Page 1 GAO-05-991R Private Pensions 

September 9, 2005 

The Honorable John Lewis 

Ranking Minority Member 

Subcommittee on Oversight 

Committee on Ways and Means 

House of Representatives 

The Honorable Earl Pomeroy 

House of Representatives 

Subject: Private Pensions: Questions Concerning the Pension Benefit Guaranty Corporation’s 

Practices Regarding Single-Employer Probable Claims

The Pension Benefit Guaranty Corporation’s (PBGC) single-employer insurance program is a federal 

program that insures certain benefits of the more than 34 million worker, retiree, and separated vested 

participants of over 29,000 private sector defined benefit pension plans. In 2003, we placed PBGC’s 

single-employer insurance program on our high-risk list of agencies and programs that need broad-based 

transformations to address major challenges because of our concerns about the program’s long-term 

viability. In recent years, because of unfavorable economic conditions and the collapse of large 

underfunded pension plans sponsored by well-known firms like Bethlehem Steel, U.S. Airways, and 

United Airlines, the program’s financial condition has worsened significantly. From a $9.7 billion surplus 

at the end of fiscal year 2000, the program reported a $23.3 billion deficit as of September 2004, including 

a $12.1 billion loss for fiscal year 2004. While 73 percent ($16.9 billion) of this deficit is due to PBGC’s 

estimated liability for its probable claims (claims from plans that PBGC deems likely to terminate in the 

future), historically over 95 percent of claims so classified by the PBGC have subsequently terminated 

and become direct obligations of the agency. 

We are providing answers to several of your questions about single-employer probable claims regarding 

(1) PBGC’s methodology for determining single-employer probable claims, (2) PBGC’s efforts to monitor 

probable claims, and (3) PBGC’s practices for disclosing financial information about these claims. 

To answer the questions, we reviewed documentation from PBGC on its process for determining, 

tracking, and monitoring probable claims. We also reviewed PBGC’s historical data on these claims and 

PBGC’s public disclosures regarding them, and reviewed documentation about PBGC practices for 

disclosing such information. We conducted our work from August to September 2005 in accordance with 

generally accepted government auditing standards. Your questions, along with our responses, follow. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-991R Private Pensions 

1. What is PBGC’s specific methodology for determining probable claims? 

There are three concurrent steps to PBGC’s process for determining single-employer probable claims: 

(1) identifying underfunded defined benefit plans insured by PBGC, 

(2) classifying underfunded plans as to the probability of a loss to PBGC, and 

(3) estimating the potential loss to PBGC. 

The first step in determining probables is to identify underfunded insured plans. To accomplish this, 

PBGC relies on information from Section 4010 filings, 1 reportable event and distress termination filings,2

credit ratings, and other sources. Section 4010 filings provide PBGC with actuarial information on 

underfunded plans and financial information for companies with aggregate unfunded vested liability 

(calculated using PBGC variable rate premium assumptions) exceeding $50 million. The major types of 

reportable events filings that PBGC uses to identify underfunded plans include the inability of a plan 

to pay participants the benefits due them in the form prescribed by the plan, bankruptcy or insolvency 

proceedings, liquidation proceedings or the dissolving of the plan sponsor, and a plan failing to meet the 

minimum funding standards. PBGC is notified of reportable events affecting approximately 300 plans per 

year. On average, 200 of these cases undergo standard terminations or continue without termination, 

resulting in PBGC not taking over the plan.3

 The remaining 100 plans eventually become distress 

terminations or involuntary terminations---the termination of an underfunded plan.4

 Additionally, 

voluntary distress termination filings alert PBGC to plan sponsors who wish to terminate their 

underfunded plans. 

PBGC also uses credit ratings in its process to identify and classify underfunded plans. These ratings 

provide an assessment of a plan sponsor’s credit quality, which includes the ability of a company to meet 

its financial obligations. PBGC seeks information as to whether a company’s bonds are investment-grade 

or below investment-grade.5

 PBGC uses Moody’s ratings, Standard and Poor’s (S&P) ratings, and other 

financial criteria to make their determinations. If there is no rating, PBGC staff determines an implied 

rating as to whether a plan sponsor’s bond would be rated as investment grade or not based upon an 

 

1

Section 4010 of the Employee Retirement Income Security Act (ERISA) requires the reporting of plan actuarial and company 

financial information by employers with plans that have aggregate unfunded vested benefits in excess of $50 million, missed 

required contributions in excess of $1 million, or outstanding minimum funding waivers in excess of $1 million. The information

required to be filed includes (1) plan identifying information, (2) actuarial information regarding the plan’s fair market value of 

assets and the value of benefit liabilities on a PBGC termination liability basis, and (3) financial information, such as financial 

statements. 

