Horizon's comment letter covers four topics. One, it discusses additional guidance that may be needed from PBGC with respect to applications for facilitated mergers. Two, it recommends changes to the applicable solvency requirements for mergers and transfers. Three, it proposes that PBGC use its authority to approve certain mergers and transfers that would result in increased solvency for the plans involved and reduced expected losses to PBGC. Four, it encourages PBGC to work with the Department of the Treasury to issue guidance regarding mergers following a suspension of benefits.
Other organizations submitting comments on the proposed rule, which can also be found at regulations.gov, include:
- The American Academy of Actuaries
- The Association of Food and Dairy Retailers, Wholesalers and Distributors (prepared by Venable, LLP)
- Bimbo Bakeries USA
- First Actuarial Consulting, Inc.
- The International Brotherhood of Teamsters
- The Kroger Co.
- The National Coordinating Committee of Multiemployer Plans ("NCCMP")
- Segal Consulting
- The US Chamber of Commerce