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Washington, DC 20548:

United States General Accounting Office:

December 17, 2003:

The Honorable Earl Pomeroy:

Ranking Minority Member:

Subcommittee on Oversight:

Committee on Ways and Means:

House of Representatives:

Subject: Private Pensions: Timely and Accurate Information Is Needed to 
Identify and Track Frozen Defined Benefit Plans:

Dear Mr. Pomeroy:

While private-sector pensions help millions of Americans achieve 
retirement income security, the number of private defined benefit (DB) 
plans[Footnote 1] has declined substantially over the past two decades. 
Recently, those concerned with the viability of the private defined 
benefit pension system point to significant increases in pension 
contributions plan sponsors must make and to the fact that most plans 
are currently underfunded. The underfunding of plans, due in large part 
to the sharp decline in the stock market combined with a general 
decline in interest rates, has increased substantially. The Pension 
Benefit Guaranty Corporation (PBGC), whose single-employer insurance 
program insures the benefits of over 34 million workers and retirees in 
private defined benefit plans,[Footnote 2] estimated that the total 
underfunding exceeded $350 billion as of September 4, 2003.

Between 1999 and 2002, roughly 7,000 DB plans participating in the PBGC 
single-employer insurance program were terminated. PBGC trusteed, or 
took over, about 5 percent of these plans because they did not have 
enough assets to pay benefits due to participants. When PBGC takes over 
a plan, participants may receive a reduction in expected retirement 
benefits.[Footnote 3]

According to employer groups, plan sponsors face inflated and 
unpredictable pension contributions that have greatly diminished the 
attractiveness of maintaining DB plans. As a result, employer groups 
have suggested that plan sponsors may consider freezing their plans 
rather than confronting the possibility of increased pension 
contributions. A plan "freeze" could have adverse consequences for the 
retirement income security of participants because new employees are 
precluded from participating in the plan, and current participants 
might not receive additional benefit accruals.

DB plan sponsors may vary the extent to which they freeze their plan. 
One type of DB plan freeze, called a "hard freeze," stops all benefit 
accruals. In this instance, all current employees who participate in 
the plan receive no additional benefit accruals after the effective 
date of the freeze. Also, employees hired after the freeze are 
prevented from participating in the plan. Another type of plan freeze, 
called a "soft freeze," stops benefit accruals based on years of 
service only. In such cases, no additional years of participant's 
service with the sponsor are included in participants' retirement 
benefit determinations after the effective date of the freeze, but 
benefits still grow with increases in an employee's compensation. 
Additionally, a plan sponsor may freeze the plan for certain groups of 
workers only or close the plan to new participants.

While data are published annually on terminations of DB plans covered 
by PBGC's insurance program, little is known regarding the occurrence 
of DB plan freezes. The Form 5500 Annual Return is a primary source of 
public information on tax-qualified private pensions.[Footnote 4] We 
previously reported that while Form 5500 Annual Returns provide 
aggregate information, there are concerns about the availability and 
quality of information reported on these forms.[Footnote 5] Because 
timely and accurate information on plan freezes could be important in 
assessing the overall health of the private DB plan system, you asked 
us to determine how many DB plans have been frozen since 2000.

To determine how many DB plans have been frozen since 2000, we 
interviewed officials at the Department of Labor (DOL), the Internal 
Revenue Service (IRS), and PBGC regarding work the agencies have done 
in this area as well as the usefulness of currently available 
information in identifying and tracking frozen DB plans. In addition, 
we reviewed selected reporting requirements and examined forms that 
plan sponsors must submit to DOL, IRS, and PBGC. We also interviewed 
pension plan consultants with DB plan sponsor clients and reviewed 
information they provided to us. We conducted our work from August to 
November 2003 in accordance with generally accepted government auditing 

Results in Brief:

We could not determine the number of defined benefit plans frozen since 
2000. Currently available public information cannot be used to readily 
identify and track frozen DB plans. Officials at PBGC and DOL we 
interviewed considered potential approaches to using Form 5500 filings 
to determine how many DB plans have been frozen, and we found that such 
approaches have limitations with respect to the accuracy and 
completeness of the results. Consequently, PBGC requested that the 2002 
Form 5500 Annual Return collect information on DB frozen plans. This 
information, however, is limited and will not be available until 2004. 
We reviewed other reports and disclosures that DB plans must provide to 
the government or participants, but determined that these are not 
useful in identifying frozen plans. Publicly available information is 
of limited use in identifying and tracking frozen plans in part because 
there is no statutory definition of a DB plan freeze. Private surveys 
from benefits consulting firms seek to estimate the incidence of DB 
plan freezes in recent years, but the results reflect information from 
their clients only and do not provide a clear and complete picture of 
plan freezes among all DB plans. More complete and timely information 
on frozen defined benefit plans could help assess the potential risks 
plan freezes pose to participants' retirement income security and the 
viability of PBGC's single-employer insurance program.

