Pension Benefit Guaranty Corporation: Improvements Needed to Strengthen Governance Structure and Strategic Management
Published: 2010-12-01T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Pension Benefit Guaranty Corporation (PBGC) is a self-financing government corporation that insures the pensions of 44 million workers in more than 27,000 private sector defined benefit pension plans. Yet, PBGC faces financial instability that could pose a future threat to this source of protection for Americans' retirement income. As fewer sponsors pay premiums for fewer participants in defined benefit plans, and as the underfunding of large defined benefit plans increases, the risks to PBGC's financial future also increase. As of September 2010, PBGC's net accumulated financial deficit was $23 billion. GAO has designated PBGC and the pension insurance programs it administers as "high risk" areas in need of urgent attention and transformation to address economy, efficiency, or effectiveness changes. In this testimony, GAO discusses its recent work regarding PBGC. Specifically, this statement focuses on needed improvements to PBGC's governance structure and strategic management based on GAO's prior work in these areas. GAO is making no new recommendations in this statement, but continues to believe that Congress should consider expanding PBGC's board of directors and that PBGC should implement recommendations from prior reports that have not yet been implemented, such as those concerning strategic workforce management and benefit determination process performance measures for large, complex plans.
section_title: What GAO Found
paragraphs: PBGC requires a strong governance structure and strategic management to ensure that it can meet its future financial challenges. Companies who pay annual premiums to PBGC and the millions of employees whose retirement benefits are under PBGC's protection are owed greater stewardship of the corporation and its funds. By law, PBGC is governed by a three-member board of directors composed of the Secretaries of the Treasury, Commerce, and Labor. Because of their numerous responsibilities in their roles as cabinet-level secretaries, the board members have historically been unable to dedicate consistent attention to PBGC matters. In fact, since 1980, the board has met only 23 times. During a critical 2-year period between February 2008 and February 2010, amid turbulent economic times and congressional investigations of certain procurement practices, the board did not meet at all. While the current PBGC board is meeting more frequently than in prior years, its members still have little time to devote to PBGC governance and the board remains vulnerable to disruptive transitions during future changes of administration. In addition, although PBGC management has taken steps in recent years to strengthen its operations, recommendations from GAO's prior work concerning how the corporation could improve its strategic workforce management and the benefit determination process have yet to be fully implemented. PBGC's contract workers comprise about two-thirds of its workforce, yet GAO found that workforce management lacked a strategic approach for determining the mix of contract and federal workers, and PBGC did not include procurement decision making in corporate-level strategic planning. Also, GAO found that management of PBGC's benefit determination process did not provide for separate reporting of performance measures for large, complex plans, yet these plans are responsible for most long delays in processing and most cases with overpayments. Measures that reflect averages across all plans do not provide sufficient incentive to improve the processing of these plans. The need for a more strategic approach in managing both the contract workforce and the benefit determination process is essential to ensure that PBGC is operating efficiently and effectively. Improvements to PBGC's governance and strategic management cannot correct structural weaknesses in its financial design, but it can better position PBGC for the challenges that lie ahead.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the need for improved governance  and strategic management of the Pension Benefit Guaranty Corporation  (PBGC). PBGC operates two pension insurance programs—the single- employer program and multiemployer program—that insure the pensions  of 44 million private sector workers and retirees in more than 27,000  defined benefit pension plans. With the growth in number of large plans  under its trusteeship, PBGC’s responsibilities for administering plans and  managing assets have increased significantly since its creation in 1974, and  its financial portfolio is now one of the largest of any federal government  corporation. While PBGC has sufficient assets to pay retirees promised  benefits in the near future, PBGC has maintained an accumulated financial  deficit for a number of years. In fact, we first designated PBGC’s largest  insurance program—the single-employer program—as “high risk” in 2003  due to PBGC’s prior-year net deficit, as well as the increased likelihood of  large, underfunded pension plan terminations. Since that time, the single- employer program has remained high risk because of its continued deficit  and the structural challenges that pose a risk for future losses. In 2009, we  designated the multiemployer program as high risk as well. At the end of  fiscal year 2010, PBGC’s deficit for both programs combined was  approximately $23 billion.
