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

Revise its ASOC review procedures to require an annual reconciliation of SFA funds and to require the review analyst to conduct an analysis of material changes or outliers in the key elements to ensure full compliance with SFA conditions.

Develop written procedures for how errors and discrepancies should be reported, tracked, and resolved, as well as specific criteria for identifying errors or deviations from established standards.

Develop written procedures that clearly define the responsibilities of the federal review process.