Because it is uncertain to what extent DB plan freezes pose risks to 
participants' retirement income security and PBGC's single-employer 
insurance program, we believe that additional steps are needed to 
collect information on such plans and evaluate their potential 
consequences. Accordingly, we are recommending that PBGC's Executive 
Director direct the agency to identify, track, and analyze frozen DB 
plans on a pilot basis.


The U.S. pension system is voluntary; employers decide whether to 
establish a retirement plan and determine the design, terms, and 
features of the plan or plans they choose to sponsor. To encourage 
employers to establish and maintain pension plans for their employees, 
the federal government provides preferential tax treatment under the 
Internal Revenue Code (IRC) for plans that meet certain requirements.

The IRS, DOL's Employee Benefits Security Administration (EBSA), and 
PBGC are primarily responsible for enforcing laws that govern private 
pension plans. IRS enforces provisions of IRC that apply to tax-
qualified pension plans. EBSA enforces the Employee Retirement Income 
Security Act's (ERISA) reporting and disclosure provisions and 
fiduciary responsibility standards, which among other things concern 
the type and extent of information provided to the federal government 
and plan participants. PBGC insures the benefits of participants in 
certain tax-qualified private-sector defined benefit plans. Insurance 
protection is provided for certain DB plan participants in the event 
that a plan terminates with insufficient assets.

DB plan administrators are required to file information annually with 
IRS, DOL, and PBGC on the financial condition and operation of their 
plans. This information is provided on the Form 5500 Annual Return and 
accompanying schedules. The Form 5500 was intended, in part, to measure 
employers' compliance with ERISA's fiduciary and funding provisions. 
The Form 5500 provides information about the financial condition of the 
plan, annual amounts contributed by participants, and the plan's income 
on investments. The form also provides information on plan 
characteristics, such as plan type (defined benefit or defined 
contribution), method of funding, and numbers of employees, 
participants, and employees who are excluded from the plan for various 

The IRS also requires that plan administrators file information in 
certain instances. For example, plan administrators must file certain 
forms that disclose changes to the plan that the sponsor wants to make. 
These changes include combining plans after a company merger or 
consolidation, or in some cases when terminating a plan. PBGC requires 
that plan administrators file forms that are used to report and pay 
their premiums to PBGC. Sponsors of PBGC-insured single-employer plans 
generally must submit information when certain reportable events occur, 
such as when there is a reduction in the number of active participants 
or failure to make required contributions to meet pension obligations.

ERISA established PBGC to pay the pension benefits of participants, 
subject to certain limits, in the event that an employer could not. 
Under ERISA, the termination of a single-employer DB plan results in an 
insurance claim with PBGC's single-employer program if the plan does 
not have sufficient assets to pay all benefits accrued under the plan 
up to the date of termination. If a single-employer DB plan terminates 
without sufficient assets, PBGC takes over the plan's assets and is 
responsible for paying benefits up to limits set by law to participants 
who are entitled to receive them.[Footnote 6] For example, PBGC 
generally does not guarantee annual benefits above a certain amount, 
currently about $44,000 per participant at age 65. A plan sponsor may 
voluntarily terminate its DB pension plan by meeting certain 
conditions, depending on the funded status of the plan. When a fully 
funded single-employer plan terminates, the benefits of participants 
are protected because the sponsor pays all participant benefits accrued 
under the plan up to the date of termination.[Footnote 7]

Alternatively, DB plan sponsors may freeze their plan. A plan freeze 
occurs when a sponsor amends its plan to cease benefit accruals 
indefinitely in the future.

