PBGC's Legal Support: Improvements Needed to Eliminate Confusion
and Ensure Provision of Consistent Advice (18-MAY-07,
GAO-07-757R).
The Pension Benefit Guaranty Corporation (PBGC) insures the
pensions of nearly 44 million private sector workers in over
30,000 employer-sponsored defined benefit pension plans.
Established in 1974 as a self-financing government corporation,
PBGC's primary responsibility is to insure, under statutory
limits, the pension benefits of participants in covered private
defined benefit plans. PBGC collects premiums from the sponsors
of defined benefit pension plans and administers plans that are
terminated for reasons such as plan insolvency or bankruptcy. In
the event of a termination, PBGC assumes control of plan assets,
determines plan benefit liabilities, and pays benefits as
guaranteed by statute. In fiscal year 2006, about 612,000 plan
participants and beneficiaries received $4.1 billion in benefit
payments from PBGC. An additional 659,000 participants in plans
already trusteed by the corporation will receive benefits from
PBGC when they become eligible to retire. An increase in
underfunded plan terminations in recent years increased the
number of plan participants receiving and eligible for benefit
payments. In 2005, PBGC reorganized, creating an additional legal
department called the Office of the Chief Counsel, and placed
this new office under the Chief Insurance Program Officer. The
Chief Counsel was given the responsibility for overseeing legal
issues pertaining to PBGC's core mission functions, such as
negotiations involving terminations resulting from bankruptcies,
while the General Counsel retained responsibility for such
general law issues as ethics, procurement, and personnel law.
Concerns have been raised, however, that this organizational
change, a decentralization of legal functions, has affected the
uniformity of PBGC's legal opinions, because there is no single
chief legal officer ultimately responsible for overseeing all
programmatic or regulatory issues. Because of these concerns, and
in light of PBGC's growing workload, you asked us to examine the
effect the reorganization of the corporation's legal functions
into separate offices has had on PBGC's operations. Accordingly,
we assessed whether the reorganization has (1) clearly defined
the roles and responsibilities of PBGC's legal offices and (2)
ensured that consistent legal advice is provided to the PBGC
Director.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-757R
ACCNO: A69825
TITLE: PBGC's Legal Support: Improvements Needed to Eliminate
Confusion and Ensure Provision of Consistent Advice
DATE: 05/18/2007
SUBJECT: Agency evaluation
Agency missions
Employee benefit plans
Federal agencies
Federal agency reorganization
Insurance
Lawyers
Payments
Pensions
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GAO-07-757R
* [1]PDF6-Ordering Information.pdf
* [2]Order by Mail or Phone
United States Government Accountability Office
Washington, DC 20548
May 18, 2007
The Honorable Max Baucus
Chairman
The Honorable Charles E. Grassley
Ranking Member
Committee on Finance
United States Senate
The Honorable Edward M. Kennedy
Chairman
The Honorable Michael B. Enzi
Ranking Member
Committee on Health, Education, Labor and Pensions
United States Senate
Subject: PBGC's Legal Support: Improvements Needed to Eliminate Confusion
and Ensure Provision of Consistent Advice
The Pension Benefit Guaranty Corporation (PBGC) insures the pensions of
nearly 44 million private sector workers in over 30,000 employer-sponsored
defined benefit pension plans.^1 Established in 1974 as a self-financing
government corporation, PBGC's primary responsibility is to insure, under
statutory limits, the pension benefits of participants in covered private
defined benefit plans. PBGC collects premiums from the sponsors of defined
benefit pension plans and administers plans that are terminated for
reasons such as plan insolvency or bankruptcy. In the event of a
termination, PBGC assumes control of plan assets, determines plan benefit
liabilities, and pays benefits as guaranteed by statute. In fiscal year
2006, about 612,000 plan participants and beneficiaries received $4.1
billion in benefit payments from PBGC. An additional 659,000 participants
in plans already trusteed by the corporation will receive benefits from
PBGC when they become eligible to retire. An increase in underfunded plan
terminations in recent years increased the number of plan participants
receiving and eligible for benefit payments.
