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

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Date Issued

Thursday, March 27, 2025

Submitting OIG

Pension Benefit Guaranty Corporation OIG

Agencies Reviewed/Investigated

Pension Benefit Guaranty Corporation

Report Number

EVAL-2025-08

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 8 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
2025-08-01	No	$0	$0
Develop written procedures that clearly define the responsibilities of the federal review process.
2025-08-02	No	$0	$0
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.
2025-08-03	No	$0	$0
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.
2025-08-04	No	$0	$0
Define specific and measurable risk tolerances for changes in key elements and develop related review procedures.
2025-08-05	No	$0	$0
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.
2025-08-06	No	$0	$0
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.
2025-08-07	No	$0	$0
Develop and document an approach for strategic risk assessments of the ASOC review program.
2025-08-08	No	$0	$0
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.