Plan sponsors may implement a freeze for a variety of reasons. PBGC 
guidelines on voluntary termination identify the cessation of benefit 
accruals as an alternative to termination under certain circumstances 
that sponsors may consider. A plan sponsor may decide to freeze its 
plan when it is not fully funded and can no longer afford the cost of 
the plan. For example, a sponsor may not be able to voluntarily 
terminate an underfunded plan until it has enough assets to cover 
benefit liabilities. Moreover, a sponsor facing financial strain may 
not meet conditions for PBGC to step in and trustee the plan either. 
However, a DB plan freeze may be temporary in some cases. For example, 
the sponsor cannot or chooses not to fund additional benefit accruals 
for the time being. Alternatively, a sponsor may freeze the plan when 
it anticipates terminating the plan at some later date. In some cases, 
this might mean that participants receive no further accruals from a DB 
pension plan. However, not all plan terminations mean that participants 
lose future pension accruals. For instance, pension sponsors might 
terminate a plan due to a corporate merger and move participants into 
an already existing DB plan. Similarly, a sponsor might terminate a DB 
plan to replace it with another type of plan such as a defined 
contribution plan.

We recently designated PBGC's single-employer insurance program as high 
risk because of its current financial weaknesses, as well as the 
serious, long-term risks to the program's future viability.[Footnote 8] 
We reported that two important risks could affect the long-term 
financial viability of the single-employer program. First, the high 
level of losses experienced in 2002, due to the bankruptcy of companies 
with large underfunded defined-benefit pension plans, could continue or 
accelerate. Second, PBGC might not receive sufficient revenue from 
premium payments and its own investments to offset the losses 
experienced to date or those that may occur in subsequent years. 
Further, we highlighted factors that could cause premium income 
received by PBGC's single-employer insurance program to dwindle over 
the long term. For example, fixed rate premiums would decline if the 
number of participants covered by the program decreases, which may 
happen if plans leave the system and are not replaced. Moreover, a 
decline in the number of plans PBGC insures could weaken its ability to 
increase premium income in the future.

The Number of Frozen Defined Benefit Plans Is Not Currently Known:

We could not determine the number of defined benefit plans that have 
frozen since 2000. Currently available public information cannot be 
used to readily identify and track frozen DB plans. PBGC officials told 
us that they cannot reliably track such plans with currently available 
public data, and DOL officials we spoke with concurred with PBGC's 
assessment. Both PBGC and DOL considered approaches to estimate the 
number of frozen DB plans using currently available Form 5500 data. 
However, upon review, the agencies determined that such approaches were 
difficult to employ and likely to yield incomplete and inconsistent 
results. According to the officials at DOL and PBGC we spoke with, the 
approaches they examined could only provide a rough estimate because 
such approaches are based on indicators that could suggest 
characteristics associated with a plan freeze. For example, DOL 
assessed its approach and determined that some frozen plans could be 
missed and some ongoing plans could be erroneously categorized as 
frozen. As a result, both PBGC and DOL officials we spoke with told us 
that they would need to contact plans directly or find supporting 
documentation in order to make a definitive determination regarding the 
status of plans identified by the approaches considered.

In recognition of the need to obtain more definitive information on 
frozen DB plans, PBGC requested the addition of an item to the 2002 
Form 5500 Annual Return. The 2002 Form 5500 Annual Return includes an 
identifying code that allows plan sponsors or administrators to 
indicate whether the plan has been frozen for all benefit accruals 
(i.e., both service credits and salary increases). Thus, information on 
plan freezes that becomes available from the 2002 Form 5500 is limited 
to so-called "hard freezes." The data will not provide information 
about plan freezes that freeze only service credits for benefit 
accruals--so-called "soft freezes." Furthermore, plan sponsors or 
administrators are not able to indicate instances when the plan is 
frozen for certain groups of workers or closed to new 
participants.[Footnote 9]

PBGC also noted shortcomings with the timeliness of Form 5500 data for 
the purpose of identifying and tracking frozen DB plans. Because 2002 
Form 5500 data filings are first due 7 months after the end of the plan 
year and because, on average, it takes over 6 months to process a Form 
5500 filing at present, data from plans whose plan year began January 
1, 2002 (plan year 2002) are not expected to be generally available 
until February 2004. At the time of this review, any approach using 
currently available Form 5500 data would only capture few instances of 
plan freezes that occurred after 2001. However, officials we 
interviewed suspected many of the recent DB plan freezes occurred 
during 2002 and 2003. In addition to being limited and delayed, the 
2002 Form 5500 identifier may not result in accurate information. For 
example, plan sponsors may not fully adjust their reporting procedures 
to account for the new identifying code. Thus, the data may initially 
result in a miscount of so-called hard freezes because reporting errors 
are typically higher in the first year a new item is added to the Form 