Until recently, all of PBGC's attorneys worked in the Office of the
General Counsel. The General Counsel reports to the Director^2 and until
recently had responsibility for all legal matters, from representing PBGC
in bankruptcy and litigation matters, to providing advice on personnel and
procurement law. In 2005, PBGC reorganized, creating an additional legal
department called the Office of the Chief Counsel, and placed this new
office under the Chief Insurance Program Officer. The Chief Counsel was
given the responsibility for overseeing legal issues pertaining to PBGC's
core mission functions, such as negotiations involving terminations
resulting from bankruptcies, while the General Counsel retained
responsibility for such general law issues as ethics, procurement, and
personnel law.^3
^1Defined benefit plans pay specific retirement benefits, generally based
on years of service or earnings or both; the sponsoring company is
responsible for ensuring that plan assets are sufficient to pay
liabilities.
^2Until recently, the PBGC was headed by an Executive Director, but the
Pension Protection Act of 2006 changed the title to Director and provided
for appointment by the President with the advice and consent of the
Senate. Pub. L. No. 109-280, S 411(a), 120 Stat. 780, 935 (to be codified
at 29 U.S.C. S 1302(a)). Throughout this letter, we use the term Director.
The former Director responsible for the reorganization told us that the
new legal structure was meant to align the staff performing PBGC's core
mission-related work with the legal staff supporting that work. It was
also meant to provide additional advancement opportunities for attorneys.
Concerns have been raised, however, that this organizational change, a
decentralization of legal functions, has affected the uniformity of PBGC's
legal opinions, because there is no single chief legal officer ultimately
responsible for overseeing all programmatic or regulatory issues. Because
of these concerns, and in light of PBGC's growing workload, you asked us
to examine the effect the reorganization of the corporation's legal
functions into separate offices has had on PBGC's operations. Accordingly,
we assessed whether the reorganization has (1) clearly defined the roles
and responsibilities of PBGC's legal offices and (2) ensured that
consistent legal advice is provided to the PBGC Director.
We reviewed PBGC's current organizational structure, including its
different legal components, such as the Office of the General Counsel and
the Office of the Chief Counsel. To assess the effect the reorganization
has had on the provision of legal services at PBGC, we reviewed PBGC
memorandums and documents concerning the reorganization and interviewed
the former Director who implemented these changes and the current and
former general counsels and chief counsels. We also interviewed
representatives from PBGC's union and several other management officials.
Because PBGC officials said that its new legal structure was modeled after
that of the Securities and Exchange Commission (SEC), we reviewed SEC
documentation and spoke to an SEC official about that agency's
organizational structure. We conducted our review from November 2006
through April 2007 in accordance with generally accepted government
auditing standards. We provided a draft of this letter to the Department
of Labor and the PBGC for comment.
In summary, the restructuring of PBGC's legal functions into separate
offices has caused confusion over each office's authority. As a result,
PBGC staff has sought advice from both the Office of the General Counsel
and the Office of the Chief Counsel, sometimes in an effort to obtain a
desired response. Further, PBGC officials told us that attorneys from the
Office of the General Counsel have provided legal advice when the Office
of the Chief Counsel had responsibility for the issue, which resulted in
confusion and conflicting opinions.
PBGC's current legal structure does not guarantee that a chief legal
officer has an opportunity to provide advice and views on legal matters,
including those reaching the Director. Currently, the Chief Counsel does
not have a reporting relationship to either the General Counsel or the
Director. In an August 2006 report on a multimillion dollar business
transaction, the Inspector General found that PBGC put itself at risk
because the General Counsel was not informed and did not serve its
function as a check on critical issues. When an organization implements a
decentralized legal structure, all counsel housed in specific business
units typically report administratively to a chief legal officer, such as
a general counsel, who in turn reports directly to the agency head.
^3In addition to the Office of the Chief Counsel, the reorganization
created another legal office, called the Legislative and Regulatory
Department, to monitor and provide legal advice on, and analysis and
drafting of legislative proposals and regulations related to PBGC's
mission.
