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Testimony before the Committee on the Budget, House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 9:30 a.m. EDT: 

Thursday, June 9, 2005: 

Private Pensions: 

The Pension Benefit Guaranty Corporation and Long-Term Budgetary 
Challenges: 

Statement of David M. Walker, Comptroller General of the United States: 

GAO-05-772T: 

GAO Highlights: 

Highlights of GAO-05-772T, testimony before the Committee on the 
Budget, House of Representatives: 

Why GAO Did This Study: 

More than 34 million workers and retirees in over 29,000 single-
employer defined benefit plans rely on a federal insurance program 
managed by the Pension Benefit Guaranty Corporation (PBGC) to protect 
their pension benefits. However, the single-employer insurance 
programís long-term viability is in doubt, and this may have 
significant implications for the federal budget. In fiscal year 2004, 
PBGCís single-employer pension insurance program incurred a net loss of 
$12.1 billion, and the programís accumulated deficit increased to $23.3 
billion. Further, PBGC has estimated that it is exposed to almost $100 
billion of underfunding in plans sponsored by companies with credit 
ratings below investment grade. 

This testimony provides GAOís observations on the nature of the 
challenges facing PBGC and why it is preferable for Congress to act 
sooner rather than later. This testimony also notes the broader context 
in which reform proposals should be considered and the criteria that 
GAO has suggested for reform. 

What GAO Found: 

A combination of recent events, long-term structural problems, and 
weaknesses in the legal framework governing the defined benefit system 
has left PBGC with a significant long-term deficit and many large plans 
badly underfunded. Lower interest rates and equity prices since 2000 
have increased the present value of pension liabilities and lowered the 
value of significant portions of pension plan assets. Meanwhile, PBGC 
is exposed to significant risk from underfunded plans in key industries 
at the same time that its revenue base is threatened by the long-term 
decline in defined benefit plan participation. In addition, the basic 
legal framework governing pension insurance and plan funding has failed 
to help ensure that plan sponsors deliver on their pension promises and 
safeguard the PBGCís financial condition. PBGCís current premium 
structure does not properly reflect the risks to its insurance program 
and facilitates moral hazard behavior by plan sponsors. Further, 
current pension funding rules have not provided sufficient incentives 
for plan sponsors to properly fund their benefit obligations. As a 
result, bankrupt plan sponsors, acting rationally and within the rules, 
have transferred the obligations of their large and significantly 
underfunded plans to PBGC. These weaknesses contribute to and are 
exacerbated by a lack of timely, accurate and transparent information 
that make it difficult for participants, investors, and others to have 
a clear understanding of the true financial condition of pension plans. 

Comprehensive reform is required to ensure that workers and retirees 
receive the benefits promised to them. Ideally, effective reform would: 

* improve the accuracy of plan funding measures while minimizing 
complexity and maintaining contribution flexibility; 
* revise the current funding rules to create incentives for plan 
sponsors to adequately finance promised benefits;
* develop a more risk-based PBGC insurance premium structure and 
provides incentives for sponsors to fund plans adequately; 
* address the issue of underfunded plans paying lump sums and granting 
benefit increases; 
* modify PBGC guarantees of certain plan benefits
* resolve outstanding controversies concerning hybrid plans by 
safeguarding the benefits of workers regardless of age; and 
* improve plan information transparency for pension plan stakeholders 
without overburdening plan sponsors. 

Pension reform is only part of a broader fiscal, economic and 
retirement security challenge. Looking ahead in the federal budget, 
Social Security, together with Medicare and Medicaid, will dominate the 
federal governmentís future fiscal outlook. Reform should also be 
considered in the context of the problems currently facing our nationís 
Social Security system. Importantly, as is the case with Social 
Security, acting sooner rather than later will make comprehensive 
pension reform less costly and more feasible. 

www.gao.gov/cgi-bin/getrpt?GAO-05-772T. 

To view the full product, click on the link above. For more 
information, contact Barbara Bovbjerg at (202) 512-7215 or 
bovbjergb@gao.gov. 

[End of section]

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss the problems and long-term 
challenges facing the defined benefit (DB) pension system, the Pension 
Benefit Guaranty Corporation (PBGC), the retirement security of workers 
and retirees covered by DB plans, and American taxpayers. In 
particular, I will discuss the factors contributing to those problems 
and suggest elements of the comprehensive reform necessary to address 
them.[Footnote 1] As I have noted before, these problems are a subset 
of the broader challenges facing the federal government and our 
nation's retirement income system.[Footnote 2] These programs, which 
include Social Security, Medicare, and Medicaid, represent large, 
growing, and unsustainable claims on the federal budget because 
America's population is aging, life expectancies are increasing, 
workforce growth is slowing, and health care costs are rising. 

The long-term effect of federal retirement programs on the budget is so 
significant that neither slowing the growth of discretionary spending 
nor allowing tax cuts to expire--nor both options combined--would by 
themselves eliminate our long-term fiscal imbalance (see fig. 1). 
Therefore, as we discussed in our 21st Century Challenges 
report,[Footnote 3] tough choices need to be made about the appropriate 
role and size of the federal government--and how to finance that 
government--and how to bring the panoply of federal policies, programs, 
functions and activities into line with the realities of today's world 
and tomorrow's challenges. More specifically to federal retirement 
policy, we need to make choices about how to promote current and long- 
term economic security in retirement. In that latter context, 
comprehensively considering our citizens' needs for income, health 
care, and long-term care is important. 

From our nation's overall fiscal perspective, continuing on our current 
unsustainable fiscal path will gradually erode, if not suddenly damage, 
our economy, our standard of living, and ultimately our national 
security. Therefore, we must fundamentally reexamine major spending and 
tax policies and priorities in an effort to recapture our fiscal 
flexibility and ensure that our programs and priorities respond to 
emerging security, social, economic and environmental changes and 
challenges. 

Figure 1: Composition of Spending as a Share of GDP Assuming 
Discretionary Spending Grows with GDP after 2005 and All Expiring Tax 
Provisions Are Extended: 

[See PDF for image]

Notes: Although expiring tax provisions are extended, revenue as a 
share of gross domestic product (GDP) increases through 2015 due to (1) 
real bracket creep, (2) more taxpayers becoming subject to the 
alternative minimum tax, and (3) increased revenue from tax-deferred 
retirement accounts. After 2015, revenue as a share of GDP is held 
constant. 

[End of figure]

PBGC is an excellent example of the need for Congress to reconsider the 
role of government programs, in general, and federal retirement 
programs, in particular, in light of past changes and 21st century 
challenges. In 1974, Congress passed the Employee Retirement Income 
Security Act (ERISA) to respond to trends and challenges that existed 
at that time.[Footnote 4] Among other things, ERISA established PBGC to 
pay the pension benefits of defined benefit plan participants, subject 
to certain limits, in the event that an employer could not.[Footnote 5] 
When ERISA was enacted, defined benefit pension plans were the most 
common form of employer-sponsored private pension and were growing both 
in number of plans and in number of participants. Today, defined 
benefit pensions cover an ever-decreasing percentage of the U.S. labor 
force, a fact that raises questions about federal policy on pensions in 
general, and defined benefit plans and the PBGC, in particular. 