My statement will focus on steps PBGC could take to help meet the  challenges of its unstable financial condition and increasing workloads.  Specifically, I will discuss PBGC’s need for (1) a stronger board structure  and (2) a more strategic approach to managing its contract workforce and  benefit determination process. My statement is based on our prior work  assessing PBGC’s long term financial prospects, and various reports we  have published over the past several years on PBGC governance and  management. Our prior work was conducted in accordance with generally  accepted government auditing standards. Those standards require that we  plan and perform the audit to obtain sufficient, appropriate evidence to  provide a reasonable basis for our findings and conclusions based on our  audit objectives. We believe that the evidence obtained provides a  reasonable basis for our findings and conclusions based on our audit  objectives.
subsections: section_title: Background
paragraphs: PBGC was created by the Employee Retirement Income Security Act of  1974 (ERISA) to pay benefits to participants in private defined benefit  pension plans in the event that an employer could not. PBGC may pay  benefits up to specified limits, if a plan does not have sufficient assets to  pay promised benefits and the sponsoring company is in financial distress.  As of September 2010, PBGC was paying monthly retirement benefits to  more than 800,000 retirees in about 4,200 terminated pension plans.
PBGC receives no funds from general tax revenues. Instead, the  corporation finances its activities from three main sources of funds: (1)  insurance premiums in amounts set by Congress and paid by defined  benefit plan sponsors, (2) assets acquired from plans that have been  terminated and trusteed by PBGC, and (3) investment income earned on  these assets. Under current law, the corporation has no substantial source  of funds available to it if it were to exhaust its assets, except for the ability  to borrow up to $100 million from the Department of the Treasury. The  United States government is not liable for any obligation or liability  incurred by the corporation.
PBGC’s deficit fluctuates due to various factors, including changes in  interest rates, investment performance, and losses from completed and  probable plan terminations. PBGC’s deficit improved during fiscal year  2008, but then worsened the next year with the severe market downturn.  As of September 2010, PBGC held approximately $79.5 billion in assets  and approximately $102.5 billion in liabilities—for an accumulated deficit  of $23.0 billion, more than double the deficit from 2 years earlier (see fig.  1). This growth in its deficit was due largely to an increase in plan  terminations and a decline in interest rates used to value PBGC’s  liabilities. As a result of these plan terminations, PBGC became directly  responsible for the pensions of more than 200,000 additional participants  in fiscal year 2009, the third highest annual total of new participants in  PBGC’s history. During this time, the corporation trusteed plans of  companies such as Lehman Brothers, IndyMac Bank, Circuit City, Nortel,  and Delphi Corporation. In addition, as of September 2010, PBGC  estimated future losses from underfunded multiemployer plans that are  unable to repay financial assistance provided by PBGC at about $3.0  billion—up from $1.8 billion 2 years earlier.
PBGC currently has sufficient assets to make scheduled benefit payments  for a number of years, given that benefits are paid monthly and spread over  participants’ and beneficiaries’ lifetimes. However, in the long term, PBGC is  likely to remain at financial risk due, in part, to several structural challenges  that limit PBGC’s ability to manage its risk. For example, statutorily  prescribed pension funding requirements specify how much a sponsor must  contribute to its defined benefit plans each year. However, these funding  rules are based on assumptions about future liabilities that may differ from  a plan’s actual payouts of benefits over time. Similarly, PBGC’s premium  structure is specified in law for both single- and multiemployer defined  benefit plans. This structure limits the corporation’s ability to manage its  financial risk because, unlike private insurers, PBGC cannot decline to  provide insurance coverage or adjust premiums in response to actual or  expected claims exposure. Meanwhile, PBGC’s premium base has been  shrinking as the number of defined benefit pension plans and active plan  participants has been declining rapidly. In fiscal year 2010, PBGC insured  about half the number of plans it insured 15 years earlier.
Legislation enacted over the past 5 years has taken steps to address these  concerns, but the extent to which these steps may reduce PBGC’s risk of  future losses is still unknown. For example, the Deficit Reduction Act of  2005 included provisions to raise flat-rate premiums and create a new,  temporary premium for certain terminated single-employer plans. In  addition, the Pension Protection Act of 2006 (PPA) included a number of  provisions aimed at improving plan funding and PBGC finances through  such measures as raising the funding targets defined benefit pension plans  must meet, reducing the period over which sponsors can “smooth”  reported plan assets and liabilities, and restricting sponsors’ ability to  substitute “credit balances” for cash contributions. However, in response  to the recession, Congress enacted legislation in 2008 to help companies  better weather the economic downturn by granting funding relief to  certain sponsors and delaying implementation of certain PPA provisions.  Thus, the overall impact of PPA remains unclear.
