It's not an organized process; it's a free for all.

Experience tells me that as long as you allow comments to dribble in, you are going to have problems.

There are holes (in the regulations) the size of the Black Canyon.

If it's frozen when you start, then it's kind of hard.

Unfortunately, the financial health of the PBGC is not improving,

Despite a strong economy, pension plans are reporting even larger shortfalls than last year. Clearly we need new rules that will require companies to fund the pension promises they make,