United States Government Accountability Office

Washington, DC 20548 

 

May 18, 2007

The Honorable Max Baucus 

Chairman 

The Honorable Charles E. Grassley 

Ranking Member 

Committee on Finance 

United States Senate 

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Member 

Committee on Health, Education, Labor and Pensions 

United States Senate 

Subject: PBGC's Legal Support: Improvements Needed to Eliminate Confusion and Ensure 

Provision of Consistent Advice 

The Pension Benefit Guaranty Corporation (PBGC) insures the pensions of nearly 44 million 

private sector workers in over 30,000 employer-sponsored defined benefit pension plans.1

Established in 1974 as a self-financing government corporation, PBGC’s primary responsibility 

is to insure, under statutory limits, the pension benefits of participants in covered private 

defined benefit plans. PBGC collects premiums from the sponsors of defined benefit pension 

plans and administers plans that are terminated for reasons such as plan insolvency or 

bankruptcy. In the event of a termination, PBGC assumes control of plan assets, determines 

plan benefit liabilities, and pays benefits as guaranteed by statute. In fiscal year 2006, about 

612,000 plan participants and beneficiaries received $4.1 billion in benefit payments from PBGC. 

An additional 659,000 participants in plans already trusteed by the corporation will receive 

benefits from PBGC when they become eligible to retire. An increase in underfunded plan 

terminations in recent years increased the number of plan participants receiving and eligible for 

benefit payments. 

Until recently, all of PBGC’s attorneys worked in the Office of the General Counsel. The General 

Counsel reports to the Director2

 and until recently had responsibility for all legal matters, from 

representing PBGC in bankruptcy and litigation matters, to providing advice on personnel and 

 1

Defined benefit plans pay specific retirement benefits, generally based on years of service or earnings or both; the sponsoring

company is responsible for ensuring that plan assets are sufficient to pay liabilities. 

2

Until recently, the PBGC was headed by an Executive Director, but the Pension Protection Act of 2006 changed the title to

Director and provided for appointment by the President with the advice and consent of the Senate. Pub. L. No. 109-280, § 411(a), 

120 Stat. 780, 935 (to be codified at 29 U.S.C. § 1302(a)). Throughout this letter, we use the term Director. 

Page 1 GAO-07-757R Reorganization of PBGC’s OGC
procurement law. In 2005, PBGC reorganized, creating an additional legal department called the 

Office of the Chief Counsel, and placed this new office under the Chief Insurance Program 

Officer. The Chief Counsel was given the responsibility for overseeing legal issues pertaining to 

PBGC’s core mission functions, such as negotiations involving terminations resulting from 

bankruptcies, while the General Counsel retained responsibility for such general law issues as 

ethics, procurement, and personnel law.3

 

The former Director responsible for the reorganization told us that the new legal structure was 

meant to align the staff performing PBGC’s core mission-related work with the legal staff 

supporting that work. It was also meant to provide additional advancement opportunities for 

attorneys. Concerns have been raised, however, that this organizational change, a 

decentralization of legal functions, has affected the uniformity of PBGC’s legal opinions, 

because there is no single chief legal officer ultimately responsible for overseeing all 

programmatic or regulatory issues. Because of these concerns, and in light of PBGC’s growing 

workload, you asked us to examine the effect the reorganization of the corporation’s legal 

functions into separate offices has had on PBGC’s operations. Accordingly, we assessed 

whether the reorganization has (1) clearly defined the roles and responsibilities of PBGC’s legal 

offices and (2) ensured that consistent legal advice is provided to the PBGC Director. 

We reviewed PBGC’s current organizational structure, including its different legal components, 

such as the Office of the General Counsel and the Office of the Chief Counsel. To assess the 

effect the reorganization has had on the provision of legal services at PBGC, we reviewed PBGC 

memorandums and documents concerning the reorganization and interviewed the former 

Director who implemented these changes and the current and former general counsels and 

chief counsels. We also interviewed representatives from PBGC’s union and several other 

management officials. Because PBGC officials said that its new legal structure was modeled 

after that of the Securities and Exchange Commission (SEC), we reviewed SEC documentation 

and spoke to an SEC official about that agency’s organizational structure. We conducted our 

review from November 2006 through April 2007 in accordance with generally accepted 

government auditing standards. We provided a draft of this letter to the Department of Labor 

and the PBGC for comment. 

