Administration
PBGC’s Special Financial Assistance Program’s Policies and Procedures for the Annual Statement of Compliance Need Improvement (EVAL-2025-08), issued March 27, 2025
The design of PBGC's ASOC policy and procedures is generally sufficient to ensure compliance with ERISA. However, there are a few areas where improvements could enhance the process. First, the absence of clearly defined procedures for supervisory reviews led to discrepancies in ASOC submissions that were not detected and corrected during the review. As a result, some discrepancies in financial data and typographical mistakes were not fully resolved at the time of review. Additionally, PBGC’s approach to reconciling SFA funds could be more comprehensive to reduce the risk of misallocation and delays in identifying issues. The current review procedures also lack specific guidelines and thresholds for identifying significant variances, which might result in potential problems going unnoticed. Furthermore, PBGC’s procedures for monitoring the Reinstatement of Benefits under the American Rescue Plan (ARP) Act could benefit from clearer communication between PBGC, the Department of Labor (DOL), and the Treasury. Finally, PBGC has not yet conducted a risk assessment to evaluate its ASOC review workload, which may present challenges in managing long-term program requirements effectively.