2

At least one of the following criteria must be met in order for PBGC to approve a distress termination filing: (1) liquidation in 

bankruptcy (Chapter 7) or insolvency proceedings; (2) reorganization in bankruptcy (Chapter 11); (3) a company will be unable 

to continue to stay in business unless its plan is terminated; and (4) unreasonable, burdensome pension costs caused solely by a 

decline in workforce. 

3

The termination of a fully funded defined benefit plan is called a standard termination. 

4

PBGC may initiate involuntary terminations for several reasons, including if PBGC’s loss from that plan may be expected to 

increase unreasonably if the plan is not terminated. See 29 U.S.C. 1342(a). 

5

The term “investment grade” was originally used by various regulatory bodies to connote obligations eligible for investment by 

institutions such as banks, insurance companies, and savings and loan associations. Over time, this term gained widespread 

usage throughout the investment community. Ratings in the four highest categories, AAA, AA, A, and BBB, generally are 

recognized as being investment grade. Below investment grade is considered to be either Moody’s Ba1 or lower or S&P BB+ or 

lower. 
Page 3 GAO-05-991R Private Pensions 

evaluation of financial statement information included in 4010 filings and other available financial 

information.6

 If the rating agencies give the company different ratings, (one agency rates a company 

below investment grade while the other rates the company investment grade), PBGC will use the lower 

of the ratings based on the conservatism principle of the Generally Accepted Accounting Principles 

(GAAP).7

Finally, PBGC relies on several other sources of information. For example, to identify potentially 

underfunded plans sponsored by privately held companies, PBGC uses data from premium filings 

submitted by the plan sponsors. In addition, PBGC monitors news sources (e.g., Bloomberg, LiveEdgar, 

and NewsEdge) to identify transactions that could adversely affect plan funding status, and ultimately, 

PBGC. 

As underfunded plans are identified, PBGC classifies each plan as to the probability of a loss to PBGC. 

Plans are classified as “remote-other,” “remote,” “reasonably possible,” or “probable” according to 

criteria that PBGC has determined meets the requirements of the Statement of Financial Accounting 

Standards No. 5 Accounting for Contingencies (FAS No. 5), which establishes standards for accounting 

and reporting for loss contingencies: 

• Plans are classified as remote-other if there is no available information with which to make a 

reasonable assessment of financial conditions. 

• Plans are categorized as remote if the plan sponsor’s bonds are rated investment grade by both 

Moody’s and S&P or PBGC has assessed the plan sponsor as investment grade. 

• Plans are classified as reasonably possible if they have over $50 million in aggregate underfunding, 

the plan sponsor’s bonds are below investment grade, have applied for a minimum funding wavier 

with the Internal Revenue Service, have missed a minimum funding contribution, or are in 

reorganization under Title 11 of the United States Code. 

In order for PBGC to classify a plan as probable, a plan must meet, as of the financial statement date, at 

least one of the seven criteria PBGC uses, five of which it characterizes as objective, and two as 

subjective. Objective criteria are used where substantial evidence exists to indicate that the plan sponsor 

is in liquidation or insolvency proceedings or will meet the requirements for a distress or involuntary 

termination. Subjective criteria involve management judgment. According to PBGC, subjective criteria 

must typically be used when most plans meet the criteria for recognition under FAS No. 5 of GAAP while 

in or close to reorganization under Chapter 11 bankruptcy. Table 1 shows the different applications of 

the objective and subjective criteria used to classify plans as probable. 

 

6

The implied rating is completed twice a year. 

7

The conservatism principle is the accounting principle that guides accountants to select the less optimistic estimate when two 

estimates of amounts to be received or paid are about equally likely.
Page 4 GAO-05-991R Private Pensions 

Table 1: List of Probable Classification Criteria 

Type of Criteria Description of Criteria 

Objective The plan’s contributing sponsor(s) is in liquidation under Title 11 of the United States Code or 

comparable state insolvency proceeding. 

Objective PBGC has received a distress termination filing, and substantial evidence exists that the requirement 

for a distress termination are likely to be met. 