I would now like to outline the challenges facing the defined benefit 
pension system and PBGC and suggest a framework for evaluating 
potential policy responses. In summary, a combination of recent events, 
long-term structural problems, and weaknesses in the legal framework 
governing pensions has left PBGC with a significant long-term deficit 
and many large plans badly underfunded. Lower interest rates and equity 
prices since 2000 have combined to significantly increase pension 
underfunding through an increase in the present value of pension 
liabilities, and decreases in the value of pension plan assets. 
Meanwhile, intense cost competition as a result of globalization and 
deregulation has led to bankruptcies of plan sponsors in key industries 
like steel and airlines, and is exposing PBGC to the risk of 
significant future losses in these and other industries. This 
competitive restructuring has occurred simultaneously with a long-term 
decline in defined benefit plan participation that threatens PBGC's 
revenue base. In addition, the basic legal framework governing pension 
insurance and plan funding has failed to safeguard the benefit security 
of American workers and retirees and the PBGC's financial condition. 
Too many companies are making pension promises that they are not 
required to deliver on, in part because of perverse incentives and "put 
options" created under the current pension insurance system. 

PBGC's current premium structure does not properly reflect the risks to 
its insurance program and facilitates moral hazard by plan sponsors. 
Further, as we have shown in a recent report, current pension funding 
rules have not provided sufficient incentives, transparency, and 
accountability mechanisms for plan sponsors to properly fund their 
benefit obligations and deliver on their promises.[Footnote 6] As a 
result, bankrupt plan sponsors, acting rationally and within the rules, 
have transferred the obligations of their large and significantly 
underfunded plans to PBGC. These weaknesses in the legal framework 
contribute to and are exacerbated by a lack of transparent information 
that makes it difficult for interested stakeholders to understand the 
true financial condition of and risk associated with selected pension 
plans. 

Given pension plans' crucial significance to our nation's retirement 
security net, it is useful to compare the challenges facing PBGC's 
insurance program and Social Security. Both systems require meaningful, 
comprehensive reform that restores solvency, assures sustainability, 
and protects the benefits of participants. Similar to that of Social 
Security, PBGC's current condition does not represent a crisis, though 
delaying reform will result in serious adverse consequences for 
individuals, the federal budget, and our economy. Furthermore, like 
Social Security, PBGC has plenty of cash on hand today to pay benefits 
to participants in the short term, but it faces large and growing 
unfunded obligations and escalating cash flow deficits in the future. 

The termination of United Airlines' defined benefit pension plans is 
just the latest in a recent series of large, underfunded plans taken 
over by PBGC, and will not be the last. In July 2003, GAO designated 
PBGC's single-employer insurance program as "high-risk," given its 
deteriorating financial condition and long-term 
vulnerabilities.[Footnote 7] At the end of fiscal year 2004, PBGC 
estimated that it was exposed to almost $100 billion of underfunding in 
plans sponsored by companies with credit ratings below investment 
grade. Though smaller in scale than Social Security, Medicare, and 
Medicaid, PBGC's deficit threatens to worsen our government's long-term 
fiscal position.[Footnote 8] While PBGC is not explicitly backed by the 
full faith and credit of the U.S. government,[Footnote 9] policymakers 
would undoubtedly face intense pressure to provide PBGC the resources 
to continue paying earned pension benefits to millions of retirees if 
PBGC were to become insolvent. 

In light of the intrinsic problems facing the defined benefit system, 
meaningful and comprehensive reform will be needed to ensure that 
workers and retirees receive the benefits promised to them and to 
secure PBGC's financial future. At this time, the Administration, 
members of Congress, and others have proposed reforms that seek to 
address many of the problems facing PBGC and the defined benefit 
system. This is a promising development that can be a critical first 
step in addressing part of the long-term fiscal problems facing this 
country. 

Background: 

Before enactment of the Employee Retirement Income Security Act of 1974 
(ERISA), few rules governed the funding of defined benefit pension 
plans, and participants had no guarantees that they would receive their 
promised benefits. Among other things, ERISA created the PBGC to 
protect the benefits of plan participants in the event that plan 
sponsors could not meet the benefit obligations under their plans. 
ERISA also established rules for funding defined benefit pension plans, 
instituted pension insurance premiums, promulgated certain fiduciary 
rules, and developed annual reporting requirements. When a plan is 
terminated with insufficient assets to pay its guaranteed benefits, 
PBGC takes over the plan and assumes responsibility for paying benefits 
to participants. According to PBGC's 2004 annual report, PBGC provides 
insurance protection for over 29,000 single-employer pension plans, 
which cover 34.6 million workers, retirees, and their 
beneficiaries.[Footnote 10]

PBGC receives no direct federal tax dollars to support the single- 
employer pension insurance program. Instead, the program receives the 
assets of terminated underfunded plans and any of the sponsor's assets 
that PBGC recovers during bankruptcy proceedings.[Footnote 11] PBGC 
finances the unfunded liabilities of terminated plans with premiums 
paid by plan sponsors and income earned from the investment of program 
assets. Premiums have two components: a per participant charge paid by 
all sponsors (currently $19 per participant), and a variable-rate 
premium that some underfunded plans pay based on the level of unfunded 
benefits.[Footnote 12]

The single-employer program has had an accumulated deficit--that is, 
program assets have been less than the present value of benefits and 
other obligations--for much of its existence. (See fig. 2.) In fiscal 
year 1996, the program had its first accumulated surplus, and by fiscal 
year 2000, the accumulated surplus had increased to about $10 billion, 
in 2002 dollars. However, the program's finances reversed direction in 
2001, and at the end of fiscal year 2002, its accumulated deficit was 
about $3.6 billion. In fiscal year 2004, the single-employer program 
incurred a net loss of $12.1 billion, and its accumulated deficit 
increased to $23.3 billion, up from $11.2 billion a year earlier. 
Furthermore, PBGC estimated that total underfunding in single-employer 
plans exceeded $450 billion, as of the end of fiscal year 2004. 

Figure 2: Assets, Liabilities, and Net Financial Position of PBGC's 
Single-Employer Insurance Program: 

[See PDF for image]

[End of figure]

In defined benefit plans, formulas set by the employer determine 
employee benefits. DB plan formulas vary widely, but benefits are 
frequently based on participant earnings and years of service, and 
traditionally paid upon retirement as a lifetime annuity, or periodic 
payments until death. Because DB plans promise to make payments in the 
future, and because tax-qualified DB plans must be funded, employers 
must use present value calculations to estimate the current value of 
promised benefits.[Footnote 13] The calculations require making 
assumptions about factors that affect the amount and timing of benefit 
payments, such as an employee's retirement age and expected mortality, 
and about the expected return on plan assets, expressed in the form of 
an interest rate. The present value of accrued benefits calculated 
using mandated assumptions is known as a plan's current liability. 
Current liability provides an estimate of the amount of assets a plan 
needs today to pay for accrued benefits. 