In summary, the restructuring of PBGC’s legal functions into separate offices has caused 

confusion over each office’s authority. As a result, PBGC staff has sought advice from both the 

Office of the General Counsel and the Office of the Chief Counsel, sometimes in an effort to

obtain a desired response. Further, PBGC officials told us that attorneys from the Office of the 

General Counsel have provided legal advice when the Office of the Chief Counsel had 

responsibility for the issue, which resulted in confusion and conflicting opinions. 

PBGC’s current legal structure does not guarantee that a chief legal officer has an opportunity 

to provide advice and views on legal matters, including those reaching the Director. Currently, 

the Chief Counsel does not have a reporting relationship to either the General Counsel or the 

Director. In an August 2006 report on a multimillion dollar business transaction, the Inspector 

 

3

In addition to the Office of the Chief Counsel, the reorganization created another legal office, called the Legislative and 

Regulatory Department, to monitor and provide legal advice on, and analysis and drafting of legislative proposals and 

regulations related to PBGC's mission.

Page 2 GAO-07-757R Reorganization of PBGC’s OGC
General found that PBGC put itself at risk because the General Counsel was not informed and 

did not serve its function as a check on critical issues. When an organization implements a 

decentralized legal structure, all counsel housed in specific business units typically report 

administratively to a chief legal officer, such as a general counsel, who in turn reports directly 

to the agency head. 

This letter contains a recommendation to PBGC to provide for all legal functions to be overseen 

by a single chief legal officer who reports directly to the Director. In commenting on a draft of 

this letter, PBGC disagreed with our recommendation, stating that a recommendation to adopt a 

single law office model was unduly prescriptive. We did not intend for our recommendation to 

be read narrowly as endorsing a single law office model. Rather than endorsing a particular 

legal structure, we point out that the legal functions could be organized in different ways, and 

this could include a decentralized structure. PBGC also expressed concern that our report did 

not sufficiently recognize the improved communication, coordination, reporting processes and 

changes to its corporate culture that it has undertaken. After carefully reviewing its concerns, 

we continue to believe that our conclusions and recommendation are well founded. PBGC’s 

comments are provided in appendix I. We did not receive formal comments from the 

Department of Labor however, both PBGC and the Department of Labor provided technical 

comments and clarifications, which we incorporated in the letter as appropriate. 

Background 

PBGC collects premiums from the sponsors of defined benefit pension plans, oversees plan 

terminations, and ensures the proper disbursement of payments. The corporation charges 

premiums to defined benefit plan sponsors, so it may make insured benefit payments to 

participants in defined benefit pension plans that terminate with insufficient assets. Under 

certain circumstances, PBGC can determine that the termination of an employer’s plan is 

necessary to protect the interests of plan participants or of PBGC‘s insurance program, for

example, if a plan does not have enough money to pay benefits currently due. In such cases 

PBGC negotiates with the plan sponsor to terminate the plan and is routinely appointed its 

permanent trustee. The negotiations are often fast-paced, high-pressure situations that 

increasingly involve large corporations and millions of dollars. PBGC’s Department of 

Insurance Supervision and Compliance (DISC) staff, who manage the negotiations, have 

extensive financial, actuarial, and market expertise. DISC’s legal support comes from the Office 

of Chief Counsel, whose staff has extensive knowledge of bankruptcy and pension law. 

