AFC (see fig. 4). From 1995 

to 2002, only 6 of the 187 unique plans that composed the 100 largest plans 

each year were ever assessed an AFC,27 and these plans owed an AFC a 

total of 23 times in years in which they were among the 100 largest plans. 

By the time a sponsor owed an AFC, its plan had an average funding level 

of 75 percent, suggesting that by the time the AFC was triggered, the plan’s 

financial condition was weak. Further, while we observed 60 instances 

between 1995 and 2002 in which a plan had funding levels between 80 and 

90 percent, only 5 times was a plan in this funding range subject to an 

AFC. This would indicate that, in practice, 80 percent represented the 

realistic funding threshold for owing or avoiding the AFC. 

 26 The rules for determining the amount of the AFC are complex, but they generally call for 

sponsors to pay a percentage of their unfunded liability. Under current law, plans that owe 

an AFC may still apply FSA credits to meet their funding obligation and, therefore, may not 

be required to satisfy the AFC with a cash contribution. 

27 Unique plans refer to the number of plans we observed with distinct plan identifiers 

called EINs and PINs. See footnote 9 of GAO-05-294 for further information on why the 

actual number of completely unrelated plans in our sample may be lower than the 187 

reported. 
Page 18 GAO-05-794T 

Figure 4: Most Plans Less Than 90 Percent Funded Were Not Assessed an AFC 

Even with those plans subject to an AFC, other FSA credits may help a 

plan satisfy minimum funding obligations. Among plans in our sample 

assessed an AFC, the average annual AFC owed was $234 million, but 

annual contributions among this group averaged $186 million, with both 

figures in 2002 dollars. In addition, 61 percent of the time a plan was 

subject to an AFC, the sponsor used an existing credit balance to help 

satisfy its funding obligation. Over 30 percent of the time a plan was 

assessed an AFC, the funding rules allowed the sponsor to forgo a cash 

contribution altogether that year. Sponsors that owed an AFC had mixed 

success at improving their plans’ financial conditions in subsequent years, 

and most of these plans remained significantly underfunded. Among the 6 

plans that owed the AFC, funding levels rose slightly from an average 75 

percent when the plan was first assessed an AFC to an average 76 percent, 

looking collectively at all subsequent years. All of these plans were 

assessed an AFC more than once. 

Again, terminated plans provide a stark illustration of weaknesses in the 

rules’ ability to ensure sufficient funding. Bethlehem Steel’s plan was 

assessed an AFC of $181 million in 2002, but the company made no cash 

0

5

10

15

20

25

Percentage of 100 largest DB plans

Source: GAO analysis of PBGC Form 5500 research data.

Year

Plans less than 90% funded 

Plans assessed an AFC

1995 1996 1997 1998 1999 2000 2001 2002
Page 19 GAO-05-794T 

contribution that year, just as it had not in 2000 or 2001, years in which the 

plan was not assessed an AFC. When the plan terminated in late 2002, its 

assets covered less than half of the $7 billion in promised benefits. LTV 

Steel, which terminated its pension plan for hourly employees in 2002 with 

assets of $1.6 billion below the value of benefits, had its plan assessed an 

AFC each year from 2000 to 2002, but for only $2 million, $73 million, and 

$79 million, or no more than 5 percent of the eventual funding shortfall. 

Despite these AFC assessments, LTV Steel made no cash contributions to 

this plan from 2000 to 2002. Both plans were able to apply existing credits 

instead of cash to fully satisfy minimum funding requirements. 

The recent funding experiences of large plans, especially those sponsored 

by financially weak firms, illustrate the limited effectiveness of certain 

current funding rules and represent a potentially large implicit financial 

risk to PBGC. The financial health of a plan sponsor may be key to plan 

funding decisions because sponsors must make funding and contribution 

decisions in the context of overall business operations. From 1995 to 2002, 

on average, 9 percent of the largest 100 plans were sponsored by a firm 

with a speculative grade credit rating, suggesting financial weakness and 

poor creditworthiness.28

Financial strength of plan sponsors’ business operations has been a key 

determinant of risk to PBGC. Financially weak sponsors of large, 

underfunded plans are, by the nature of the insurance offered by PBGC, 

likely to cause the most financial burden to PBGC and other premium 

payers. For instance, PBGC typically trustees a plan when a covered 

sponsor is unable to financially support the plan, such as in the event of 

bankruptcy or insolvency. Current funding rules, coupled with the 

presence of PBGC insurance, may create incentives for financially 

distressed plan sponsors to avoid or postpone contributions and increase 

benefits. Many of the minimum funding rules are designed so that 

sponsors of ongoing plans may smooth contributions over a number of 

years. Sponsors that are in financial distress, however, may have a more 

 28Credit ratings are generally considered to be a useful proxy for a firm’s financial health. A 

credit rating, generally speaking, is a rating service’s current opinion of the 

creditworthiness of an obligor with respect to a financial obligation. It typically takes into 

consideration the creditworthiness of guarantors, insurers, or other forms of credit 

enhancement on the obligation and takes into account the currency in which the obligation 

is denominated. Moody’s and Standard and Poor’s (S&P) are two examples of well-known 

ratings services. 