Objective PBGC has been informed that a distress termination will be filed, and substantial evidence exists that 

the requirements for a distress termination are likely to be met. 

Objective PBGC has advised the plan administrator that a distress termination should be filed, and substantial 

evidence exists that the requirements for a distress termination are likely to be met. 

Objective PBGC is considering or is expected to consider the plan for an involuntary termination, and substantial 

evidence exist that the requirements for an involuntary termination are likely to be met. 

Subjective The plan was classified as reasonably possible and it was determined that the plan is a very high risk 

plan that should be classified as probable. 

Subjective Plans can be classified as probable if any other set of circumstances exist that in PBGC’s judgment 

constitute a probable termination. 

Source: GAO analysis of PBGC data. 

In fiscal year 2004, PBGC classified 45 plans as probable; 29 of these were based strictly on objective 

criteria and accounted for almost $1 billion in probable claims. The remaining 16 required consideration 

of subjective criteria, representing nearly $16 billion in probable claims. 

Once a plan is classified as probable, PBGC begins to estimate the probable losses and does so 

according to GAAP and FAS No. 5 standards. To calculate the fiscal year--end financial statement assets 

and liabilities for probable plans, PBGC uses an automated system known as the Integrated Present 

Value of Future Benefits (IPVFB) system. Plan information, such as Form 5500 filings, asset statements, 

annuity purchases, contributions, and estimated dates of plan termination are entered into the IPVFB 

system in order to calculate asset and liability amounts as of the date of plan termination and fiscal year 

end. This process adjusts the liabilities from the plan’s assumptions (mortality, interest, and expected 

retirement age) to standard assumptions used by PBGC. This system then produces a report that 

provides PBGC staff with information on how the assets and liabilities are brought forward, from the 

Actuarial Valuation Report date to the date of the financial statements. To meet the requirements of FAS 

No. 5, PBGC accrues its net probable claims in its financial statements. 

PBGC stated its exposure for probable claims in accordance with FAS No. 5 as required by GAAP. 

Directed at the accounting objective of full disclosure, this standard requires the PBGC to record a loss 

if it is likely to occur and the amount of the loss can be reasonably estimated. PBGC’s financial 

statement auditors routinely review this area and its compliance with GAAP requirements as part of 

their annual audit. PBGC has consistently used a method of specifically identifying potential claims 

supplemented by estimates for additional claims that might be missed by its method for selecting 

probable claims. 

2. The description of PBGC’s method for selecting plans that are probable changed from 2003 to 2004. 

Does this reflect a change in methodology for selecting plans in the past decade? Why does PBGC not 

disclose the effects of the changes in methodology on the amount of probable claims? What was the 

effect of the most recent changes?
Page 5 GAO-05-991R Private Pensions 

According to PBGC officials, the 2004 Annual Report expanded the footnote disclosure describing 

PBGC’s method for selecting probable plans but stressed that this did not reflect a change in 

methodology.8

 PBGC officials stated that the 2004 report was intended to provide a more explicit 

description of the specific criteria PBGC uses. These officials also emphasized that PBGC has 

consistently used a specific identification method as required by FAS No. 5 for its identification of 

probables. 

While PBGC did not change its methodology or criteria for determining probable terminations in fiscal 

year 2004, it did make revisions to the way it calculates reserves for unidentified probable losses. PBGC 

stated that this was done in response to a PBGC Office of Inspector General recommendation arising 

from the PricewaterhouseCooper’s audit of PBGC’s 2003 financial statements. The recommendation 

stated that PBGC should “reevaluate the methods by which PBGC calculates its reserves.” As a result, 

PBGC initiated a study to determine how its reserve calculations could be improved, and implemented 

improvements and expanded disclosures for fiscal year 2004. We did not receive information on the 

effect of this revision for calculating reserves for unidentified probable losses. However, PBGC stated 

that it is preparing such an analysis, and noted that its estimate for unidentified probable losses over the 

2 year period, both before and after the revision, constituted less than 4 percent of the total probables 

estimate.9

3. What controls does PBGC have in place to ensure that current methodologies for selecting probable 

claims are sufficiently like prior procedures?

PBGC officials stated that they have not made any changes to PBGC’s method for selecting probable 

claims. If PBGC were to make changes to its procedures or methodologies, these officials told us that 

they would use a multifaceted approach to review and consider those changes. PBGC regularly 

monitors, reclassifies, and revalues estimates of exposure on all at-risk plans. Any changes proposed 

would go through PBGC’s internal review process, which includes a review and concurrence by PBGC’s 

Contingency Working Group and Chief Financial Officer. 