The Office of the Chief Insurance Program Officer, as shown in figure 1, manages the Office of 

the Chief Counsel and DISC. DISC monitors the corporate events and transactions of defined 

benefit pension plan sponsors and provides the necessary analyses to enable PBGC to assess its 

insurance program. In coordination with the Office of the Chief Counsel, DISC determines and 

pursues recoveries of unpaid employer contributions. DISC also makes recommendations to the 

Director concerning the filing of liens and makes recommendations to the Internal Revenue 

Service concerning conditions for granting employers waivers of the minimum funding 

requirements, which are the minimum amount of assets an employer’s defined benefit plan

must hold in order to fund promised benefits. Neither office reports to or through the Office of 

the General Counsel. 

Page 3 GAO-07-757R Reorganization of PBGC’s OGC
Figure 1: PBGC’s Organizational Chart 

The Office of the Chief Counsel provides comprehensive legal services relating to PBGC's

programs involving ongoing and terminated pension plans. Its attorneys represent PBGC in

bankruptcy or insolvency proceedings, provide legal advice and services to support termination 

negotiations and settlements, and make recommendations concerning the initiation of litigation. 

Currently, the Office of the Chief Counsel has 50 attorneys. 

Since the reorganization, the Office of the General Counsel consists primarily of attorneys who 

had previously worked in the general law area and are tasked with functions related to ethics, 

procurement, and personnel law. According to PBGC documents, the Office of the General 

Counsel provides the Director and PBGC departments with legal advice and counsel on general 

law issues and can provide advice on pension-law matters at the request of the Director. The 

Office of the General Counsel is also responsible for deciding administrative appeals of PBGC 

decisions concerning benefit coverage and other determinations. Further, the General Counsel 

Page 4 GAO-07-757R Reorganization of PBGC’s OGC
serves as Secretary to the PBGC’s board of directors and keeps board meeting minutes.4

 The 

office currently has 27 attorneys.5

Restructuring Has Resulted in Confusion over Legal Roles and Responsibilities 

The restructuring of PBGC’s legal functions has caused confusion within the corporation over 

each office’s authority. As a result, PBGC staff has sought advice from both the Office of the 

General Counsel and the Office of the Chief Counsel, on the same or substantially similar 

issues, sometimes in an effort to obtain a desired response. In addition, PBGC officials told us 

that attorneys from both legal offices often provide legal advice on the same issues, which has 

resulted in confusion. For example, early in 2006, PBGC’s Chief Financial Officer sent a memo 

to both offices requesting advice on an issue involving bankruptcy, and each office rendered a 

separate legal opinion. According to PBGC, the Office of Chief Counsel has responsibility for 

providing legal advice on issues involving bankruptcy matters, and the Office of the General 

Counsel has responsibility for providing legal services to the Financial Operations Department. 

While the legal conclusions of the two memos can be read in concert, the Chief Counsel’s memo 

appears to reflect some level of disagreement with the General Counsel’s approach to the issue 

raised. In another case, involving advice on a benefits issue concerning a specific pension plan, 

even though the Office of the Chief Counsel is generally responsible for providing legal advice 

to the Benefits Administration and Payments Department, both legal offices wrote memos to 

this department, presenting legal opinions that were in disagreement. After internal discussions 

among senior management, PBGC officers followed the advice presented by the Office of the 

General Counsel. 

Confusion over roles and responsibilities has led to problems for those outside of PBGC as well. 

In some cases, external clients, such as employers that sponsor defined benefit plans, have 

experienced delays in receiving advice because they mistakenly sent their legal queries to the 

Office of the General Counsel rather than the Office of the Chief Counsel. For example, 

according to a PBGC official, an outside attorney contacted the Office of the General Counsel 

seeking guidance on a transaction and was told to submit a written request for a legal opinion. 

PBGC officials later agreed that the inquiry should have been sent to the Chief Counsel’s office. 

Determining internal jurisdiction delayed by about a month PBGC’s analysis of the transaction 

and its guidance. In another example, the General Counsel’s office was asked for advice 

regarding a plan that was seeking relief from its premium payments. An attorney from the 

Office of the General Counsel drafted a letter that would have allowed for such relief. The 

letter, had it been approved, would have permitted PBGC staff to stop collecting premiums 

from the specific plan sponsor, indicating that PBGC did not cover the plan. However, the Chief 

Counsel’s office disagreed with the Office of the General Counsel’s position, and found that 

PBGC did cover the plan. According to a PBGC official, if the plan sponsor had stopped paying 

premiums to PBGC, the law would still require PBGC to guarantee benefits if the plan 

terminated with insufficient assets. 

