This letter supplements ERIC's prior comment letter and testimony on this issue.
In particular, ERIC's recent letter discussed in further detail that:
- Companies will need to restructure their credit agreements as a result of the proposed regulations;
- Many financially sound companies secure their receivables to reduce financing costs;
- Complying with the proposed regulations would be costly for companies;
- 98% of the largest U.S. defined benefit plans will not qualify for the safe harbor for plans that are 120% funded on a premium basis; and
- The PBGC should not create a new approach whereby it uses a limited number of factors in the company safe harbor.
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