ERISA and the Internal Revenue Code (IRC) prescribe rules regarding the 
assumptions that sponsors must use to measure plan liabilities and 
assets. While different assumptions will change a plan's reported 
assets and liabilities, sponsors eventually must pay the amount of 
benefits promised; if the assumptions used to compute current liability 
differ from the plan's actual experience, current liability will differ 
from the amount of assets actually needed to pay benefits.[Footnote 14]

Funding rules generally presume that a pension plan and its sponsor are 
ongoing entities, and plans do not necessarily have to maintain an 
asset level equal to current liabilities every year. However, the 
funding rules include certain mechanisms that are intended to keep 
plans from becoming too underfunded. One such mechanism is the 
additional funding charge (AFC), which applies to plans with more than 
100 participants.[Footnote 15] The AFC requires plan sponsors to make 
additional contributions to plans that fall below a prescribed funding 
level. With some exceptions, plans with reported asset values below 90 
percent of current liabilities are affected by the AFC rules. 

PBGC'S Problems Stem from Recent Events, Long-Term Structural Trends, 
and Weaknesses in the Legal Framework Governing DB Pensions: 

A combination of recent events, long-term structural problems, and 
weaknesses in the legal framework governing the DB system has left PBGC 
with a significant long-term deficit and many large plans badly 
underfunded. Lower interest rates and equity prices since 2000 have 
combined to significantly increase pension underfunding through an 
increase in the present value of pension liabilities, and decreases in 
the value of pension plan assets. Meanwhile, intense cost competition 
as a result of globalization and deregulation has led to bankruptcies 
of plan sponsors in key industries like steel and airlines, and is 
exposing PBGC to the risk of significant future losses in these and 
other industries. This competitive restructuring has occurred 
simultaneously with a long term decline in defined benefit plan 
participation that threatens PBGC's revenue base. In addition, the 
basic legal framework governing pension insurance and plan funding has 
failed to safeguard the benefit security of American workers and 
retirees and the PBGC's financial condition. Too many companies are 
making pension promises that they are not required to deliver on, in 
part because of perverse incentives and "put options" created under the 
current pension insurance system. 

PBGC's current premium structure does not properly reflect the risks to 
its insurance program and facilitates moral hazard by plan sponsors. 
Further, current pension funding rules have not provided sufficient 
incentives, transparency, and accountability mechanisms for plan 
sponsors to properly fund their benefit obligations and deliver on 
their promises. As a result, bankrupt plan sponsors, acting rationally 
and within the rules, have transferred the obligations of their large 
and significantly underfunded plans to PBGC. These weaknesses in the 
legal framework contribute to and are exacerbated by a lack of 
transparent information that makes it difficult for interested 
stakeholders to understand the true financial condition of and risk 
associated with selected pension plans. 

Recent Economic Factors Exacerbated the Underfunding of Large 
Terminated Plans by Bankrupt Sponsors: 

Over the last 5 years, many large pension plans have been adversely 
affected by simultaneous declines in broad equity indexes and long-term 
interest rates, as well as by the financial difficulties of their plan 
sponsors.[Footnote 16] Poor investment returns from stock market 
declines affected the asset values of pension plans to the extent that 
plans invested in stocks. According to the ERISA Industry Committee, 
assets in private sector defined benefit plans totaled $2.056 trillion 
at the end of 1999, dropped to $1.531 trillion at the end of 2002, and 
climbed back to $1.8 trillion by the end of 2004.[Footnote 17] Lower 
equity values since the end of 1999 have been particularly problematic 
because interest rates have also declined and thus increased the 
present value of plan liabilities.[Footnote 18] Some sponsors of large 
pension plans that were terminated were not in sufficiently strong 
financial condition to meet their pension funding requirements because 
of weaknesses in their primary business activities. Bankruptcies and 
pension plan terminations increased around the U.S. economic recession 
of 2001 and around prior recessions.[Footnote 19]

These conditions played a part in increasing the unfunded liabilities 
of plans terminated by bankrupt sponsors since 2000. For example, 
according to the filing of its annual regulatory report for pension 
plans, Bethlehem Steel's plan went from 86 percent funded in 1992 to 97 
percent funded in 1999. From 1999 to its plan termination in December 
2002, plan funding fell to less than 50 percent as assets decreased and 
liabilities increased and sponsor contributions were not sufficient to 
offset the changes. 

Long-Term Declines of Key Industries and in Defined Benefit Pension 
Coverage Have Contributed to PBGC's Weakening Financial Condition: 

Long-term trends in some sectors of the economy and in defined benefit 
pension coverage are threatening both PBGC's future solvency and the 
economic security in retirement of workers and retirees. PBGC's risk of 
inheriting underfunded pensions largely stems from the fact that more 
than half of the pension participants it insures are in the 
manufacturing and airline sectors, which have been exposed to lower 
cost competition because of several factors including globalization and 
deregulation.[Footnote 20] A potentially exacerbating risk to PBGC is 
the cumulative effect of bankruptcy in these industries: if a critical 
mass of firms go bankrupt and terminate their underfunded pension 
plans, their competitors may also declare bankruptcy to similarly avoid 
the cost of funding their plans. 

PBGC also faces the possibility of long-term revenue declines from 
demographic changes in the population of defined benefit plan 
participants and a shrinking number of DB plans. Over the long term, an 
aging population of defined benefit plan participants threatens to 
reduce PBGC's ability to raise premium revenues as participants die and 
are not replaced by enough new participants. The percentage of 
participants who are active workers has declined from 78 percent in 
1980 to just under 50 percent in 2002. Furthermore, PBGC cannot 
effectively diversify its risk from the terminations of plans in 
declining economic sectors because companies in other growing 
industries have generally not sponsored new defined benefit plans. As 
plan sponsors in weak industries go bankrupt and terminate their 
pension plans, PBGC not only faces immediate changes in its financial 
position from taking over underfunded plans, but also faces losses of 
future revenues from these terminated plans. 

A related factor eroding PBGC's premium base is the growth of lump-sum 
pension distributions. More and more plan participants are exiting the 
defined benefit system by taking lump-sum distributions from their 
plans. After a lump-sum distribution is paid, the participant is out of 
the defined benefit system and the plan sponsor no longer has to 
contribute to the pension insurance system on the participant's behalf. 
In addition, lump-sum distributions to participants in underfunded 
plans can create the effect of a "run on the bank" and worsen a plan's 
underfunding. In such cases, the plan may terminate without enough 
assets to pay full benefits to other participants and PBGC may incur 
losses. 

The increasing prevalence of lump-sum distributions in defined benefit 
plans and the growth of defined contribution plans also raise 
significant questions about whether many Americans will enjoy an 
economically secure retirement.[Footnote 21] Many Americans are at risk 
of outliving their retirement assets as life expectancies, health care, 
and long-term care costs continue to increase. 