 4

29 C.F.R. § 4002.6 (2006). 

5

The Legislative and Regulatory Department currently has 11 attorneys. 

Page 5 GAO-07-757R Reorganization of PBGC’s OGC
In an attempt to clarify the roles and responsibilities of the two legal offices, PBGC’s Interim 

Director issued a memorandum in January 2007 discussing certain areas of jurisdiction that 

were not clearly addressed in the reorganization. To a certain extent, the memo heightened the 

confusion because, according to some PBGC officials, the memorandum reassigned certain 

functions previously understood to be within the scope of the Office of the Chief Counsel to the 

General Counsel’s office. For example, although benefit determinations are made based on legal 

advice provided by the Office of the Chief Counsel, the responsibility for deciding appeals of 

benefit determinations has been given to the Office of the General Counsel. The memorandum 

states that the Office of the General Counsel is responsible for leading litigation arising from 

such an appeal. This is in conflict with PBGC documents that state that the Office of the Chief 

Counsel will represent PBGC in litigation in all courts when the issue involves ongoing and 

terminated pension plans. PBGC union representatives also asserted that the memorandum was 

not consistent with the union-negotiated reorganization agreements with PBGC management. 

According to the union representatives, the reorganization agreements state that the Office of 

the Chief Counsel will consist of the group that had previously been responsible for litigating 

fiduciary breach and Appeals Board cases in the pre-reorganization Office of the General 

Counsel and do not mention transferring these functions, or any others, to the postreorganization Office of the General Counsel. PBGC management disagreed with the union’s 

views on the Interim Director’s memorandum, and told us that PBGC has not yet finalized how 

the issues discussed in the memorandum will be implemented. 

Although officials at PBGC have acknowledged that there was confusion during the initial 

period of reorganization, they have also indicated that communication and collaboration among 

attorneys and clients has improved, and stated that the potential for future confusion is low. 

They explained that in response to the Interim Director’s memorandum, PBGC’s two legal 

offices now participate in biweekly meetings, to coordinate the matters his memo addressed. 

According to the officials, these meetings have enhanced collaboration. 

Current Structure Does Not Ensure That Advice of a Chief Legal Officer is Provided 

on Significant Legal Issues 

PBGC’s legal structure does not guarantee that a chief legal officer has an opportunity to 

provide advice on significant legal matters, including those reaching the Director. Organizations 

that implement a decentralized legal structure—by having all legal advice from counsel housed 

in specific business units pass through a chief legal officer, such as a general counsel, reporting 

directly to the agency head—can ensure that only legal advice that is backed by the chief legal 

officer reaches the agency head. However, PBGC’s current legal structure fails to give the Office 

of the Chief Counsel an independent reporting line to either the General Counsel or the 

Director. In a 2006 survey of 186 large private-sector corporations, 154 corporations reported 

having attorneys that were organized in a centralized structure. Eighty-nine percent of these 

corporations reported that between “76 and 100 percent” of their attorneys report directly to a 

general counsel. In addition, 19 corporations reported having attorneys who were organized in a 

decentralized structure. The attorneys report directly to the head of their business units, with 

Page 6 GAO-07-757R Reorganization of PBGC’s OGC
an indirect reporting relationship to a general counsel.6

 An entity’s general counsel commonly 

reports directly to the chief executive officer within the management hierarchy. 