PBGC officials stated that if a change in methodology were to occur, they would disclose the effect of 

such methodology changes in accordance with GAAP. In addition, any necessary restatements of prior 

year amounts would be made, including appropriate disclosures describing the effect in the notes to the 

financial statements. 

4. How do probable claims progress? What is the average duration, in years, of a claim on the 

probable claims list? What is the distribution of probable claims by year added?

Probable claims can progress in a number of ways after a plan is initially added to the list, which is 

updated three times a year. At each update, a plan can remain on the list, be removed from the list 

because of termination, or be deleted from the list if an upgrade in classification is warranted based on a 

 

8

PBGC’s 2004 Annual Report, Washington D.C. 20005 

9

The reserves represented $0.4 billion of the $16.9 billion in net probable claims for fiscal year 2004 and $0.2 billion of the $5.2 

billion in net probable claims for fiscal year 2003. The reserves are comprised of a reserve for large unidentified probable losses 

and a reserve for small unidentified probable losses. According to the 2004 Annual Report, the current method for estimating 

the reserve for large unidentified probable losses is recorded based on sound, actuarial methodologies that consider actual 

PBGC experience, as well as the historical industry bond default rates. This reserve has been developed by segregating plan 

sponsors with aggregate underfunding equal to or greater than $5 million into risk bands, which reflect their level of credit risk. 

Another reserve for small unidentified probable losses, that is, plans with less than $5 million in underfunding, and incurred but 

not reported claims, is also recorded based on a commonly-accepted actuarial methodology, called triangulation. 
Page 6 GAO-05-991R Private Pensions 

settlement with the sponsor to fund and retain the plan or termination risk is otherwise reduced.10 If the 

plan does not terminate, and PBGC continues to consider the plan as probable, the plan remains on the 

list. If a plan is progressing toward termination, PBGC closely monitors the bankruptcy proceedings (if 

the sponsor is in bankruptcy) for PBGC claims determinations and also monitors the criteria for distress 

termination and PBGC-initiated termination. If the plan terminates, PBGC removes the plan from its list 

of probable claims and adjusts the previously recorded loss to reflect the actual loss on the date of plan 

terminations. 

The majority of plans spend less than a year on PBGC’s probable claims list. Between 1995 and 2004, 

PBGC added 223 plans to its probable claims list. As of September 30, 2004, 171 of these plans were 

removed from the list within 1 year after they were added for various reasons, including termination and 

deletion. Of those plans not removed from the list in the year added, the majority of plans spend only 1 

additional year on the list. As shown in table 2, of the 223 plans added to PBGC’s list, 52 of these plans 

were on PBGC’s list 1 year later, 15 of these plans were on PBGC’s list 2 years later, and only 3 plans 

were on PBGC’s list 3 years later. Only 3 plans have been PBGC’s list 4 years or longer. 

Table 2: Duration of Plans Newly Classified as Probable from Fiscal Years 1995-2004 

Fiscal 

Year 

Plans Added 

to Probables 

List 

Plans on 

List 1 

Year 

Later 

Plans on 

List 2 

Years 

Later 

Plans on 

List 3 

Years 

Later 

Plans on 

List 4 

Years 

Later 

Plans on 

List 5 

Years 

Later 

Plans on 

List 6 

Years 

Later 

Number of 

Plans Still 

on List 

1995 15 8 3 3 3 2 2 -

1996 16 6 3 0 0 0 0 -

1997 12 3 1 0 0 0 0 -

1998 15 5 2 0 0 0 0 -

1999 14 3 3 0 0 0 - -

2000 1 0 0 0 0 - - -

2001 16 3 1 0 - - - -

2002 38 15 2 - - - - 2

2003 62 9 - - - - - 9

2004 34 - - - - - - 34 

Totals 223 52 15 3 3 2 2 45

Source: PBGC. 

* Includes probables balance at 9/30/1994 of $1,166 million and the net change to large unidentified and small unidentified reserves during the 

ten year period of $184 million. 