PBGC’s insurance programs are in need of urgent congressional attention  and agency action. We first designated the single-employer insurance  program as “high risk” in 2003 after it moved from a $9.7 billion  accumulated surplus in fiscal year 2000 to a $3.6 billion accumulated deficit  in fiscal year 2002. Since that time, the net financial position of PBGC has  significantly worsened due, in part, to the declines in certain industries that  led to PBGC having to assume responsibility for several large underfunded  plans, and to the steep downturn in the financial markets. We added the  high risk designation to the multiemployer program in 2009 in light of the  increased risk of future losses in that program as well. As of September  2010, PBGC’s estimated financial deficit for both programs combined was  $23.0 billion—more than double its deficit from 2 years earlier.
section_title: PBGC’s Board Structure Needs Strengthening
paragraphs: PBGC needs strong policy direction and oversight in the face of its current  financial condition and long-term structural challenges, yet the board’s  structure as established by law limits the board’s ability to provide such  policy direction and oversight. ERISA specified that PBGC is to have a  three-member board of directors consisting of the Secretaries of the  Treasury, Commerce, and Labor. The Secretary of Labor serves as the  Chairman of the Board. The board is required to direct and oversee the  corporation, in part, by approving all policy decisions affecting American  employers and workers as well as reviewing and approving its budget,  strategic plans, and financial performance. Each board member can  designate an official to serve on his or her behalf in most instances. This  designee is referred to as the board member’s “representative.” In addition,  ERISA established an Advisory Committee, whose seven members are  appointed by the President to represent the interests of labor, employers,  and the general public. The committee has an advisory role but has no  statutory authority to set PBGC policy or conduct formal oversight.
Our prior work has highlighted a number of limitations with this statutory  governance structure, starting with the size and composition of the board.  According to corporate governance guidelines published by The  Conference Board, corporate boards should be structured so that the  composition and skill set of a board is linked to the corporation’s  particular challenges and strategic vision, and should include a mix of  knowledge and expertise targeted to the needs of the corporation. We  found that other government corporations’ boards averaged about 7  members, with one having as many as 15 (see table 1). None had a board  as small as PBGC’s. In addition, the size of PBGC’s board also prevents the  members from establishing standing oversight committees, which are  commonly used by both government corporations and private corporate  boards. For example, other government corporations, such as the  Overseas Private Investment Corporation (OPIC) and the Federal Deposit  Insurance Corporation have established standing committees to conduct  oversight of certain functions, such as audits and case file reviews.
PBGC’s governance structure is also vulnerable to disruptive transitions  with each administration change. The board, its representatives, and the  director typically change with each presidential transition, thus limiting  the board’s institutional knowledge of the challenges facing the  corporation. Other government corporations have board structures with  staggered terms for their directors, which arguably avoid gaps in their  organization’s institutional knowledge. For instance, OPIC’s directors may  be appointed for a term of no more than 3 years, and the terms of no more  than 3 of the 15 directors can expire in any given year.
Our prior work has also found that PBGC’s board members often have  limited time and resources to dedicate to PBGC matters given their  numerous other responsibilities in their roles as cabinet secretaries.  According to corporate governance guidelines, boards should meet  regularly and focus principally on broader issues, such as corporate  philosophy and mission, broad policy, strategic management, oversight and  monitoring of management, and company performance against business  plans. However, we found that since PBGC’s inception, the board has met  infrequently, even when pressing strategic and operational issues were at  play. In 2003, after several high-profile pension plan terminations, PBGC’s  board began meeting twice a year (see fig. 2). But PBGC officials have told  us that it is a challenge to find a time when all three cabinet secretaries are  able to meet, and when they do meet, the meetings generally only last about  an hour. The current board has recently begun to meet more frequently,  meeting three times since February 2010. However, prior to that time, the  board had not met since February 2008, despite pending terminations of  several pension plans sponsored by large automakers and congressional  investigations into certain procurement practices.