This letter contains a recommendation to PBGC to provide for all legal
functions to be overseen by a single chief legal officer who reports
directly to the Director. In commenting on a draft of this letter, PBGC
disagreed with our recommendation, stating that a recommendation to adopt
a single law office model was unduly prescriptive. We did not intend for
our recommendation to be read narrowly as endorsing a single law office
model. Rather than endorsing a particular legal structure, we point out
that the legal functions could be organized in different ways, and this
could include a decentralized structure. PBGC also expressed concern that
our report did not sufficiently recognize the improved communication,
coordination, reporting processes and changes to its corporate culture
that it has undertaken. After carefully reviewing its concerns, we
continue to believe that our conclusions and recommendation are well
founded. PBGC's comments are provided in appendix I. We did not receive
formal comments from the Department of Labor however, both PBGC and the
Department of Labor provided technical comments and clarifications, which
we incorporated in the letter as appropriate.
Background
PBGC collects premiums from the sponsors of defined benefit pension plans,
oversees plan terminations, and ensures the proper disbursement of
payments. The corporation charges premiums to defined benefit plan
sponsors, so it may make insured benefit payments to participants in
defined benefit pension plans that terminate with insufficient assets.
Under certain circumstances, PBGC can determine that the termination of an
employer's plan is necessary to protect the interests of plan participants
or of PBGC`s insurance program, for example, if a plan does not have
enough money to pay benefits currently due. In such cases PBGC negotiates
with the plan sponsor to terminate the plan and is routinely appointed its
permanent trustee. The negotiations are often fast-paced, high-pressure
situations that increasingly involve large corporations and millions of
dollars. PBGC's Department of Insurance Supervision and Compliance (DISC)
staff, who manage the negotiations, have extensive financial, actuarial,
and market expertise. DISC's legal support comes from the Office of Chief
Counsel, whose staff has extensive knowledge of bankruptcy and pension
law.
The Office of the Chief Insurance Program Officer, as shown in figure 1,
manages the Office of the Chief Counsel and DISC. DISC monitors the
corporate events and transactions of defined benefit pension plan sponsors
and provides the necessary analyses to enable PBGC to assess its insurance
program. In coordination with the Office of the Chief Counsel, DISC
determines and pursues recoveries of unpaid employer contributions. DISC
also makes recommendations to the Director concerning the filing of liens
and makes recommendations to the Internal Revenue Service concerning
conditions for granting employers waivers of the minimum funding
requirements, which are the minimum amount of assets an employer's defined
benefit plan must hold in order to fund promised benefits. Neither office
reports to or through the Office of the General Counsel.
Figure 1: PBGC's Organizational Chart
The Office of the Chief Counsel provides comprehensive legal services
relating to PBGC's programs involving ongoing and terminated pension
plans. Its attorneys represent PBGC in bankruptcy or insolvency
proceedings, provide legal advice and services to support termination
negotiations and settlements, and make recommendations concerning the
initiation of litigation. Currently, the Office of the Chief Counsel has
50 attorneys.
Since the reorganization, the Office of the General Counsel consists
primarily of attorneys who had previously worked in the general law area
and are tasked with functions related to ethics, procurement, and
personnel law. According to PBGC documents, the Office of the General
Counsel provides the Director and PBGC departments with legal advice and
counsel on general law issues and can provide advice on pension-law
matters at the request of the Director. The Office of the General Counsel
is also responsible for deciding administrative appeals of PBGC decisions
concerning benefit coverage and other determinations. Further, the General
Counsel serves as Secretary to the PBGC's board of directors and keeps
board meeting minutes.^4 The office currently has 27 attorneys.^5
Restructuring Has Resulted in Confusion over Legal Roles and
Responsibilities
The restructuring of PBGC's legal functions has caused confusion within
the corporation over each office's authority. As a result, PBGC staff has
sought advice from both the Office of the General Counsel and the Office
of the Chief Counsel, on the same or substantially similar issues,
sometimes in an effort to obtain a desired response. In addition, PBGC
officials told us that attorneys from both legal offices often provide
legal advice on the same issues, which has resulted in confusion. For
example, early in 2006, PBGC's Chief Financial Officer sent a memo to both
offices requesting advice on an issue involving bankruptcy, and each
office rendered a separate legal opinion. According to PBGC, the Office of
Chief Counsel has responsibility for providing legal advice on issues
involving bankruptcy matters, and the Office of the General Counsel has
responsibility for providing legal services to the Financial Operations
Department. While the legal conclusions of the two memos can be read in
concert, the Chief Counsel's memo appears to reflect some level of
disagreement with the General Counsel's approach to the issue raised. In
another case, involving advice on a benefits issue concerning a specific
pension plan, even though the Office of the Chief Counsel is generally
responsible for providing legal advice to the Benefits Administration and
Payments Department, both legal offices wrote memos to this department,
presenting legal opinions that were in disagreement. After internal
discussions among senior management, PBGC officers followed the advice
presented by the Office of the General Counsel.