Other reports and disclosures that plans must provide to the government 
or participants about the plan's operation, financial status, terms, or 
benefits do not specifically or readily identify frozen DB plans. The 
reports and disclosures we reviewed include the premium forms that 
covered plans submit to PBGC, the notice of reportable events submitted 
to PBGC, Application for Determination for Employee Benefit Plan 
submitted to IRS, and requirements under section 204(h) of ERISA. While 
events related to a DB plan freeze may trigger certain reporting or 
disclosure requirements, plan sponsors are not explicitly required to 
report to the federal government or participants that they have frozen 
their plan in such instances. For example, while a PBGC-insured frozen 
DB plan would be required to submit the annual premium form, the form 
does not expressly require the sponsor to indicate whether or not the 
plan is frozen. Additionally, section 204(h) of ERISA requires plan 
sponsors to provide notices to participants when they amend the plan in 
a way that results in a significant reduction in either the rate of 
future benefit accruals or an early retirement benefit or retirement-
type subsidy, which would include a plan freeze. However, plan sponsors 
are not required to furnish these notices to the government nor are 
they specifically required to declare the plan as frozen, even though 
the information contained within the notice could describe changes to 
future benefit accruals consistent with a plan freeze.

Publicly available information is of limited use in identifying and 
tracking frozen DB plans in part because there is no statutory 
definition of a DB plan freeze. We found few references to DB plan 
freezes within existing laws and regulations applicable to private 
pensions. While ERISA and IRS regulations delineate characteristics 
indicative of a plan freeze in determining whether a partial 
termination has occurred, this reference only applies to a limited set 
of frozen plans.[Footnote 10] Aside from this limited regulatory 
reference and the new identifying code on the 2002 Form 5500, there is 
no definition of a plan freeze within current law and regulations. The 
lack of a statutory definition constrains the capability of federal 
agencies in identifying and tracking such plans.

Private Surveys of Plan Sponsors Indicate Occurrence of Plan Freezes, 
but Results Are Limited:

Surveys from benefits consulting firms indicate that plan freezes have 
occurred in recent years, but such surveys do not provide a clear and 
complete picture of plan freezes among all DB plans. Generally, 
practitioners we spoke with from these benefits consulting firms 
highlighted the role of current economic conditions on the funding 
status of defined benefit pensions. They also noted an increase in the 
number of DB plans freezing over the last few years. Some had surveyed 
their clients to ascertain to what extent they had frozen or intended 
to freeze their DB plan. For example, one consulting firm reported that 
2 percent of plans it surveyed had frozen benefits prior to 2001, and 
13 percent implemented a freeze since that time.[Footnote 11] Another 
private consulting firm conducted a survey on their clients' DB plans 
and found that 15 percent of these plans had frozen or reduced benefits 
for current employees, and 19 percent had frozen or reduced benefits 
for new employees since 2000. While the results of these surveys 
suggest that some plan sponsors have frozen or are considering freezing 
their plans, they cannot be generalized to all DB plans because they 
are drawn from a limited client base. Moreover, the surveys we reviewed 
used different definitions of a plan freeze so their results are not 
directly comparable. For example, one survey asked questions broadly 
about actions plan sponsors had taken or intended to take, including 
plan freezes along with other changes such as terminating the plan.

Complete and Timely Information on Frozen DB Plans Could Help Assess 
the Potential Risks to Participants and the PBGC Insurance Program:

More complete and timely information on frozen DB plans could help 
assess the potential risks that plan freezes might pose to 
participants' retirement income security and the viability of PBGC's 
single-employer insurance program. The impact on participant's 
retirement income is likely to vary depending on the extent to which 
the plan is frozen and the long-term result of the freeze. DB plan 
freezes may also increase risks to the long-term health of PBGC's 
single-employer insurance program.

Because plan sponsors can freeze their plan in various ways, the risks 
to participants' retirement income security can vary in part depending 
on the type of freeze that the sponsor implements. Depending on the 
extent to which benefit accruals are frozen, the number of participants 
whose future benefit accruals are reduced will vary, as will the extent 
to which a participant's future benefit accruals could be reduced. For 
example, a hard freeze reduces expected future defined benefit accruals 
to a greater degree than a soft freeze. Furthermore, a hard freeze 
affects all participants and new employees, while a soft freeze may 
leave certain participants unaffected.