Legal Framework Has Not Encouraged Adequate Plan Funding, Contributing 
to PBGC's Financial Difficulties: 

Existing laws and regulations governing pension funding and premiums 
have contributed to PBGC's financial difficulties and exposed PBGC to 
greater risks from the companies whose pension plans it insures. PBGC's 
current premium structure does not properly reflect the risks to its 
insurance program and facilitates moral hazard by plan sponsors. 
Further, the pension funding rules, under ERISA and the IRC, have not 
ensured that plans have the means to meet their benefit obligations in 
the event that plan sponsors run into financial distress. First, the 
current rules likely allowed plans to appear better funded than they 
actually were, in both good years and bad years. And even these 
reported funding levels indicated significant levels of underfunding in 
our study of the 100 largest DB plans.[Footnote 22] Second, plan 
sponsors often substituted "account credits" for cash contributions, 
even as the market value of plan assets may have been in decline. And 
third, the AFC, the primary mechanism for improving the financial 
condition of poorly funded plans, was ineffective in doing so. These 
weaknesses contribute to and are exacerbated by a lack of transparent 
information that makes it difficult for plan participants, investors, 
and others to have a clear understanding of their plan's financial 
condition. As a result, financially weak benefit plan sponsors, acting 
rationally and within the current law, have been able to avoid large 
contributions to underfunded plans prior to bankruptcy and plan 
termination, thus adding to PBGC's current deficit. 

PBGC's Premium Structure Does Not Properly Reflect Risks to the 
Insurance Program: 

PBGC's current premium structure does not properly reflect risks to the 
insurance program. The current premium structure relies heavily on flat-
rate premiums, which, since they are unrelated to risk, result in large 
cost shifting from financially troubled companies with underfunded 
plans to healthy companies with well-funded plans. PBGC also charges 
plans a variable-rate premium based on the plan's level of 
underfunding. However, these premiums do not consider other relevant 
risk factors, such as the economic strength of the sponsor, plan asset 
investment strategies, the plan's benefit structure, or the plan's 
demographic profile. PBGC is currently operated somewhat more on a 
social insurance model, since it must cover all eligible plans 
regardless of their financial condition or the risks they pose to the 
solvency of the insurance program. 

In addition to facing firm-specific risk that an individual underfunded 
plan may terminate, PBGC faces market risk that a poor economy may lead 
to widespread underfunded terminations during the same period, 
potentially causing very large losses for PBGC. Similarly, PBGC may 
face risk from insuring plans concentrated in vulnerable industries 
affected by certain macroeconomic forces such as deregulation and 
globalization that have played a role in multiple bankruptcies over a 
short time period, as has happened recently in the airline and steel 
industries. One study estimates that the overall premiums collected by 
PBGC amount to about 50 percent of what a private insurer would charge 
because its premiums do not adequately account for these market 
risks.[Footnote 23] Others note that it would be hard to determine the 
market-rate premium for insuring private pension plans because private 
insurers would probably refuse to insure poorly funded plans sponsored 
by weak companies. 

PBGC Is Subject to Moral Hazard: 

Current pension funding and insurance laws create incentives for 
financially troubled firms to use PBGC in ways that Congress likely did 
not intend when it formed the agency in 1974. At that time, PBGC was 
established to pay the pension benefits of participants, subject to 
certain limits, in the event that an employer could not. However, since 
that time, some firms with underfunded pension plans may have come to 
view PBGC coverage as a fallback, or "put option," for financial 
assistance. The very presence of PBGC insurance may create certain 
perverse incentives that represent what economists call moral hazard-- 
where struggling plan sponsors may place other financial priorities 
above funding up their pension plans because they know PBGC will pay 
guaranteed benefits. Firms may even have an incentive to seek Chapter 
11 bankruptcy in order to escape their pension obligations. As a 
result, once a plan sponsor with an underfunded pension plan 
experiences financial difficulty, these moral hazard incentives may 
exacerbate the funding shortfall for PBGC. 

This moral hazard effect has the potential to escalate, with the 
initial bankruptcy of firms with underfunded plans creating a vicious 
cycle of bankruptcies and terminations. Firms with onerous pension 
obligations and strained finances could see PBGC as a means of shedding 
these liabilities, thereby providing these companies with a competitive 
advantage over other firms that deliver on their pension commitments. 
This would also potentially subject PBGC to a series of terminations of 
underfunded plans in the same industry, as we have already seen with 
the steel and airlines industries in the past 20 years. 

Moral hazard effects are likely amplified by current pension funding 
and pension accounting rules that may also encourage plans to invest in 
riskier assets to benefit from higher expected long-term rates of 
return. In determining funding requirements, a higher expected rate of 
return on pension assets means that the plan needs to hold fewer assets 
in order to meet its future benefit obligations. And under current 
accounting rules, the greater the expected rate of return on plan 
assets, the greater the plan sponsor's operating earnings and net 
income. However, with higher expected rates of return comes greater 
risk of investment volatility, which is not reflected in the pension 
insurance program's premium structure. Investments in riskier assets 
with higher expected rates of return may allow financially weak plan 
sponsors and their plan participants to benefit from the upside of 
large positive returns on pension plan assets without being truly 
exposed to the risk of losses. The benefits of plan participants are 
guaranteed by PBGC, and weak plan sponsors that enter bankruptcy can 
often have their plans taken over by PBGC. 

Current Funding Rules Do Not Provide Sufficient Incentives for Sponsors 
to Adequately Fund Their Plans: 

The pension funding rules, under ERISA and the IRC, have not provided 
sufficient incentives for plan sponsors to properly fund their benefit 
obligations. The funding rules generally presume that pension plans and 
their sponsors are ongoing entities and therefore allow for a certain 
extent of plan underfunding that can be made up over time. However, the 
measures of plan funding used to determine contribution requirements 
can significantly overstate the true financial condition of a plan. And 
even these reported funding levels indicated significant levels of 
underfunding in our study of the 100 largest DB plans.[Footnote 24] 
Furthermore, when plan sponsors make contributions to their plans, they 
can use account credits, rather than cash, even in cases when plans are 
underfunded. The funding rules include certain mechanisms--primarily, 
the AFC--that are intended to prevent plans from becoming too 
underfunded. However, our analysis shows that for several reasons, the 
AFC proved ineffective in restoring financial health to poorly funded 
plans. 

Rules May Allow Plans to Overstate Their Current Funding Levels: 

Current funding rules may allow plans to overstate their current 
funding levels to plan participants and the public. Because many plans 
in our sample chose legally allowable actuarial assumptions and asset 
valuation methods that may have altered their reported liabilities and 
assets relative to market levels, it is possible that funding over our 
sample period was actually worse than reported. 

Although as a group, funding levels among the 100 largest plans were 
reasonably stable and strong from 1996 to 2000, by 2002, more than half 
of the largest plans were underfunded (see fig. 3). On average, each 
year 39 of these plans were less than 100 percent funded, 10 had assets 
below 90 percent of their current liabilities, and 3 plans were less 
than 80 percent funded. In 2002 there were 23 plans less than 90 
percent funded. 

