“ERIC strongly supports the current regulatory framework and believes that the PBGC has the tools it needs to protect the system without unduly burdening those employers who choose to continue to sponsor defined benefit plans,” Francese testified.
ERIC’s testimony centered on the following four points:
- It is not necessary to overhaul the existing regulations’ approach to waivers;
- The proposed regulations essentially eliminate plan funding as a basis for a waiver;
- The PBGC should focus on the financial soundness of the plan and not the plan sponsor; and
- The proposed safe harbor for financial soundness of a plan sponsor is unworkable and there is no suitable alternative.
A more detailed description is available for ERIC members and guests here.
To access ERIC’s testimony, click here.
To access ERIC’s comment letter, click here.

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