PBGC’s Special Financial Assistance Program’s Policies and Procedures for the Annual Statement of Compliance Need Improvement

Conduct a strategic risk assessment to determine the most cost-effective approach to ensuring compliance with ARP and PBGC regulations. This assessment should consider factors such as the number and size of the plans submitting ASOCs and the 30-year duration of the program.

Develop and document an approach for strategic risk assessments of the ASOC review program.

Implement a formal process that identifies roles and responsibilities, including information sharing, and cooperation with DOL and Treasury to improve SFA oversight and compliance over the Reinstatement of Benefits.

Design specific procedures to ensure (1) appropriate in-depth analysis and review of exceptions, and (2) ensure the review and decision-making process for exceptions and historical data is fully documented in the ASOC workbook.

Define specific and measurable risk tolerances for changes in key elements and develop related review procedures.