Figure 3: Almost One-Fourth of the Largest Pension Plans Were Less than 
90 Percent Funded on a Current Liability Basis in 2002: 

[See PDF for image]

[End of figure]

Reported funding levels may have been overstated for a number of 
reasons. These include the use of above-market interest rates, which 
leads to an understatement of the cost of settling benefit obligations 
through the purchase of group annuity contracts. Also, actuarial asset 
values may have differed by as much as 20 percent from current market 
value of plan assets. The funding rules allow for smoothing out year- 
to-year fluctuations in asset and liability values so that plan 
sponsors are gradually, and not suddenly, affected by significant 
changes in interest rates and the values of their assets. When current 
interest rates decline, the use of a 4-year weighted average interest 
rate lags behind, and thus measurements of the present value of plan 
liabilities do not accurately reflect the cost of settling a plan's 
benefit obligations.[Footnote 25]

The terminations of the Bethlehem Steel and LTV Steel pension plans in 
2002 (two of the largest plan terminations, to date) illustrate the 
potential discrepancies between reported and actual funding. In 2002, 
the Bethlehem Steel Corporation reported that its plan was 85.2 percent 
funded on a current liability basis, yet the plan terminated later that 
year with assets of less than half of the value of promised benefits. 
In 2001, LTV Steel reported that its plan for hourly employees was 80 
percent funded, yet when the plan terminated in March 2002, it was only 
52 percent funded. From these terminations PBGC's single-employer 
program suffered losses of $3.7 billion and $1.6 billion, 
respectively.[Footnote 26]

Most Sponsors Most Years Made No Cash Contributions to Plans but 
Satisfied Funding Requirements through Use of Accounting Credits: 

The amount of contributions required under IRC minimum funding rules is 
generally the amount needed to fund benefits earned during that year 
plus that year's portion of other liabilities that are amortized over a 
period of years. This minimum contribution requirement may be met by 
the plan sponsor putting cash into the plan or by applying earned 
funding credits. These funding credits are not measured at their market 
value and are credited with interest each year, according to the plan's 
long-term expected rate of return on assets.[Footnote 27] When the 
market value of a plan's assets declines, the value of funding credits 
may be significantly overstated. 

For the 1995 to 2002 period, the sponsors of the 100 largest plans each 
year on average made relatively small cash contributions to their plans 
(see fig. 4). Annual cash contributions for the 100 largest plans 
averaged approximately $97 million on plans averaging $5.3 billion in 
current liabilities (in 2002 dollars). This average contribution level 
masks a large difference in contributions between 1995 and 2001, during 
which period annual contributions averaged $62 million (in 2002 
dollars), and in 2002, when contributions increased significantly to 
$395 million per plan. Further, in 6 of the 8 years in our sample, a 
majority of the largest plans made no cash contribution to their plan. 
On average each year, 62.5 plans received no cash contribution, 
including an annual average of 41 percent of plans that were less than 
100 percent funded. 

Figure 4: Most Large Plans Received No Annual Cash Contribution, 1995- 
2002: 

[See PDF for image]

Note: Average contributions for 2002 are largely driven by one 
sponsor's contribution to its plan. Disregarding this $15.2 billion 
contribution reduces the average plan contribution for 2002 from $395 
million to $246 million. 

[End of figure]

As stated earlier, Bethlehem Steel and LTV Steel both had plans 
terminate in 2002 that were only about 50 percent funded. Yet each plan 
was able to forgo a cash contribution each year from 2000 to 2002, 
instead using credits to satisfy minimum funding obligations, primarily 
from large accumulated credit balances from prior years. Despite being 
severely underfunded, each plan reported an existing credit balance at 
the time of termination. 

AFC, Primary Mechanism for Improving Funding of Underfunded Plans, 
Proved Ineffective: 

The funding rules' primary mechanism for improving the financial 
condition of underfunded plans, the additional funding charge proved 
ineffective in helping underfunded plans for four main reasons: 

1. Very few plans in our sample were actually assessed an AFC because 
the rules, despite the statutory threshold of a 90 percent funding 
level for some plans to owe an AFC, in practice require a plan to be 
much more poorly funded to be subject to this requirement.[Footnote 28] 
From 1995 to 2002, an average of only 2.9 of the 100 largest DB plans 
each year were assessed an additional funding charge, even though on 
average 10 percent of plans each year reported funding levels below 90 
percent. Over the entire 8-year period, only 6 unique plans that were 
among the 100 largest plans in any year from 1995 to 2002 owed an AFC. 
These 6 plans owed an AFC during the period a total of 23 times in 
years in which they were among the 100 largest plans, meaning that 
plans that were assessed an AFC were likely to owe it again. 

2. AFC rules also specify a current liability calculation method that 
may overstate actual plan funding, relative to market-value measures, 
thereby reducing the number of plans that might be assessed an AFC. The 
specified interest rate for this calculation exceeded current market 
rates in 98 percent of the months between 1995 and 2002. 

3. The AFC rules generally call for sponsors to pay only a percentage 
of their unfunded liability, rather than requiring restoration of full 
funding. On average, by the time a plan was assessed an AFC, it was 
significantly underfunded and was likely to remain chronically 
underfunded in subsequent years. Among the 6 plans that owed the AFC, 
funding levels rose slightly from an average of 75 percent when the 
plan was first assessed an AFC to an average of 76 percent, looking 
collectively at all subsequent years. All of these plans were assessed 
an AFC more than once. 

4. Plan sponsors can meet the AFC requirement by applying funding 
credits earned in prior years in place of cash contributions. The 
account value of these credits, which accumulate interest, may not 
reflect the underlying value of the assets in the plan. Many plans 
experienced significant market value losses of their assets between 
2000 and 2002 while they were able to apply these funding credits. 
Among the 100 largest plans, just over 30 percent of the time a plan 
was assessed an AFC, the funding rules allowed the sponsor to forgo a 
cash contribution altogether that year. 

The experience of two large terminated plans illustrates the 
ineffectiveness of the AFC. For example, Bethlehem Steel's plan was 
assessed an AFC of $181 million in 2002, but the company made no cash 
contribution that year, just as it had not in 2000 or 2001, years in 
which the plan was not assessed an AFC. When the plan terminated in 
late 2002, its assets covered less than half of the $7 billion in 
promised benefits. LTV Steel, which terminated its pension plan for 
hourly employees in 2002 with assets of $1.6 billion below the value of 
benefits, had its plan assessed an AFC each year from 2000 to 2002, but 
for only $2 million, $73 million, and $79 million, or no more than 5 
percent of the eventual funding shortfall. Despite these AFC 
assessments, LTV Steel made no cash contributions to its plan from 2000 
to 2002. Both plans were able to apply existing credits instead of cash 
to satisfy minimum funding requirements. In addition, both sponsors had 
unused funding credits at the time their plans were terminated. 

Weaknesses in Funding Rules Amplified by Lack of Transparency Hinders 
Sound Policy making: 

Unclear measures of pension funding and a lack of timely information 
have made it difficult for plan participants, investors, regulators, 
and policy makers to accurately assess the financial condition of 
pension plans. Without timely and reasonably accurate data about the 
financial condition of pension plans, the various stakeholders cannot 
make timely and informed decisions on retirement savings, employment, 
and other key life issues. The primary regulatory filing for pension 
plans--the Form 5500--requires multiple measures of pension assets and 
liabilities, yet none of these measures tell PBGC and plan participants 
what share of the benefit obligations are funded in the event of plan 
termination. Furthermore, by the time these regulatory reports are 
publicly available, the information is usually at least 2 years 
old.[Footnote 29] In a time of significant changes in interest rates 
and equity prices, it is possible that reported measures of pension 
funding will substantially differ from current measures of plan 
funding. PBGC does receive more current information about plans that 
are underfunded by at least $50 million. This more current information 
includes estimates of funding measures if the plan were to be 
terminated; however, by law this information is not disclosed to the 
public. 