The Chief Counsel reports to the Chief Insurance Program Officer, a position that also has 

responsibility for the high-pressure negotiations conducted by DISC. Given the high value and 

risk of these negotiations, an independent legal voice is important. PBGC officials told us that 

the lack of a direct-reporting line is remedied because legal questions can be discussed in the 

executive management forum, which includes the Chief Insurance Program Officer, the 

Director, and the General Counsel. However, legal issues raised by the Office of the Chief 

Counsel may not reach the Executive Management forum, if the Chief Insurance Program 

Officer does not elevate them to that forum. The Chief Insurance Program Officer could be 

faced with competing priorities. On the one hand, this official has staff negotiating highpressure deals. On the other hand, this official has attorneys responsible for ensuring that the 

deals are legally sound. Under pressure to close the deal, the potential exists for this executive 

to make a decision or take an action without airing an important legal concern before the 

General Counsel or the Director. However, PBGC officials noted that the current Chief 

Insurance Program Officer is an attorney with the necessary expertise to manage the Office of 

the Chief Counsel effectively. They also noted that the position of the Chief Insurance Program 

Officer may not always be held by someone with legal qualifications. 

While PBGC documentation requires the General Counsel to review important transactions, this 

review does not always occur, which may put the corporation at risk. For example, in an August 

2006 report, PBGC’s Office of Inspector General found that the Office of the General Counsel 

had not been substantively involved in a multimillion dollar business transaction, even though 

PBGC documentation requires that the General Counsel review relevant proposed actions 

requiring approval of the Director. If, during the fast pace of decision making in negotiations, 

the Office of the General Counsel does not review important transactions, gaps in responsibility 

and accountability can occur. For example, an organization’s General Counsel can help ensure 

that attorneys in the business units maintain their professional independence while providing 

specialized legal services.7

 Under the current legal structure, the Office of the General Counsel 

cannot realistically be integrally involved in every aspect of negotiations, and there may be 

times when the Office of the General Counsel is not aware of an issue that can result in damage 

to the PBGC. The Inspector General found that PBGC put itself at risk because the General 

Counsel was not informed, and did not serve its function as a check on critical issues facing

PBGC. 

According to PBGC officials, the corporation refined its practices after this transaction and the 

report by the Office of Inspector General, and began coordinating better in a variety of areas. 

For example, the Interim Director implemented biweekly meetings on major cases, at which 

key senior staff are alerted to major developments that may require their input. According to 

PBGC officials, during a subsequent transaction, there was improved cooperation across all 

 6

The Hildebrandt 2006 Law Department survey was conducted by Hildebrandt International, a professional services consulting 

firm. Its benchmarking survey provides information on legal spending, staffing, management, and compensation. The median 

company in its survey is one with approximately $8 billion in worldwide revenues, 20,000 worldwide employees, and a U.S. law 

department with over 20 lawyers and 40 total staff. 

7

E. Norman Veasey, and Christine T. Di Guglielmo, “The Tensions, Stresses, and Professional Responsibilities of the Lawyer for 

the Corporation,” The Business Lawyer (Vol. 62, Nov. 2006). 

Page 7 GAO-07-757R Reorganization of PBGC’s OGC
department lines that, according to the officials, resulted from the implementation of these 

meetings. 

The former Director, responsible for the reorganization, told us that the new legal structure is 

modeled on that of the SEC. At SEC, there is an Office of the General Counsel that reports to 

the SEC Chairman. There are also several Chief Counsels who are embedded in the various 

business units, and they report directly to the department heads—not necessarily the General 

Counsel. However, according to an SEC official, it is agency practice that the Chief Counsels’ 

most important actions are reviewed by the Office of the General Counsel. In addition, the

official also told us that the heads of the majority of SEC’s business units are required to be 

filled by attorneys, whereas at PBGC the Chief Insurance Program Officer position, although 

currently filled by an attorney, is a general management position. 

Conclusions 

The current organization of PBGC’s legal functions lacks a clear division of authority and does 

not ensure that the Director receives legal advice directly and with the full support of a chief 

legal officer. Currently, there are two distinct legal offices within PBGC, but there is no single 

legal voice. The current structure creates confusion for PBGC both internally and externally, 

which could seriously affect PBGC’s mission. While PBGC’s legal functions could be organized 

in different ways, we believe that the lack of a direct reporting line from the Chief Counsel to 

the General Counsel or the Director could result in decisions made without consideration of 

PBGC’s overarching legal concerns. In short, the current legal structure has resulted in various 

problems and has the potential to create additional problems in the future. Therefore, this 

matter deserves prompt attention to eliminate such problems. 

