The trade association for the country's largest plans sponsors wants to make sure the Pension Benefit Guaranty Corp. understands how de-risking can ultimately strengthen what remains of private-sector defined benefit plans.
For starters, it would like the agency to remain flexible and to write clearer language as it sets out to gather data on plans' de-risking efforts for the first time.
"By allowing companies to have flexibility and choice with respect to approaches to managing retirement plans, policymakers can support companies in their efforts to continue to provide their workers with retirement benefits through pension plans," said Kathryn Ricard, vice president for retirement policy at the ERISA Industry Committee.
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ERIC's letter noted that many companies want to continue to sponsor their defined benefit plans, but need to minimize the risks associated with them.
"De-risking activities is one method that companies are utilizing to reduce their risks associated with defined benefit plans, while simultaneously maximizing and securing benefits for participants and retirees," Ricard wrote. "These plan sponsors are able to continue to sponsor their pension plans through managing investment risks, purchasing annuities from reputable companies, offering lump sums, and amending their plan designs."
"If these risks are not properly managed, they can impact the value of a plan sponsor's market capitalization as well as its credit rating, ability to obtain capital, and cash flow," ERIC's letter said.
Also read: PBGC wants annuity conversion reports
This year, Motorola Solutions Inc. and Newell Rubbermaid Inc. have announced de-risking plans, as have dozens of other large employers over the past few years.
In a notice published in the Federal Register in September, the PBGC said it plans to require sponsors next year to report "certain undertakings to cash out or annuitize benefits for a specified group of former employees."
Responding to the agency's request for comments from the industry, ERIC, the Washington, D.C.-based lobbying organization representing large plan sponsors' pension interests, called the PBGC's Information Collection Request "somewhat vague and open-ended" with respect to the type of information the agency hopes to collect.
In pushing for clarification, ERIC said in its comment letter that as proposed, PBGC's time frame for collecting "de-risking" data was inconsistent, as the information it will seek next year will include the previous two years, while going-forward data collected annually will reflect de-risking activity for only one year.
It also suggested PBGC broaden its reporting time. The agency has said it will want information for all lump-sum payouts and annuity purchases made up to 30 days before the premium is paid. ERIC wants that extended to 60 days, which it says will allow plan administrators the time necessary to provide accurate data.
And ERIC wants the language PBGC uses changed when it comes to gauging how many participants are offered buyout options and how many take them.
Using terms such as "offered" and "elected," according to ERIC, is not specific enough and could create inaccurate data. For instance, a retiree may be mailed a letter offering the option but never actually receive that letter, because of an address change.
Instead, ERIC wants to the PBGC to use "eligible for lump sum" and "received lump sum."
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