Our cash-based budgetary framework for federal insurance programs also 
contributes to a lack of transparency that, at worst, may create 
disincentives for policy makers to enact reform measures.[Footnote 30] 
With the current cash-based reporting, premiums for insurance programs 
are recorded in the budget when collected, and outlays are reported 
when claims are paid.[Footnote 31] This focus on annual cash flows 
generally does not adequately reflect the government's cost for federal 
insurance programs because the time between the extension of the 
insurance, the receipt of premiums and other collections, the 
occurrence of an insured event, and the payment of claims may extend 
over several budget periods. As a result, the government's cost may be 
understated in years that a program's current premium and other 
collections exceed current payments and overstated in years that 
current claim payments exceed current collections. This is especially 
problematic in the case of pension insurance because of the erratic 
occurrence of plan terminations as well as the mismatch between premium 
collections and benefit payments that can extend over several decades. 

Cash-based budgeting also may not be a very accurate gauge of the 
economic impact of federal insurance programs. Although discerning the 
economic impact of federal insurance programs can be difficult, private 
economic behavior generally is affected when the government commits to 
providing insurance coverage. In the case of PBGC, the existence of 
pension insurance may encourage plan sponsors and employees to agree to 
pension benefit increases in lieu of wage increases when the plan 
sponsor faces economic difficulties.[Footnote 32]

Cash-based budgeting for federal insurance programs may provide neither 
the information nor incentives necessary to signal emerging problems, 
make adequate cost comparisons, control costs, or ensure the 
availability of resources to pay future claims. Because the cash-based 
budget delays recognition of emerging problems, it may not provide 
policy makers with information or incentives to address potential 
funding shortfalls before claim payments come due. Policy makers may 
not be alerted to the need to address programmatic design issues 
because, in most cases, the budget does not encourage them to consider 
the future costs of federal insurance commitments. Thus, reforms aimed 
at reducing costs may be delayed. In most cases, by the time costs are 
recorded in the budget, policy makers do not have time to ensure that 
adequate resources are accumulated to pay for them or to take actions 
to control them. The late budget recognition of these costs can reduce 
the number of viable options available to policy makers, ultimately 
increasing the cost to the government. 

Retirement Income Security Requires Meaningful and Comprehensive 
Reform: 

In light of the intrinsic problems facing the defined benefit system, 
meaningful and comprehensive pension reform is required to ensure that 
workers and retirees receive the benefits promised to them and to 
secure PBGC's financial future. While PBGC's current financial 
condition does not represent a crisis, delaying reform will result in 
serious adverse consequences for plan participants, the federal budget, 
and our nation's economy. At this time, the Administration, members of 
Congress, and others have proposed reforms that seek to address many of 
the problems facing PBGC and the defined benefit system.[Footnote 33] 
Such comprehensive effective pension reform would likely include 
elements that would improve measures of pension funding and enhance 
transparency of plan information, strengthen funding rules (while 
preserving some contribution flexibility for plan sponsors, modify 
certain PBGC guarantees, develop an enhanced and more risk-based 
insurance premium structure, and resolve outstanding controversies 
concerning hybrid plans, such as cash balance plans.[Footnote 34]

GAO Has Suggested Elements of Pension Reform: 

Pension reform is a challenge because of the necessity of fusing 
together so many complex, and sometimes competing, elements into a 
comprehensive proposal. Ideally, effective reform would: 

* improve the accuracy of plan funding measures while minimizing 
complexity and maintaining contribution flexibility;

* revise the current funding rules to create incentives for plan 
sponsors to adequately finance promised benefits;

* develop a more risk-based PBGC insurance premium structure and 
provides incentives for sponsors to fund plans adequately;

* address the issue of underfunded plans paying lump sums and granting 
benefit increases;

* modify PBGC guarantees of certain plan benefits (e.g., shutdown 
benefits);

* resolve outstanding controversies concerning hybrid plans by 
safeguarding the benefits of workers regardless of age; and: 

* improve plan information transparency for pension plan stakeholders 
without overburdening plan sponsors. 

Furthermore, if policy makers decide to provide measures of relief to 
sponsors of poorly funded pension plans, there should be mechanisms 
built into such laws that would prevent any undue exacerbation of 
PBGC's financial condition. 

Developed in isolation, solutions to some of these concerns could erode 
the effectiveness of other reform components or introduce needless 
complexity. As deliberations on reform move forward, it will be 
important that each of these individual elements be designed so that 
all work in concert toward well-defined goals. Even with meaningful, 
carefully crafted reform, it is possible that some defined benefit plan 
sponsors may choose to freeze or terminate their plans. While these are 
serious concerns, the overarching goals of balanced pension reform 
should be to protect workers' benefits by providing employers the 
flexibility they need in managing their pension plans while also 
holding those employers accountable for the promises they make to their 
employees. 

The debate over defined benefit pension reform should not take place in 
isolation of larger related issues. Challenges in the defined benefit 
system, together with the recent public debate over the merits of 
including individual accounts as part of a more comprehensive Social 
Security reform proposal, should lead us to consider fundamental 
questions about how who should bear certain risks and responsibilities 
for economic security in retirement. 

* Individual savings require greater responsibility and offer greater 
potential rewards and the possibility of bequeathing any unused 
retirement savings. However, longevity risk--the risk of outliving 
retirement savings--and poor investment choice are significant 
concerns, particularly as health care and long-term care costs and life 
expectancies continue to rise. 

* The federal government is in the best position to share risk across 
the population, and social insurance programs, including Social 
Security, Medicare, and Medicaid already reflect this fact. However, 
the current structure of existing federal retirement programs is 
unsustainable. 

* Employer-sponsored pensions can alleviate longevity risk for plan 
participants and are generally presumed to be better placed to manage 
investment risk. However, poor management of plans can lead to 
shortfalls in funding that can damage the competitiveness of the plan 
sponsors. Furthermore, many employers are cutting or reducing retiree 
health benefits, and even employee health benefits, as growing health 
care costs threaten their competitiveness. 

Experts Identified a Variety of Broad Pension Reforms: 

Earlier this year, GAO convened a forum on the future of the defined 
benefit system and the PBGC that included a diverse group of about 40 
pension experts, representing various interests, to discuss various 
reforms to the defined benefit pension system.[Footnote 35] In addition 
to debating changes to the funding rules and PBGC premiums, 
participants also talked about ways to address pension legacy costs 
(the costs of terminated and underfunded pension plans) and features of 
pension plans that government policy should encourage. 

According to participants in the GAO forum, resolution of pension 
legacy costs and clarification of the legal status of cash balance and 
other hybrid pension plans could play a significant role in shoring up 
the defined benefit system.[Footnote 36] Separating legacy costs from 
the existing and future liabilities of the remaining defined benefit 
plans might encourage plan sponsors to remain in the defined benefit 
system. Many plan sponsors are concerned that through increased PBGC 
premiums, they may be required to pay for the failures of other 
companies to responsibly fund and manage their pension plans. Some 
participants added that resolving legacy costs could be a key component 
of any pension reform legislation that tightened the funding rules and 
assessed premiums according to PBGC's risk. Also, some participants 
supported, and other participants opposed, the idea of separately 
addressing the pension legacy costs of specific industries, such as 
airlines and steel, which have imposed the most significant costs on 
PBGC. Separately addressing pension legacy costs does not necessarily 
imply a taxpayer bailout, as some participants suggested other ways to 
cover their cost, such as through an airline ticket fee to cover the 
airlines' share of PBGC's deficit. Others noted that resolving the 
uncertain legal status of cash balance and other hybrid pension plans 
could encourage greater participation in the defined benefit system. 
Expanding the universe of pension plan sponsors could lead to an 
increase in PBGC's premium income. 