Recommendation for Executive Action 

In order to promote clear lines of authority and the provision of consistent legal advice, we 

recommend that PBGC 

• provide for all legal functions to be overseen by a single chief legal officer with full 

authority to delineate the duties of each legal office and a direct reporting relationship to 

the Director. 

Agency Comments and Our Evaluation 

We provided copies of a draft of this letter to the Secretary of Labor and PBGC’s Interim 

Director for their comments. The Department of Labor provided technical comments which we 

incorporated in our final letter as appropriate. PBGC provided written comments which are 

reproduced in appendix I. In its comments, PBGC stated that it disagrees with our 

recommendation, which it characterizes as an unduly prescriptive recommendation that it 

adopt a single law office model. We did not intend for our recommendation to be read narrowly 

as endorsing a single law office model. Rather than endorsing a particular legal structure, we 

point out that the legal functions could be organized in different ways, and this could include a 

decentralized structure. We recommended, and continue to believe, however, that in 

determining the most appropriate structure for providing legal support, PBGC should ensure 

that all legal functions are overseen by a single chief legal officer with authority and 

accountability for all legal advice provided to the Director and the various departments within 

Page 8 GAO-07-757R Reorganization of PBGC’s OGC
PBGC. Without a single chief legal officer, we believe that the inconsistency and confusion that 

we documented in the report are likely to continue. Indeed, our recommendation is consistent 

with the views of four former General Counsels of the PBGC. We interviewed these individuals, 

with a combined 28 years of service as General Counsel, and each of them independently stated 

that having a chief legal officer oversee PBGC’s attorneys is the best approach for the 

corporation. 

PBGC also expressed concern that our report did not sufficiently recognize the improved 

communication, coordination, reporting processes and changes to its corporate culture that it 

has undertaken. While we have modified the report to include these stated changes, we point 

out that, during our five month review we saw little evidence of such change. We believe that 

the new biweekly meetings implemented by the Interim Director are a step in the right 

direction, and involving the General Counsel in the oversight of major agency decisions is 

consistent with our recommendation. However, relying solely on improved cooperation and 

communication is not an adequate approach for improving a flawed organizational structure. 

In addition to its written comments, PBGC also noted several technical corrections to the letter, 

which we incorporated as appropriate. 

- - - - - 

As arranged with your offices, unless you publicly announce its contents earlier, we plan no 

further distribution of this letter until 30 days after the date of the letter. At that time, we will 

send copies of this letter to the Secretary of Labor, the Interim Director at PBGC, and other 

interested parties. We will also make copies available to others on request. In addition, the 

letter will be available at no charge on GAO’s Web site at http://www.gao.gov. 

If you or your staff have any questions about this letter, please contact me at (202) 512-7215 or 

bovbjergb@gao.gov. Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this letter. Other key contributors to this letter were 

Blake Ainsworth, Assistant Director; Monika Gomez; Jason Holsclaw; Kisha Clark; and Craig 

Winslow. 

Sincerely yours, 

Barbara D. Bovbjerg 

Director, Education, Workforce, and 

 Income Security Issues

Page 9 GAO-07-757R Reorganization of PBGC’s OGC
Appendix I: Comments from the Pension Benefits Guaranty Corporation 

Appendix I: Comments from the Pension Benefits Guaranty Corporation 

Page 10 GAO-07-757R Reorganization of PBGC’s OGC 
Appendix I: Comments from the Pension Benefits Guaranty Corporation 

Page 11 GAO-07-757R Reorganization of PBGC’s OGC 
Appendix I: Comments from the Pension Benefits Guaranty Corporation 

(130647) 

Page 12 GAO-07-757R Reorganization of PBGC’s OGC 
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