Confusion over roles and responsibilities has led to problems for those
outside of PBGC as well. In some cases, external clients, such as
employers that sponsor defined benefit plans, have experienced delays in
receiving advice because they mistakenly sent their legal queries to the
Office of the General Counsel rather than the Office of the Chief Counsel.
For example, according to a PBGC official, an outside attorney contacted
the Office of the General Counsel seeking guidance on a transaction and
was told to submit a written request for a legal opinion. PBGC officials
later agreed that the inquiry should have been sent to the Chief Counsel's
office. Determining internal jurisdiction delayed by about a month PBGC's
analysis of the transaction and its guidance. In another example, the
General Counsel's office was asked for advice regarding a plan that was
seeking relief from its premium payments. An attorney from the Office of
the General Counsel drafted a letter that would have allowed for such
relief. The letter, had it been approved, would have permitted PBGC staff
to stop collecting premiums from the specific plan sponsor, indicating
that PBGC did not cover the plan. However, the Chief Counsel's office
disagreed with the Office of the General Counsel's position, and found
that PBGC did cover the plan. According to a PBGC official, if the plan
sponsor had stopped paying premiums to PBGC, the law would still require
PBGC to guarantee benefits if the plan terminated with insufficient
assets.
^429 C.F.R. S 4002.6 (2006).
^5The Legislative and Regulatory Department currently has 11 attorneys.
In an attempt to clarify the roles and responsibilities of the two legal
offices, PBGC's Interim Director issued a memorandum in January 2007
discussing certain areas of jurisdiction that were not clearly addressed
in the reorganization. To a certain extent, the memo heightened the
confusion because, according to some PBGC officials, the memorandum
reassigned certain functions previously understood to be within the scope
of the Office of the Chief Counsel to the General Counsel's office. For
example, although benefit determinations are made based on legal advice
provided by the Office of the Chief Counsel, the responsibility for
deciding appeals of benefit determinations has been given to the Office of
the General Counsel. The memorandum states that the Office of the General
Counsel is responsible for leading litigation arising from such an appeal.
This is in conflict with PBGC documents that state that the Office of the
Chief Counsel will represent PBGC in litigation in all courts when the
issue involves ongoing and terminated pension plans. PBGC union
representatives also asserted that the memorandum was not consistent with
the union-negotiated reorganization agreements with PBGC management.
According to the union representatives, the reorganization agreements
state that the Office of the Chief Counsel will consist of the group that
had previously been responsible for litigating fiduciary breach and
Appeals Board cases in the pre-reorganization Office of the General
Counsel and do not mention transferring these functions, or any others, to
the post-reorganization Office of the General Counsel. PBGC management
disagreed with the union's views on the Interim Director's memorandum, and
told us that PBGC has not yet finalized how the issues discussed in the
memorandum will be implemented.
Although officials at PBGC have acknowledged that there was confusion
during the initial period of reorganization, they have also indicated that
communication and collaboration among attorneys and clients has improved,
and stated that the potential for future confusion is low. They explained
that in response to the Interim Director's memorandum, PBGC's two legal
offices now participate in biweekly meetings, to coordinate the matters
his memo addressed. According to the officials, these meetings have
enhanced collaboration.