Of the 223 plans added to PBGC’s probable list since fiscal year 1995, 187 were either terminated or 

deleted from the list by September 30, 2004—45 plans remain on the list, only 11 of which were added 

prior to fiscal year 2004. As shown in table 3, of the 223 plans, 136 were eventually terminated, and 42 

were deleted for reasons other than termination, representing a $10,536 million loss to PBGC for 

terminated plans and $718 million was reversed for deleted plans. For example, 5 plans of one financially 

troubled company were included as probables in FY 2003. Through negotiations, the company 

subsequently agreed to continue to fund 4 of the plans and terminate only 1. As a result all five plans 

 

10Plans may be reclassified as reasonably possible or remote, in which case they would be deleted from PBGC’s probable list. 
Page 7 GAO-05-991R Private Pensions 

were removed from the probables list--one through termination and four by moving to the reasonably 

possible list. 

Table 3: Duration of Plans Classified as Probable from Fiscal Years 1995-2004 

Fiscal Year 

Plans Added

 to Probables List 

Number of Plans 

Eventually Terminated 

Number of Plans 

Eventually Deleted 

Number of Plans 

Still on List 

1995 15 11 4 - 

1996 16 9 7 - 

1997 12 8 4 - 

1998 15 11 4 - 

1999 14 10 4 - 

2000 1 1 0 - 

2001 16 16 0 - 

2002 38 26 10 2 

2003 62 44 9 9 

2004 34 - - 34 

Totals 223 136 42 45

Total Dollars 

(in millions) $28,180* $10,536 $718 $16,926

Source: PBGC 

Note: includes probables balance at 9/30/1994 of $1,186 million and the net change to large unidentified and small unidentified reserves 

during the ten year period of $184 million. 

As shown in table 4, from fiscal year 1995 to 2004, PBGC had up to 19 plans remain on its probable 

claims list from a previous year. The distribution of plans added to PBGC’s probable claims list varied 

during that time from 1 plan to as many as 62 plans added to the list in a given year. Since fiscal year 

2002, the number of plans added to the probable claims list each year has more than doubled the average 

from the previous years of 1995 through 2001. 

Table 4: Plans Newly Classified as Probable and Total Plans Classified as Probable from Fiscal Years 1995-2004 

Fiscal 

Year 

Plans 

Remaining on Probables

 List from Previous Year

Plans Newly Added 

 to Probables List 

Total

 Number of Plans

 on Probables List

1995 19 15 34

1996 11 16 27

1997 11 12 23

1998 11 15 26

1999 11 14 25

2000 9 1 10

2001 5 16 21

2002 3 38 41

2003 16 62 78

2004 11 34 45

Source: PBGC 
Page 8 GAO-05-991R Private Pensions 

PBGC cites the deteriorating financial position of a number of PBGC-insured plans and the companies 

that sponsor them as a primary reason for the increase in claims for probable terminations. GAO has 

previously reported on this and other structural problems facing PBGC’s single-employer program.11 

Risks that threaten the long-term viability of the program include: a general downturn in economic 

conditions resulting in recent deficits, a concentration of plan underfunding in financially challenged 

industries as well as a premium structure that does not adequately reflect risk. In addition, the current 

funding rules and other pension regulations have not kept some plans from becoming severely 

underfunded and subsequently terminating with large claims placed on the PBGC. 

5. When PBGC takes over a plan, it typically issues a press release discussing the liability PBGC 

expects to incur. Often media sources appear to indicate that the entire amount represents a 

worsening of PBGC’s financial condition. Why does PBGC not disclose in its press releases the 

amount of the liability that the PBGC had already booked? 

According to PBGC officials, the agency does not release the amount of its previously-booked claims in 

its press releases for fear of compromising PBGC’s position in litigation and of negatively affecting a 

company’s financial condition. These officials said that releasing its previously-booked claim amounts 

would enable someone to make a comparison between PBGC’s booked liability for a particular plan and 

the amount of underfunding for that plan. Publicizing this information could affect PBGC’s ability to 

recover the full amount of a plan’s claims in litigation because companies would resist a settlement with 

PBGC for more than the amount of PBGC’s previously-booked losses. Another consideration is that this 

information could also have a negative impact on a company’s ability to obtain additional financing and 

could worsen its financial condition. Although releasing this information to the public would help 

interested parties understand the potential impact, if any, on PBGC’s net financial position with regard 

to particular plans mentioned in PBGC’s press releases, officials believe that the potential adverse 

impact on PBGC and affected companies has outweighed this potential benefit. PBGC officials have 

stated that they are reviewing this policy. 

6. For each plan that PBGC took over and discussed in a press release during 2004 and 2005, what 

was the liability that PBGC announced and how much of that liability had already been booked? 