Some forum participants also suggested that the debate over federal 
retirement policy needs to move beyond distinctions between defined 
benefit and defined contribution plans. Others added that discussions 
of retirement policy need to focus on ways to create incentives and 
remove barriers for employers to set up retirement plans, and how to 
get American workers to build adequate retirement savings and security. 
This may be achieved by thinking about the interaction of private 
pensions and Social Security and by looking at hybrid pension plans, 
such as cash balance plans and plans that combine the best features of 
defined benefit and defined contribution plans. Participants suggested 
new pension plan designs be developed that explore the following 
features: 

* allowing automatic participation of the covered population in order 
to expand pension coverage generally;

* improving the portability of pension benefits to accommodate workers 
who frequently change jobs;

* providing for professional money management and pooled investment 
risk;

* minimizing early withdrawals and borrowing--a problem known as 
leakage--from retirement savings; and: 

* providing incentives to receive benefits in the form of a fixed 
annuity, rather than a lump-sum distribution. 

Conclusions: 

Widely reported recent large plan terminations by bankrupt sponsors and 
the resulting adverse consequences for plan participants and the PBGC 
have pushed pension reform into the spotlight of national concern. Our 
analysis here suggests that a variety of factors have contributed to 
the current state of affairs: recent declines in interest rates and 
financial markets, a soft economy, industry restructuring because of 
changes in the national and world economies, weaknesses in the legal 
framework governing pensions that has encouraged moral hazard by 
sponsors, the underfunding of plans, and a lack of timely, accurate, 
useful and transparent information that limits participants, unions, 
investors and other stakeholders from being able to make accurate and 
timely decisions. 

In light of the intrinsic problems facing the defined benefit system, 
meaningful and comprehensive pension reform is required to ensure that 
workers and retirees receive the benefits promised to them. At this 
time, the Administration, members of Congress, and others have proposed 
reforms that seek to address many of the problems facing PBGC and the 
defined benefit system. This is a promising development that can be a 
critical first step in addressing part of the long-term fiscal problems 
facing this country. Such reform will demand wisdom and patience, given 
the necessity of fusing together so many complex, and sometimes 
competing, elements into a comprehensive proposal. Ideally, effective 
reform would: 

* improve the accuracy of plan funding measures while minimizing 
complexity and maintaining contribution flexibility;

* revise the current funding rules to create incentives for plan 
sponsors to adequately finance promised benefits;

* develop a more risk-based PBGC insurance premium structure and 
provides incentives for sponsors to fund plans adequately;

* address the issue of underfunded plans paying lump sums and granting 
benefit increases;

* modify PBGC guarantees of certain plan benefits (e.g., shutdown 
benefits);

* resolve outstanding controversies concerning hybrid plans by 
safeguarding the benefits of workers regardless of age; and: 

* improve plan information transparency for pension plan stakeholders 
without overburdening plan sponsors. 

However, it is also necessary to keep in mind that pension reform is 
only part of the broader fiscal, economic, workforce, and retirement 
security challenges facing our nation. If you look ahead in the federal 
budget, Social Security, together with the rapidly growing health 
programs (Medicare and Medicaid), will dominate the federal 
government's future fiscal outlook. These are far larger and more 
urgent challenges, representing an unsustainable burden on future 
generations. Furthermore, pension reform should be considered in the 
context of the problems facing our nation's Social Security system. How 
we reform DB pensions has crucial implications for directions taken in 
reforming Social Security. For example, pension reforms that reduce the 
scope of the private pension system or change the dominant form of 
private pension design may have consequences for those elements of 
Social Security reform packages that reduce benefits or include an 
individual accounts feature. 

This also means that acting sooner rather than later will make reform 
less costly and more feasible. Though smaller in scale than actuarial 
deficits in Social Security, Medicare, and Medicaid, PBGC's deficit 
threatens to worsen our government's long-term fiscal position. 
Finally, as with Social Security, it is also important to evaluate 
pension reform proposals as comprehensive packages. The elements of any 
reform proposal interact; every package will have pluses and minuses, 
and no plan will satisfy everyone on all dimensions. If we focus on the 
pros and cons of each element of reform by itself, we may find it 
impossible to build the bridges necessary to achieve consensus. 

We look forward to working with Congress on these crucial issues. 

Mr. Chairman, this concludes my statement. I would be happy to respond 
to any questions you or other members of the Committee may have. 

Contact and Acknowledgments: 

For further information, please contact Barbara Bovbjerg at (202) 512- 
7215. Individuals making key contributions to this testimony include 
David Eisenstadt and Charlie Jeszeck. 

FOOTNOTES

[1] Many of these elements are explored in greater detail in a report 
that GAO is releasing today. GAO, Comptroller General's Forum: The 
Future of the Defined Benefit System and the Pension Benefit Guaranty 
Corporation, GAO-05-578SP (Washington, D.C.: June 9, 2005). 

[2] GAO, Long-Term Fiscal Issues: The Need for Social Security Reform, 
GAO-05-318T (Washington, D.C.: Feb. 9, 2005). 

[3] GAO, 21st Century Challenges: Reexamining the Base of the Federal 
Government, GAO-05-325SP (Washington, D.C.: Feb. 2005). 

[4] One impetus for the passage of ERISA was the failure of 
Studebaker's defined benefit pension plan in the 1960s, in which 
thousands of plan participants lost most or all of their pensions. 

[5] Some defined benefit plans are not covered by PBGC insurance; for 
example, plans sponsored by professional service employers, such as 
physicians and lawyers, with 25 or fewer employees. 

[6] GAO, Private Pensions: Recent Experiences of Large Defined Benefit 
Plans Illustrate Weaknesses in Funding Rules, GAO-05-294 (Washington, 
D.C.: May 31, 2005). 

[7] GAO, Pension Benefit Guaranty Corporation Single-Employer Insurance 
Program: Long-Term Vulnerabilities Warrant "High Risk" Designation, GAO-
03-1050SP (Washington, DC: July 23, 2003). 

[8] For additional discussion of these broader fiscal challenges, see 
GAO, Our Nation's Fiscal Outlook: The Federal Government's Long-Term 
Budget Imbalance, at http://www.gao.gov/special.pubs/longterm/longterm.html. 

[9] PBGC is authorized to borrow up to $100 million from the U.S. 
Treasury to cover temporary cash shortfalls. 

[10] PBGC also guarantees a smaller pension benefit for approximately 
10 million participants in multiemployer pension plans. 

[11] According to PBGC officials, PBGC files a claim for all unfunded 
benefits in bankruptcy proceedings. However, PBGC generally recovers 
only a small portion of the total unfunded benefit amount in bankruptcy 
proceedings, and the recovered amount is split between PBGC (for 
unfunded guaranteed benefits) and participants (for unfunded 
nonguaranteed benefits). 