Current Structure Does Not Ensure That Advice of a Chief Legal Officer is
Provided on Significant Legal Issues
PBGC's legal structure does not guarantee that a chief legal officer has
an opportunity to provide advice on significant legal matters, including
those reaching the Director. Organizations that implement a decentralized
legal structure--by having all legal advice from counsel housed in
specific business units pass through a chief legal officer, such as a
general counsel, reporting directly to the agency head--can ensure that
only legal advice that is backed by the chief legal officer reaches the
agency head. However, PBGC's current legal structure fails to give the
Office of the Chief Counsel an independent reporting line to either the
General Counsel or the Director. In a 2006 survey of 186 large
private-sector corporations, 154 corporations reported having attorneys
that were organized in a centralized structure. Eighty-nine percent of
these corporations reported that between "76 and 100 percent" of their
attorneys report directly to a general counsel. In addition, 19
corporations reported having attorneys who were organized in a
decentralized structure. The attorneys report directly to the head of
their business units, with an indirect reporting relationship to a general
counsel.^6 An entity's general counsel commonly reports directly to the
chief executive officer within the management hierarchy.
The Chief Counsel reports to the Chief Insurance Program Officer, a
position that also has responsibility for the high-pressure negotiations
conducted by DISC. Given the high value and risk of these negotiations, an
independent legal voice is important. PBGC officials told us that the lack
of a direct-reporting line is remedied because legal questions can be
discussed in the executive management forum, which includes the Chief
Insurance Program Officer, the Director, and the General Counsel. However,
legal issues raised by the Office of the Chief Counsel may not reach the
Executive Management forum, if the Chief Insurance Program Officer does
not elevate them to that forum. The Chief Insurance Program Officer could
be faced with competing priorities. On the one hand, this official has
staff negotiating high-pressure deals. On the other hand, this official
has attorneys responsible for ensuring that the deals are legally sound.
Under pressure to close the deal, the potential exists for this executive
to make a decision or take an action without airing an important legal
concern before the General Counsel or the Director. However, PBGC
officials noted that the current Chief Insurance Program Officer is an
attorney with the necessary expertise to manage the Office of the Chief
Counsel effectively. They also noted that the position of the Chief
Insurance Program Officer may not always be held by someone with legal
qualifications.
While PBGC documentation requires the General Counsel to review important
transactions, this review does not always occur, which may put the
corporation at risk. For example, in an August 2006 report, PBGC's Office
of Inspector General found that the Office of the General Counsel had not
been substantively involved in a multimillion dollar business transaction,
even though PBGC documentation requires that the General Counsel review
relevant proposed actions requiring approval of the Director. If, during
the fast pace of decision making in negotiations, the Office of the
General Counsel does not review important transactions, gaps in
responsibility and accountability can occur. For example, an
organization's General Counsel can help ensure that attorneys in the
business units maintain their professional independence while providing
specialized legal services.^7 Under the current legal structure, the
Office of the General Counsel cannot realistically be integrally involved
in every aspect of negotiations, and there may be times when the Office of
the General Counsel is not aware of an issue that can result in damage to
the PBGC. The Inspector General found that PBGC put itself at risk because
the General Counsel was not informed, and did not serve its function as a
check on critical issues facing PBGC.
According to PBGC officials, the corporation refined its practices after
this transaction and the report by the Office of Inspector General, and
began coordinating better in a variety of areas. For example, the Interim
Director implemented biweekly meetings on major cases, at which key senior
staff are alerted to major developments that may require their input.
According to PBGC officials, during a subsequent transaction, there was
improved cooperation across all department lines that, according to the
officials, resulted from the implementation of these meetings.
^6The Hildebrandt 2006 Law Department survey was conducted by Hildebrandt
International, a professional services consulting firm. Its benchmarking
survey provides information on legal spending, staffing, management, and
compensation. The median company in its survey is one with approximately
$8 billion in worldwide revenues, 20,000 worldwide employees, and a U.S.
law department with over 20 lawyers and 40 total staff.
^7E. Norman Veasey, and Christine T. Di Guglielmo, "The Tensions,
Stresses, and Professional Responsibilities of the Lawyer for the
Corporation," The Business Lawyer (Vol. 62, Nov. 2006).