Because PBGC’s board members have generally been unable to dedicate  consistent attention to PBGC, they have relied on their board  representatives to conduct much of the work on their behalf. The board  also relies on PBGC’s Inspector General and management oversight  committees to ensure that PBGC is operating effectively. However, we  have found that the communications between these entities and the board  may be limited and the board may not always be sufficiently aware of  PBGC’s activities. For example, PBGC’s bylaws require the board to  review any reports that the Inspector General deems appropriate, and the  Inspector General reports to the board through the Chair. However, there  is no formal protocol requiring the Inspector General to routinely meet  with the board of directors or their representatives. Moreover, PBGC’s  oversight committees are not independent of the PBGC director nor  required to formally report all matters to the board. Under this structure, it  remains unclear if the board members would be aware of the Inspector’s  General findings or of significant actions taken by PBGC management.
We have also noted that the PBGC Advisory Committee does not have  formal access to the board members, potentially limiting the board  members’ knowledge of the committees’ concerns and recommendations.  PBGC’s Advisory Committee typically reports only to the director,  although officials said that the committee can submit concerns to the  board if it believes it is warranted. In contrast, the advisory boards or  committees of other government corporations—such as the Federal  Deposit Insurance Corporation and Export-Import Bank—are required to  submit formal reports to their board chair and directors.
To address these weaknesses in PBGC’s governance structure, we believe  that Congress should consider expanding the board of directors to include  additional members with diverse backgrounds who possess knowledge  and expertise useful to PBGC’s mission. PBGC hired a consulting firm to  review governance models and provide a background report to assist the  board in its review of alternative corporate governance structures. While  the report did not advocate any particular governance option, the  consulting firm’s final report corroborated our findings and described the  advantages and disadvantages of governance practices of other  government corporations and selected private sector companies. The  report concluded that there are several viable alternatives for  strengthening PBGC’s governance structure and practices, some of which  are now being put forth in pending legislation.
section_title: PBGC Needs More Strategic Management of Its Contract Workforce and Benefit Determination Process
paragraphs: Although PBGC management has taken steps in recent years to strengthen  its operations, our prior work has identified ways that the corporation  could be more strategic in its management of its contract workforce and  the benefit determination process. The need for a strategic approach in  these areas is essential to ensure that PBGC is operating as efficiently and  effectively as possible to manage its increasing workload.
subsections: section_title: Contract Workforce Management
paragraphs: Since the mid-1980s, PBGC has had contracts covering a wide range of  services, including the administration of terminated plans, payment of  benefits, customer communication, legal assistance, document  management, and information technology. As PBGC’s workload grew in  response to the significant number of large pension plan terminations,  PBGC has come to rely on contractors to supplement its workforce. About  two-thirds of PBGC’s workforce consists of contract workers (see fig. 3).
Over the years, PBGC has taken steps to improve its workforce  management. For example, in response to a recommendation we made in  2000, PBGC agreed to conduct a comprehensive review of its future  human capital needs and to use this review to better link contracting  decisions to PBGC’s long-term strategic planning process. After  commissioning this review, PBGC developed a human capital strategic  plan that called for aligning human capital programs with the  corporations’ strategic goals and mission. However, in 2008, we found that  the corporation still lacked a strategic approach to identifying the optimal  mix of federal versus contract workers and ensuring that the performance  of its contract workforce contributes to the corporation’s mission.
As a matter of general best practice, our 2008 work noted that a strategic  plan should incorporate an understanding of how acquisitions will be used  to assist an agency in achieving its mission. This is especially true of  PBGC with its large contract workforce. Yet, our 2008 work found that  although PBGC had made efforts to improve its acquisition infrastructure,  it had not developed a strategic approach to its contracting process as  envisioned in our 2000 report. Moreover, PBGC’s human capital strategic  plan focused almost exclusively on its federal workforce. We  recommended that the plan do more to reflect the importance of  contracting and to link staffing and contracting decisions at the corporate  level. While PBGC agreed that contracting should be part of its strategic  planning process, it maintained that this is already being achieved by its  current process.
Since our 2008 report, PBGC has implemented new guidance and policies  in a number of areas to improve its management of the contracting  process and contractor oversight. In August 2009, PBGC issued guidelines  for determining whether to use contractors or government employees.  While useful, these procedures do not include any specific steps to ensure  that such decisions are linked to the strategic planning process.  Subsequently, PBGC issued its new human capital strategic plan for fiscal  years 2010-2014. In this plan, PBGC acknowledges the importance of  contracting and the challenges of balancing their workforce between  federal and contract workers, but the plan does not provide specific  actions to address such challenges and appears to continue to focus  primarily on PBGC’s federal workers.