Large Plans’ 

Sponsors’ Credit 

Ratings Appear 

Related to Certain 

Funding Behavior and 

Represent Risk to 

PBGC 
Page 20 GAO-05-794T 

limited time horizon and place other financial priorities above “funding 

up” their pension plans. To the extent that the presence of PBGC 

insurance causes financially troubled sponsors to alter their funding 

behavior, PBGC’s potential exposure increases. 

Underfunded plans sponsored by financially weak firms pose the greatest 

immediate threat to PBGC’s single-employer plans. PBGC’s best estimate 

of the total underfunding of plans sponsored by companies with credit 

ratings below investment grade and classified by PBGC as “reasonably 

possible” to terminate was an estimated $96 billion as of September 30, 

2004 (see fig. 5).29

 29 Criteria used for classifying a plan as a reasonably possible termination include, but are 

not limited to, one or more of the following conditions: the plan sponsor is in Chapter 11 

reorganization; funding waiver pending or outstanding with the Internal Revenue Service; 

sponsor missed minimum funding contribution; sponsor’s bond rating is below-investmentgrade for Standard & Poor’s (BB+) or Moody’s (Ba1); sponsor has no bond rating but 

unsecured debt is below investment grade; or sponsor has no bond rating, but the ratio of 

long-term debt plus unfunded benefit liability to market value of shares is 1.5 or greater. 
Page 21 GAO-05-794T 

Figure 5: Total Underfunding among All DB Plans, and among Those Considered by 

PBGC as Reasonably Possible for Termination, Has Increased Markedly since 2001 

Note: Underfunding figures for non-reasonably possible plans represent the end of the calendar year, 

except for 2004, which represents the end of fiscal year 2004 (September 30, 2004). Figures for 

reasonably possible plans are taken as of the end of each fiscal year. 

From 1995 to 2002, we observed that plans sponsored by speculative 

grade-rated firms had lower levels of average funding compared with the 

average for the 100 largest plans. For instance, the average funding of 

these plans was 12 percentage points lower on average than the funding 

level for all plans from 1995 to 2002. Plans sponsored by speculative graderated firms were also more likely to be underfunded. From 1995 to 2002, 

each year, on average, 18 percent of plans sponsored by speculative graderated firms had assets that were below 90 percent of current liability. 

Plans sponsored by nonspeculative grade-rated firms had just over half 

this incidence, or an average of 10 percent of plans funded below 90 

percent of current liability. 

Plans Sponsored by 

Financially Weak Firms 

Exhibit Riskier Funding 

Behavior 
Page 22 GAO-05-794T 

Large plans sponsored by firms with a speculative grade rating were also 

more likely to incur an AFC. While plans sponsored by speculative graderated firms accounted for only 9 percent of all plans that we examined 

over the 1995 to 2002 period, they accounted for just over one-third of all 

instances in which a sponsor was required to pay an AFC. In contrast, no 

high investment grade sponsors (those rated AAA or AA) were required to 

pay an AFC for this period. While the AFC is intended to be a backstop for 

underfunded plans, to the extent that plans sponsored by speculative 

grade-rated firms are considered to pose a significant risk for near-term 

termination, it may not be an effective mechanism for improving a plan’s 

funding level. Plans sponsored by firms that are in financial distress are, by 

definition, having difficulty paying off debts and may be ill equipped to 

afford increased contributions to their plan. That is, the AFC itself may be 

a symptom of plan distress rather than a solution to improve a plan’s 

funding level. 

Large plans with sponsors rated as speculative grade were also generally 

more likely to use the highest allowable interest rate to compute their 

current liability under the minimum funding rules. While a majority of 

sponsors from all credit rating categories used the highest allowable 

interest rate, over the entire 1995 to 2002 period, speculative grade-rated 

sponsors used the highest rate at an incidence 23 percentage points above 

the incidence for all other plans in the sample. The use of higher interest 

rates likely lowers a plan’s reported current liability and minimum funding 

requirement. To the extent that this depresses cash contributions, such 

plans may have a higher chance of underfunding, thus creating additional 

financial risk to PBGC. 

PBGC’s claims experience shows that financially weak plans have been a 

source of substantial claims. Of the 41 largest claims in PBGC history in 

which a rating was known, 39 of the plan sponsors involved were credit 

rated as speculative grade at least 3 years prior to termination (see fig. 6). 

These claims account for 67 percent of the value of total gross claims on 

the single-employer program from 1975 to 2004. Most of the plan sponsors 

involved in these claims were given speculative grade ratings for many 

more years prior to their eventual termination. Even 10 years prior to plan 

termination, 33 of these 41 claims involved sponsors rated as speculative 

grade. 
Page 23 GAO-05-794T 

Figure 6: Over 80 Percent of Sponsors Associated with PBGC’s Largest 

Termination Claims Had Speculative Grade Ratings 10 Years Prior to Termination 

Note: Based on 41 of PBGC’s largest gross claims in which the rating of the sponsor was known, 

representing over 67 percent of total gross claims from 1975 to 2004. These 41 claims may include 

sponsors with more than one plan and are not limited to those plans in our sample. Ratings based on 

S&P rating. 