The ultimate outcome of a DB plan freeze also affects the extent to 
which workers may receive income from private pensions. For example, a 
frozen DB plan may or may not be replaced with another pension plan at 
some later date. If a frozen plan is terminated and replaced, the new 
plan could be more or less generous in terms of providing future 
benefit accruals. Thus, it could be important to examine the reasons 
any individual plan sponsor might freeze. This is because they could 
potentially indicate whether the plan sponsor is likely to continue 
offering that plan or a similar plan in the future, or whether the plan 
sponsor is likely to significantly reduce pension benefits. Knowing the 
reasons why DB plan freezes occur could help assess the likelihood that 
the affected participants may or may not experience a significant 
reduction in expected benefit accruals.

DB plan freezes could also increase risks to the long-term 
sustainability of PBGC's single-employer insurance program. PBGC 
officials told us that to the extent plan freezes are an early 
indicator of future terminations, they may also be predictive of 
reductions in PBGC's premium revenue stream. Furthermore, they said 
that anticipated problems with respect to PBGC's ability to collect 
premium revenue might be understated because plan freezes are not 
currently analyzed by PBGC. To be viable in the long term, the single-
employer insurance program must receive sufficient income from premiums 
and investments to offset losses due to terminated underfunded plans. 
Fixed rate premiums will decline if the number of participants covered 
by the program decreases, which may happen if plans leave the system 
and are not replaced. Frozen plans that are ultimately terminated could 
lessen PBGC's ability to collect revenue premiums over the long term.

The extent to which plan freezes pose risks to the sustainability of 
PBGC's single-employer insurance program, and the associated PBGC 
liabilities are difficult to gauge because PBGC cannot identify and 
analyze frozen DB plans with currently available public information. 
PBGC officials indicated that DB plans might implement a plan freeze in 
a variety of ways and for a variety of reasons. Because different 
factors may precipitate a plan freeze, it is important to have 
information on the extent of and the reason for the freeze so that the 
risks to participants and PBGC can be adequately assessed. It is also 
important to track the final outcome of a plan freeze. Whether a frozen 
plan will eventually unfreeze, terminate, or remain frozen has 
different implications for the risk facing PBGC. For instance, if a 
plan sponsor freezes an underfunded plan, such action could help reduce 
or delay PBGC's exposure to termination liabilities. While plans that 
unfreeze or remain frozen pose no immediate risks, their eventual 
termination could reduce PBGC premium revenue and if underfunded result 
in liabilities for PBGC.


The extent to which DB plan freezes pose risks to participants' 
retirement income security and to the sustainability of PBGC's single-
employer insurance program is difficult to gauge with currently 
available public information. Plan freezes lessen pension adequacy 
through the cessation of benefit accruals for current participants and 
by preventing new employees from participating in the plan. However, it 
is difficult to assess the potential long-term impact of plan freezes 
on participants' retirement income without information on the eventual 
consequences in such instances. Additionally, while plans that unfreeze 
or remain frozen pose no immediate risk to PBGC, their eventual 
termination could reduce premium revenue and if underfunded, result in 
claims on the single-employer insurance program.

However, the federal government cannot systematically identify and 
track frozen DB plans with currently available public information. 
Eventually, the recent addition of an identifying code to the Form 5500 
Annual Return will provide federal agencies with data on frozen DB 
plans limited to so-called hard freezes. However, such initial 
information is likely to be of poor quality, and by the time such 
information becomes available on frozen DB plans, it may well be out of 
date. Hence, policymakers have incomplete information to formulate and 
evaluate policies to ensure DB plans provide adequate and secure 
retirement income.

Reliable and timely identification and tracking of DB plan freezes is 
an important first step in obtaining the information needed to make 
sound assessments regarding potential risks to participants and PBGC's 
insurance program. PBGC intends to examine the potential for obtaining 
more detailed and timely information on frozen plans without creating 
an undue burden on plan sponsors. However, simply collecting and 
reporting information on the incidence of plan freezes is not 
sufficient to gauge the associated risks. A thorough examination of the 
factors that precipitated and the eventual outcomes of DB plan freezes 
is needed to ascertain the extent to which such instances pose risks to 
participants and PBGC.