[12] The additional premium equals $9.00 for each $1,000 (or fraction 
thereof) of unfunded vested benefits. A plan's sponsor may be exempt 
from paying the variable rate premium if the plan met a specified 
funding threshold in the previous plan year. 

[13] Present value calculations reflect the time value of money--that a 
dollar in the future is worth less than a dollar today, because the 
dollar today can be invested and earn interest. Using a higher interest 
rate will lower the present value of a stream of payments because it 
implies that a lower level of assets today will be able to fund those 
future payments. 

[14] A plan's current liability may differ from its termination 
liability, which measures the value of accrued benefits using 
assumptions appropriate for a terminating plan. For further discussion 
of current versus termination liability, see appendix IV of GAO, 
Pension Benefit Guaranty Corporation: Single-Employer Pension Insurance 
Program Faces Significant Long-Term Risks, GAO-04-90, (Washington, 
D.C.: Oct. 29, 2003). 

[15] The AFC was introduced by the Omnibus Budget Reconciliation Act of 
1987. See Pub. L. No. 100-203 (1987). 

[16] Broad equity indexes in the U.S. have risen since 2002 but remain 
significantly below their peak levels of 2000. 

[17] ERISA Industry Committee, Consensus Proposals for Pension Funding, 
PBGC Reform, and Hybrid Pension Plans, (Washington, D.C.: May 2005). 
Asset totals in 2002 and 2004 include billions of dollars in 
contributions by plan sponsors since 1999. 

[18] Falling interest rates raise the price of group annuities that a 
terminating plan must purchase to cover its promised benefits and 
increase the likelihood that a terminating plan will not have 
sufficient assets to make such a purchase. A potentially offsetting 
effect of falling interest rates is the possible increased return on 
fixed-income assets that plans hold. When interest rates fall, the 
value of existing fixed-income securities with time left to maturity 
rises. 

[19] Three of the last five annual increases in bankruptcies coincided 
with recessions, and the record economic expansion of the 1990s is 
associated with a substantial decline in bankruptcies. Annual plan 
terminations resulting in losses to the single-employer program rose 
from 83 in 1989 to 175 in 1991, and after declining to 65 in 2000, the 
number reached 93 in 2001. The last three recessions on record in the 
United States occurred during 1981, 1990-91, and 2001 (See www.bea.gov/ 
bea/dn/gdpchg.xls). 

[20] The causes of restructuring are likely industry-specific. For 
example, the U.S. airline industry, which has many pension plans in 
poor financial condition, has faced profit pressures as a result of 
severe price competition, terrorism, the war in Iraq, and the outbreak 
of severe acute respiratory syndrome (SARS), creating bankruptcies and 
uncertainty about the future financial health of the industry. 

[21] A major factor contributing to the increase in lump-sum 
distributions from defined benefit plans is the growing prevalence of 
hybrid plans, such as cash balance plans, which typically offer lump 
sums. Hybrid plans are a form of DB plan that determines benefits on 
the basis of hypothetical individual accounts. 

[22] GAO-05-294. 

[23] Boyce, Steven, and Richard A. Ippolitio, "The Cost of Pension 
Insurance," The Journal of Risk and Insurance, (2002) Vol. 69, No. 2, 
pp.121-170. 

[24] For further details of this study, covering 1995-2002, see GAO-05-
294. These 100 plans are not a closed group. The 100 largest plans, as 
measured by current liability, changed from year to year for various 
reasons, including mergers and divestitures of plan sponsors. A total 
of 187 distinct plan identifiers were included in our sample, and 25 of 
them were in each year's sample. 

[25] Conversely, when interest rates rise, the opposite would be true, 
and the weighted average would make the cost of settling plan 
liabilities higher than the current market rate would indicate. 

[26] Several factors may explain the wide discrepancy between reported 
funding levels and actual funding levels at termination. Reported 
funding levels may use an actuarial value of assets, which may exceed 
the market value at termination. In addition, termination liabilities 
are valued using a different interest rate than that used for current 
liabilities. Further, current liabilities and termination liabilities 
may be measured at different times. Unfunded shutdown benefits may also 
raise termination liabilities. For more discussion of the differences 
between termination and current liabilities, see GAO-04-90, appendix 
IV. 

[27] See 26 U.S.C. 412(b). 

[28] A plan is not subject to an AFC if the value of plan assets (1) is 
at least 80 percent of current liability and (2) was at least 90 
percent of current liability for at least 2 consecutive of the 3 
immediately preceding years. 

[29] For further information about problems with the content and 
timeliness of regulatory reports on pensions, see GAO, Private 
Pensions: Government Actions Could Improve the Timeliness and Content 
of Form 5500 Pension Information, GAO-05-491 (Washington, D.C.: June 3, 
2005), and Private Pensions: Publicly Available Reports Provide Useful 
but Limited Information on Plans' Financial Condition, GAO-04-395 
(Washington, D.C.: Mar. 31, 2004). 

[30] GAO, Budget Issues: Budgeting for Federal Insurance Programs, GAO/ 
T-AIMD-98-147 (Washington, D.C.: Apr. 23, 1998), and Budget Issues: 
Budgeting for Federal Insurance Programs, GAO/AIMD-97-16 (Washington, 
D.C.: Sept. 30, 1997). 

[31] PBGC's premium collections and benefit payments are recorded in 
the budget on a cash basis, regardless of when the commitments are 
made. The premiums paid by participants are held in a revolving fund. 
PBGC's budget treatment is complicated by the use of a second account 
for some activities which is not included in the federal budget. This 
account records the assets and liabilities that PBGC acquires from 
terminated plans. As a result, the budget only reports PBGC's net 
annual cash flows between its on-budget account and all other entities, 
including the other PBGC account. It does not provide information on 
liabilities PBGC incurs when it takes over an underfunded plan or other 
changes in PBGC's assets and liabilities. 

[32] GAO-05-578SP. 

[33] For example, earlier this year, the Administration released a 
proposal that focuses on reforming the funding rules; improving 
disclosure to workers, investors, and regulators about pension plan 
status; and adjusting premiums to better reflect a plan's risk to PBGC. 
See U.S. Department of Labor, Employee Benefits Security 
Administration, Strengthen Funding for Single Employer Pension Plans, 
February 7, 2005. 

[34] For greater detail, see GAO-04-90. 

[35] GAO, Comptroller General's Forum: The Future of the Defined 
Benefit System and the Pension Benefit Guaranty Corporation, GAO-05-
578SP (Washington, DC: June 2005). Participants included government 
officials, researchers, accounting experts, actuaries, plan sponsor and 
employee group representatives, and members of the investment 
community. 

[36] Cash balance plans are a type of defined benefit plan that look 
more like a defined contribution plan to participants. As with other 
defined benefit plans, the sponsor is responsible for managing the 
plan's commingled assets and complying with the minimum funding 
requirements. However, information about benefits is communicated to 
plan participants through the use of hypothetical account balances, 
which makes the plan appear like an individual account-based defined 
contribution plan. The hypothetical account balances communicated to 
plan participants do not necessarily bear any relationship to actual 
assets held by the plan.