The former Director, responsible for the reorganization, told us that the
new legal structure is modeled on that of the SEC. At SEC, there is an
Office of the General Counsel that reports to the SEC Chairman. There are
also several Chief Counsels who are embedded in the various business
units, and they report directly to the department heads--not necessarily
the General Counsel. However, according to an SEC official, it is agency
practice that the Chief Counsels' most important actions are reviewed by
the Office of the General Counsel. In addition, the official also told us
that the heads of the majority of SEC's business units are required to be
filled by attorneys, whereas at PBGC the Chief Insurance Program Officer
position, although currently filled by an attorney, is a general
management position.
Conclusions
The current organization of PBGC's legal functions lacks a clear division
of authority and does not ensure that the Director receives legal advice
directly and with the full support of a chief legal officer. Currently,
there are two distinct legal offices within PBGC, but there is no single
legal voice. The current structure creates confusion for PBGC both
internally and externally, which could seriously affect PBGC's mission.
While PBGC's legal functions could be organized in different ways, we
believe that the lack of a direct reporting line from the Chief Counsel to
the General Counsel or the Director could result in decisions made without
consideration of PBGC's overarching legal concerns. In short, the current
legal structure has resulted in various problems and has the potential to
create additional problems in the future. Therefore, this matter deserves
prompt attention to eliminate such problems.
Recommendation for Executive Action
In order to promote clear lines of authority and the provision of
consistent legal advice, we recommend that PBGC
o provide for all legal functions to be overseen by a single chief
legal officer with full authority to delineate the duties of each
legal office and a direct reporting relationship to the Director.
Agency Comments and Our Evaluation
We provided copies of a draft of this letter to the Secretary of Labor and
PBGC's Interim Director for their comments. The Department of Labor
provided technical comments which we incorporated in our final letter as
appropriate. PBGC provided written comments which are reproduced in
appendix I. In its comments, PBGC stated that it disagrees with our
recommendation, which it characterizes as an unduly prescriptive
recommendation that it adopt a single law office model. We did not intend
for our recommendation to be read narrowly as endorsing a single law
office model. Rather than endorsing a particular legal structure, we point
out that the legal functions could be organized in different ways, and
this could include a decentralized structure. We recommended, and continue
to believe, however, that in determining the most appropriate structure
for providing legal support, PBGC should ensure that all legal functions
are overseen by a single chief legal officer with authority and
accountability for all legal advice provided to the Director and the
various departments within PBGC. Without a single chief legal officer, we
believe that the inconsistency and confusion that we documented in the
report are likely to continue. Indeed, our recommendation is consistent
with the views of four former General Counsels of the PBGC. We interviewed
these individuals, with a combined 28 years of service as General Counsel,
and each of them independently stated that having a chief legal officer
oversee PBGC's attorneys is the best approach for the corporation.
PBGC also expressed concern that our report did not sufficiently recognize
the improved communication, coordination, reporting processes and changes
to its corporate culture that it has undertaken. While we have modified
the report to include these stated changes, we point out that, during our
five month review we saw little evidence of such change. We believe that
the new biweekly meetings implemented by the Interim Director are a step
in the right direction, and involving the General Counsel in the oversight
of major agency decisions is consistent with our recommendation. However,
relying solely on improved cooperation and communication is not an
adequate approach for improving a flawed organizational structure.
In addition to its written comments, PBGC also noted several technical
corrections to the letter, which we incorporated as appropriate.
- - - - -
As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this letter until 30 days
after the date of the letter. At that time, we will send copies of this
letter to the Secretary of Labor, the Interim Director at PBGC, and other
interested parties. We will also make copies available to others on
request. In addition, the letter will be available at no charge on GAO's
Web site at http://www.gao.gov.
If you or your staff have any questions about this letter, please contact
me at (202) 512-7215 or [email protected]. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this letter. Other key contributors to this letter were Blake
Ainsworth, Assistant Director; Monika Gomez; Jason Holsclaw; Kisha Clark;
and Craig Winslow.
Sincerely yours,
Barbara D. Bovbjerg
Director, Education, Workforce, and Income Security
Issues
Appendix I: Comments from the Pension Benefits Guaranty Corporation
(130647)
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