During fiscal years 2004 and 2005, PBGC issued press releases for several large financially troubled 

pension plans that it had taken over. As shown in table 5, the liability amounts listed in PBGC’s press 

releases differ from the amounts of its previously-booked claims. PBGC officials said that the difference 

in the amounts of their previously-booked claims and the claim amounts listed in their press releases 

reflects the preliminary nature of the data used to determine their booked losses and the assumptions 

used to value liabilities at that time.12 Once the final data are available, PBGC officials stated they 

recalculate the plan’s liability amounts and make the proper adjustments to reflect the actual loss 

incurred at the date of plan terminations. From fiscal years 2004 and 2005, in all but three cases, PBGC’s 

previously-booked claim amounts for plans exceeded the claim amounts listed in the press releases that 

PBGC issued when it took over a plan. 

 

11See GAO, Pension Benefit Guaranty Corporation: Single-Employer Pension Insurance Program Faces Significant LongTerm Risks, GAO-04-90 (Washington, D.C.: Oct. 29, 2003); Private Pensions: Recent Experiences of Large Defined Benefit 

Plans Illustrate Weaknesses in Funding Rules, GAO-05-294 (Washington, D.C.: May 31, 2005); Private Pensions: Revision of 

Defined Benefit Pension Plan Funding Rules Is an Essential Component of Comprehensive Pension Reform, GAO-05-794T 

(Washington, D.C.: June 7, 2005); and Private Pensions: The Pension Benefit Guaranty Corporation and Long-Term 

Budgetary Challenges, GAO-05-772T (Washington, D.C.: June 9, 2005). 

12PBGC officials noted that the net claim amount previously booked will be adjusted in future accounting periods based on new 

information (e.g., plan asset data or participant data) 
Page 9 GAO-05-991R Private Pensions 

Table 5: Comparison of PBGC’s Expected Claims and Claims Announced in its Press Releases 

(Dollars in millions) 

Plan Name Amount of Claims

Claims Amount

 in Press Release 

Fiscal Year 2005 (as of June 30, 2005) 

Penn Traffic Co. $136 $125

United Airlines Ground Employees $2,571 $2,100

United Airlines Pilots Pension Plan $1,437 $1,400 

US Airways Inc. $2,174 $2,300

Fiscal Year 2004 

Cone Mills Corp. $27 $43 

Fansteel Inc. $23 $19

Fleming Companies Inc. $348 $358 

Fruehauf Trailer Corp. Pensions $14 $7

Horizon Natural Resources Co. $87 $75 

Ingersoll International Inc. $64 $48 

JA Jones Inc. $112 $104 

Kaiser Aluminum Inactive Pension 

Plan $56 $47 

Kaiser Aluminum Pension Plan $296 $262 

Lumbermens Mutual $565 $529

Piccadilly Cafeterias Inc. $65 $51 

Sound Shore Medical Center of 

Westchester $45 $38

Top-Flite Golf Co. $39 $30

Source: GAO analysis of PBGC data. 

Note: This table includes claims information regarding only those plans that PBGC has both issued a press release for and has previouslybooked an expected claim amount for during fiscal years 2004 and 2005. 

Agency Comments 

We provided a draft of this report to the Pension Benefit Guaranty Corporation, the Department of Labor 

(DOL), and the Department of Treasury (Treasury) for review and comment. We received written 

comments from PBGC that are reprinted in the enclosure. As stated in our report, PBGC’s letter 

emphasized that PBGC follows FAS No. 5. In addition, PBGC‘s letter emphasized that its financial 

statement auditors have regularly issued opinions stating that PBGC practices are in accordance with 

GAAP. PBGC also provided technical comments on the draft, which we incorporated as appropriate. 

DOL and Treasury did not provide any comments on the draft. 
Page 10 GAO-05-991R Private Pensions 

If you have any questions concerning this letter, please contact me at (202) 512-7215 or Tamara Cross, 

Assistant Director at (202) 512-4890. Joseph Applebaum, Diana Brauner, David Eisenstadt, Charles Ford, 

Mark Glickman, Raun Lazier, and Roger Thomas also made major contributions to this correspondence. 

Barbara D. Bovbjerg 

Director, Education, Workforce, 

and Income Security Issues 

Enclosure 
Enclosure 

Page 11 GAO-05-991R Private Pensions 

Comments From the Pension Benefit Guaranty Corporation

(130519)