Comments & Letters

PRC letter in support of the Pension Accountability Act (October 22, 2015)
The Pension Rights Center sent a letter to U.S. Senator Rob Portman (R-Ohio), expressing its support for Senator Portman’s Pension Accountability Act (S. 2147). Read the letter here [PDF]. Related: PRC’s summary of the Pension Accountability Act An op-ed by Sen. Portman about the Pension Accountability Act in the Plain Dealer (October 9, 2015) PRC’s fact sheet on […]

PRC comments to Treasury on rules for retiree benefit cuts in financially troubled multiemployer pension plans (August 18, 2015)
The Pension Rights Center submitted comments to the Treasury Department regarding its rules for retiree benefit cuts in severely underfunded multiemployer plans, as authorized by the Multiemployer Pension Reform Act of 2014. Our comments focus on improving the proposed regulations to better protect retirees in the following areas: Plan eligibility to suspend benefits; Post-suspension maintenance […]

PRC comments to PBGC on partition rules for financially troubled multiemployer plans (August 18, 2015)
The Pension Rights Center submitted comments to the Pension Benefit Guaranty Corporation (PBGC) regarding its rules for partitions in severely underfunded multiemployer plans, as authorized by the Multiemployer Pension Reform Act of 2014. The Center’s comments focus on five issues that most directly affect participants in plans that are seeking partition: The content of the […]

PRC comments to DOL on its proposed fiduciary rule (July 21, 2015)
The Pension Rights Center submitted comments to the Department Labor on its proposed rules governing conflicts of interest in investment advice for retirement plans. Related: Financial Illiteracy Meets Conflicted Advice: The Case of Thrift Savings Plan Rollovers — a draft paper cited in our testimony (May 2015) Save Our Retirement coalition’s statement after an initial review […]

PRC comments to IRS on revenue procedures related to recoupment (July 20, 2015)
The Pension Rights Center submitted comments to the Internal Revenue Service regarding Revenue Procedure 2015-27 and Revenue Procedure 2013-12, both of which address corrective action that pension plans should take when they overpay retirees. The Center discusses the financial hardships caused by “recoupment” — when a plan overpays a retiree and demands repayment — and offers […]

PRC letter to Pensions & Investments responding to editorial about the Keep Our Pension Promises Act (July 13, 2015 — UPDATED)
The Pension Rights Center sent a letter to the editor of Pensions & Investments, in response to its negative editorial on the Keep Our Pension Promises Act of 2015. The text of the letter as published is below. Your June 29 editorial, “Defying economic reality,” does your readers a disservice by failing to accurately inform […]

Comments to the White House Conference on Aging on its Retirement Security Policy Brief (July 7, 2015)
The following comments were submitted to the White House Conference on Aging on its Retirement Security Policy Brief, in advance of the Conference’s 2015 meeting on July 13. According to the Center for Retirement Research at Boston College, the nation is facing a $7.7 trillion Retirement Income Deficit, which is the gap between what […]

PRC Comments to Treasury on the Multiemployer Pension Reform Act of 2014 (May 26, 2015)
The Pension Rights Center sent comments [PDF] on the retiree cutback provisions of the Multiemployer Pension Reform Act of 2014 to the Treasury Department in response to its Request for Information. Additional resources Our summary of the retiree pension cutback provisions in the spending bill. Our fact sheet on multiemployer plan funding in general (May 29, 2014) Related […]

PRC Comments to the PBGC on partitions and mergers in multiemployer pension plans (April 15, 2015)
The Pension Rights Center submitted comments to the Pension Benefit Guaranty Corporation in response to its Request for Information on partitions and mergers in certain underfunded multiemployer plans.

PRC letter to Congress opposing “stealth” provisions that would cut retiree benefits in multiemployer plans (December 3, 2014)
The Pension Rights Center sent a letter to every member of Congress, urging them to oppose measures that would allow certain multiemployer plans to cut the earned benefits of retirees. Such a provision might be slipped into the omnibus spending bill without public debate during the lame-duck session of the 113th Congress. Not only is […]

PRC letter to OMB, supporting the collection of additional information from terminating pension plans (November 18, 2014)
The Pension Rights Center sent a brief letter to the Office of Management and Budget in support of the Pension Benefit Guaranty Corporation’s request to require additional information from terminating defined benefit plans. The PBGC’s request includes the Center’s recommendation from July that plans provide an accurate list of annuity providers and list the participants […]