Recommendation for Executive Action:

To enable the federal government to determine the risks DB plan freezes 
pose to participants and PBGC, we recommend that the Executive Director 
of the PBGC direct the agency to conduct a pilot study to identify 
frozen DB plans it insures and assess the usefulness of information on 
the characteristics and consequences of plan freezes. The information 
PBGC obtains from plan sponsors could help it assess the extent to 
which plans are frozen, the eventual outcomes of plan freezes, and the 
likely consequences on PBGC's single-employer insurance program and 
participants' retirement benefits. The results of a pilot study could 
help PBGC determine whether a regular data collection and analysis 
effort is warranted and if an additional reporting requirement for plan 
sponsors is needed.

Agency Comments:

We provided PBGC with a draft of this correspondence for review and 
comment. PBGC provided informal technical comments, which we have 
incorporated where appropriate.

We are sending copies of this correspondence to the Executive Director 
of PBGC, the Secretary of Labor, the Secretary of Treasury, and other 
interested congressional committees. Copies will also be available at 
GAO's Web site at

If you have any questions concerning this letter, please contact me at 
(202) 512-7215 or George Scott at (202) 512-5932. Jeremy Citro, Charles 
Ford, and Gene Kuehneman also made major contributions to this 

Sincerely yours,

Barbara D. Bovbjerg:

Director, Education, Workforce, and Income Security Issues:


Signed by Barbara D. Bovbjerg:


[1] Employers may sponsor DB and/or defined contribution (DC) plans for 
their employees. DB plans promise to provide a benefit that is 
generally based on an employee's salary and years of service. DB plans 
use a formula to determine the ultimate pension benefit participants 
are entitled to receive. Under a DC plan, employees have individual 
accounts to which the employee, employer, or both make contributions, 
and benefits are based on contributions to and investment returns 
(gains and losses) on the accounts.

[2] There are two federal insurance programs for defined benefit plans: 
one for single-employer plans and another for multiemployer plans. 
Single-employer plans provide benefits to employees of one firm or, if 
plan terms are not collectively bargained, to employees of several 
unrelated firms.

[3] The benefit PBGC pays to a participant whose plan has been 
terminated and taken over by PBGC depends on the provisions of the 
terminated plan and certain statutory limits that specify maximum 
benefit payments among other factors.

[4] The Department of Labor, in conjunction with the Internal Revenue 
Service and PBGC publishes the Form 5500 to be used by plan 
administrators and employers in order to satisfy their annual reporting 
obligations under the Employee Retirement Income Security Act and the 
Internal Revenue Code. Plan administrators must also submit certain 
schedules, depending on the features of the plan that accompany the 
Form 5500.

[5] U.S. General Accounting Office, Retirement Income Data: 
Improvements Could Better Support Analysis of Future Retirees' 
Prospects, GAO-03-337 (Washington, D.C.: Mar. 21, 2003).

[6] PBGC receives no direct federal tax dollars to support the single-
employer pension insurance program. The program receives the assets of 
terminated underfunded plans and any of the sponsor's assets that PBGC 
recovers during bankruptcy proceedings. PBGC finances the unfunded 
liabilities of terminated plans with (1) premiums paid by plan sponsors 
and (2) income earned from the investment of program assets.

[7] When a single-employer DB is terminated in accordance with PBGC's 
requirements and with enough assets to pay all of the liabilities of 
the plan, the termination is referred to as a standard termination. 
Plan sponsors typically terminate fully funded plans either by 
purchasing annuities from a private sector insurance company or making 
lump sum distributions to participants that are no smaller than the 
present value of accrued benefits.

[8] See U.S. General Accounting Office, Pension Benefit Guaranty 
Corporation Single-Employer Insurance Program: Long-Term 
Vulnerabilities Warrant 'High Risk' Designation, GAO-03-1050SP 
(Washington, D.C.: July 23, 2003), and Pension Benefit Guaranty 
Corporation: Single-Employer Pension Insurance Program Faces 
Significant Long-Term Risks, GAO-04-90 (Washington, D.C.: Oct. 29, 

[9] We previously reported on the delays and other problems associated 
with the Form 5500. See U.S. General Accounting Office, Retirement 
Income Data: Improvements Could Better Support Analysis of Future 
Retirees' Prospects, GAO-03-337 (Washington, D.C.: Mar. 21, 2003).

[10] A DB plan freeze that creates or increases a potential assets 
reversion to the employer or employers maintaining the plan is deemed a 
partial termination. See IRS Revenue Ruling 2003-65, IRS Bulletin 2003, 
and 26 C.F.R 1.401(a)(26)-2(b).

[11] Aon Consulting Alert, October 22, 2003. Aon's survey included more 
than 1,000 private-sector DB plans.