Horizon's comment letter emphasizes how two-pool allocation methods can help multiemployer pension plans attract and retain employers, which can strengthen their funding levels. The letter also encourages PBGC to provide guidance to plan sponsors on how to apply and receive approval for two-pool methods, while cautioning against guidance that is overly restrictive or budensome.
Other organizations submitting comments on the proposed rule, which can also be found at regulations.gov, include:
- The American Academy of Actuaries
- The National Coordinating Committee of Multiemployer Plans ("NCCMP")
- Proskauer Rose, LLP
- Segal Consulting
- The US Chamber of Commerce