Widely reported recent large plan terminations by bankrupt sponsors and 

the financial consequences for PBGC have pushed pension reform into the 

spotlight of national concern. Our analysis here suggests that certain 

aspects of the funding rules have contributed to the general underfunding 

of pensions and, indirectly, to PBGC’s recent financial difficulties. The 

persistence of a large number of underfunded plans, even during the 

strong economic period of the late 1990s, implies that current funding 

rules are not stringent enough to ensure that sponsors can fund their 

pensions adequately. Further, the rules appear to lack strong mechanisms 

to compel sponsors to make regular contributions to their plans, even 

those that are underfunded or subject to an AFC. Perhaps most troubling 

is that current rules for measuring and reporting plan assets and liabilities 

may not reflect true current values and often understate the true degree of 

underfunding. 

Conclusions 

0

10

20

30

40

50

60

70

80

90

100

Percentage of plan sponsors associated with PBGC’s largest claims

Source: PBGC.

Years prior to date of plan termination 

Investment grade-rated 

10 9 8 7 2 1 6 543

Speculative grade-rated
Page 24 GAO-05-794T 

The current rules have the reasonable and important goals of long-term 

funding adequacy and short-term funding flexibility. However, our work 

shows that although the current system permits flexibility, it also permits 

reported plan funding to be inadequate, misleading, and opaque; even so, 

funding and contributions for some plans can still swing wildly from year 

to year. This would appear not to serve the interest of any DB pension 

stakeholders effectively. The challenge is determining how to achieve a 

balance of interests: how to temper the need for funding flexibility with 

accurate measurement, adequate funding, and appropriate transparency. 

Despite flaws in the funding rules, our work here shows that most of the 

largest plans appear to be adequately funded. Rules should acknowledge 

that funding will vary with cyclical economic conditions, and even 

sponsors who make regular contributions may find their plans 

underfunded on occasion. Periodic and mild underfunding is not usually a 

major concern, but it becomes a threat to workers’ and retirees’ economic 

security in retirement and to PBGC when the sponsor becomes financially 

weak and the risk of bankruptcy and plan termination becomes likely. This 

suggests that perhaps the stringency of certain funding rules should be 

adjusted depending on the financial strength of the sponsor, with stronger 

sponsors being allowed greater latitude in funding and contributions than 

weaker sponsors that might present a near-term bankruptcy risk. 

However, focusing more stringent funding obligations on weak plans and 

sponsors alone may not be adequate, because strong companies and 

industries can quickly become risky ones, and, once sponsors and plans 

become too weak, it may be difficult for them to make larger contributions 

and still recover. 

It should be noted also that while funding rule change is an essential piece 

of the overall reform puzzle, it is certainly not the only piece. Indeed, 

pension reform is a challenge precisely because of the necessity of fusing 

together so many complex, and sometimes competing, elements into a 

comprehensive proposal. Ideally, effective reform would 

• improve the accuracy of plan asset and liability measurement while 

minimizing complexity and maintaining contribution flexibility; 

• develop a PBGC insurance premium structure that charges sponsors fairly, 

based on the risk their plans pose to PBGC, and provides incentives for 

sponsors to fund plans adequately; 

• address the issue of severely underfunded plans making lump-sum 

distributions; 
Page 25 GAO-05-794T 

• resolve outstanding controversies concerning cash balance and other 

hybrid plans by safeguarding the benefits of workers regardless of age; 

and 

• improve plan information transparency for PBGC, plan participants, 

unions, and investors in a manner that does not add considerable burden 

to plan sponsors. 

As deliberations on reform move forward, it will be important that each of 

these individual elements be designed so that all work in concert toward 

well-defined goals. Even with meaningful, carefully crafted reform, it is 

possible that some DB plan sponsors may choose to freeze or terminate 

their plans. While these are serious concerns, the overarching goals of 

balanced pension reform should be to protect the retirement benefits of 

American workers and retirees by providing employers reasonable funding 

flexibility while also holding those employers accountable for the 

promises they make to their employees. 

As I noted in my opening remarks, PBGC’s challenges parallel the 

challenges facing our Social Security system. While both programs have 

adequate current revenues and assets to pay promised benefits today, both 

face large and growing accumulated deficits on an accrual basis. Further, 

timely action to address both private pension and Social Security reform is 

needed. However, consideration must be given to the interactive effects of 

any such reforms and how they contribute to addressing our nation’s large 

and growing fiscal challenge, key demographic, economic and workforce 

trends, and the economic security of Americans in their retirement years. 

Mr. Chairman, this concludes my statement. I would be happy to respond 

to any questions you or other Members of the Committee may have. 

For further information, please contact Barbara Bovbjerg at (202) 512-

7215. Contact points for our Office of Congressional Relations and Public 

Affairs may be found on the last page of this testimony. Other individuals 

making key contributions to this testimony included Charlie Jeszeck, Mark 

Glickman, and Chuck Ford. 

Contact and 

Acknowledgments 

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