Our previous reports also found weaknesses in PBGC’s efforts to ensure  that the performance of its contract workforce contributes to the  corporation’s mission. In 2000, and again in 2008, we found that most of  PBGC’s contracts lacked performance incentives and methods to hold  contractors accountable for performance outcomes linked to the  corporation’s strategic goals. In 2000, we recommended that, where  appropriate, PBGC should utilize more fixed-price contracts and fewer  labor-hour payment arrangements, consistent with best practices in  performance-based contracting. In 2008, we recommended that to improve  implementation of a performance-based approach to contracting, PBGC  should ensure that future contracts measure performance in terms of  outcomes, provide incentives for the accomplishment of desired  outcomes, and ensure payment of award fees only for excellent  performance. We also recommended that PBGC should provide  comprehensive training on performance-based contracting for PBGC’s  procurement staff, managers, and acquisition-related workforce.
PBGC agreed with our previous recommendations to enhance  implementation of performance-based contracting, and stated that the  actions recommended were already under way, including: incorporating  performance-based measures into its future contracts and providing  comprehensive training for PBGC staff. Further, PBGC noted that the use  of labor-hour contracts had been restricted. However, the move to  performance-based contracting has been difficult. For example, officials  attempted to use performance-based contracts when making new awards  for contracts with the field benefit administration offices, but these efforts  were abandoned because, according to PBGC officials, the proposals were  too complicated to evaluate and more costly than expected. We are  examining these issues in a study currently under way to assess how well  PBGC is managing its contracting activities and the steps it is taking to  ensure the integrity of its contract process. We anticipate completing this  work next summer.
Although we commend PBGC for its improvements to contract  management, we continue to believe that more should be done to include  procurement decision-making in corporate-level strategic planning and to  link contractor performance measures with the corporation’s mission.  Without a more inclusive strategic planning process that looks at the  contract workforce and federal workforce together, PBGC cannot be  assured that it has the optimal mix of contractor staff and federal  employees and that it is holding its contract workforce accountable for  helping meet its strategic goals.
section_title: Benefit Determination Process Management
paragraphs: Finally, our prior work has also found that PBGC needs a more strategic  approach for determining the benefits for participants in large, complex  plans that have been terminated. In our August 2009 report, we reviewed  plans terminated with insufficient funds and trusteed by PBGC during  fiscal years 2000 through 2008. We found that a small number of complex  plans—especially those with large numbers of participants affected by  limits on guaranteed benefit amounts—accounted for most cases with  lengthy delays and overpayments. For example, PBGC completed most  participants’ benefit determinations in less than 3 years, but required more  time—up to 9 years—to process determinations for complex plans and  plans with missing data. In addition, while only a small percentage of  participants receive overpayments of their estimated benefits while their  final benefit amounts are being determined, we found that nearly two- thirds of cases with overpayments involved participants in just 10 large,  complex plans.
Given these findings, we recommended that PBGC develop a better  strategy for processing benefit determinations for complex plans in order  to reduce delays and minimize overpayments, and that PBGC set goals for  timeliness and monitor the progress made in finalizing benefit  determinations for large, complex plans separately from other plans. In  response, PBGC has taken a number of steps to improve its procedures for  communicating with participants in large, complex plans and to reduce  overpayments. In addition, officials indicated that formal process  improvement efforts were under way to tailor plan processing to plan size  and streamline other aspects of work in an effort to reduce process times  in the future. At the same time, officials noted that they had no plans to set  any performance goals separately for large, complex plans as a group. Due  to the complexities and variations with each of these plans, PBGC prefers  to set schedules only on an individual plan basis. However, we continue to  believe that reporting performance measures that reflect averages across  all plans does not provide adequate weight to large versus small plans and  does not provide sufficient incentive to improve the processing times for  large, complex plans.
section_title: Concluding Observations
paragraphs: In these challenging economic times, PBGC has become even more  essential as millions of American workers and retirees have come to rely  on the corporation for protection of their retirement income. PBGC is now  one of the largest federal government corporations with nearly $80 billion  in assets, yet it continues to face a future of financial instability. Its  premium base has been eroding over time as fewer sponsors are paying  premiums for fewer participants. In addition, as a result of the recession,  PBGC is still at risk from the increased underfunding of some large  defined benefit plans. To the extent that companies are more at risk of  bankruptcy, the plans that they sponsor are more at risk of termination.  The fact that PBGC’s board of directors has only recently begun to meet to  discuss these problems is less than reassuring. Moreover, even with the  increased attentiveness of the current board, the lack of staggered terms  for board membership means that consistency in both policy direction and  oversight is not guaranteed in the future. PBGC needs a board that can  offer long-term, strategic sophistication to keep the corporation as solvent  as possible for as long as possible.
Improvements to PBGC’s governance and to its strategic management  cannot correct the structural weaknesses of its financial design, but it can  put PBGC in a better position to confront the challenges that lie ahead. It  is untenable to rest the management of nearly $80 billion in assets on a  corporate board architecture that can fail to meet and provide strategic  direction for years at a time, and that is vulnerable to a lack of leadership  during transitions to new administrations. Companies that pay annual  premiums to PBGC and the millions of employees whose retirement  benefits are under PBGC’s protection are owed greater stewardship of the  corporation and its funds.
Chairman Harkin and Members of the Committee, this concludes my  prepared statement. I would be happy to respond to any questions.
section_title: Contacts and Staff Acknowledgments
paragraphs: For further questions on this testimony, please contact me at (202) 512- 7215. Individuals who made key contributions to this testimony include  Blake L. Ainsworth, Joseph A. Applebaum, Susan C. Bernstein, Jason S.  Holsclaw, Charles A. Jeszeck, Kristen W. Jones, Lara L. Laufer, Sheila R.  McCoy, Margie K. Shields, Craig H. Winslow, and William T. Woods.
section_title: Related GAO Products
paragraphs: Private Pensions: Changes Needed to Better Protect Multiemployer  Pension Plans. GAO-11-79. Washington, D.C.: October 18, 2010.
Private Pensions: Long-standing Challenges Remain for Multiemployer  Pension Plans. GAO-10-708T. Washington, D.C.: May 27, 2010.
Pension Benefit Guaranty Corporation: Workers and Retirees  Experience Delays and Uncertainty when Underfunded Plans Are  Terminated. GAO-10-181T. Washington, D.C.: October 29, 2009.
Pension Benefit Guaranty Corporation: More Strategic Approach Needed  for Processing Complex Plans Prone to Delays and Overpayments.   GAO-09-716. Washington, D.C.: August 17, 2009.
Pension Benefit Guaranty Corporation: Financial Challenges Highlight  Need for Improved Governance and Management. GAO-09-702T  Washington, D.C.: May 20, 2009.
High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January  2009.
Pension Benefit Guaranty Corporation: Improvements Needed to  Address Financial and Management Challenges. GAO-08-1162T.  Washington, D.C.: September 24, 2008.
Pension Benefit Guaranty Corporation: Need for Improved Oversight  Persists. GAO-08-1062. Washington, D.C.: September 10, 2008.
Pension Benefit Guaranty Corporation: Some Steps Have Been Taken to  Improve Contracting, but a More Strategic Approach Is Needed.   GAO-08-871. Washington, D.C.: August 18, 2008.
PBGC Assets: Implementation of New Investment Policy Will Need  Stronger Board Oversight. GAO-08-667. Washington, D.C.: July 17, 2008.
Pension Benefit Guaranty Corporation: A More Strategic Approach  Could Improve Human Capital Management. GAO-08-624. Washington,  D.C.: June 12, 2008.
Pension Benefit Guaranty Corporation: Governance Structure Needs  Improvements to Ensure Policy Direction and Oversight. GAO-07-808  Washington, D.C.: July 6, 2007.
PBGC’s Legal Support: Improvement Needed to Eliminate Confusion and  Ensure Provision of Consistent Advice. GAO-07-757R. Washington, D.C.:  May 18, 2007.
High-Risk Series: An Update. GAO-07-310. Washington, D.C.: January  2007.
Private Pensions: Questions Concerning the Pension Benefit Guaranty  Corporation’s Practices Regarding Single-Employer Probable Claims.  GAO-05-991R. Washington, D.C.: September 9, 2005.
Private Pensions: The Pension Benefit Guaranty Corporation and Long- Term Budgetary Challenges. GAO-05-772T. Washington, D.C.: June 9,  2005.
Private Pensions: Recent Experiences of Large Defined Benefit Plans  Illustrate Weaknesses in Funding Rules. GAO-05-294. Washington, D.C.:  May 31, 2005.
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