“Further PBGC Premium Increases Pose Greatest Threat to Pension System,” recently released by the American Benefits Council, finds that PBGC premiums are disproportionately high already and that further increases could force employers out of the DB plan system and erode the PBGC’s premium base.

The report’s authors point out that premiums have increased substantially over the past decade or so. Specifically, between 2005 and 2016, the flat rate or per-participant premium is expected to more than triple, from $19 to $64 per participant. In addition, the variable rate premium is expected to more than triple, from $9 per participant per $1,000 of unfunded vested benefits to at least $29 per participant, during the 2012 to 2016 time period.

The increases translate to “real and significant liabilities for employers and ultimately for employees,” according to the report. While the rationale given for these premium increases, by Congress, is to avoid short-run liquidity problems, the report finds that the PBGC holds enough assets to pay all benefits to participants in terminated single-employer defined benefit pension plans for many years into the future.

In addition, the report finds that proposed premium increases would impose an estimated $2 billion per year of additional costs on employers in the single-employer DB plan system by fiscal year 2024. Over the short run, employers may address these costs by reducing capital investments or reducing dividends paid to shareholders.

“All available data refutes the notion that the PBGC’s single-employer guarantee program needs additional premium revenue,” contends American Benefits Council President James A. Klein, based in Washington, D.C. “The agency’s self-reported deficit belies the fact that PBGC’s assets and income far exceed its foreseeable payouts.”

The report also finds that:

• Artificially low interest rates inflate purported underfunding of pension plans and the PBGC’s self-reported deficit. More than 96% of PBGC’s own reported deficit estimates relate to plans that have already exited the DB plan system. So, current sponsors of plans that pose no risk to the PBGC are forced to pay for the actions of employers who long ago terminated their plans.

• Double counting of PBGC premium increases perpetuates long-term deficit spending. Policymakers perpetuate long-term deficit spending by, in effect, “double counting” premium increases (which can legally only be used by the PBGC) for general revenue purposes, thereby offsetting spending for completely unrelated matters.

• The mandatory nature of the PBGC program effectively gives employers only one choice to avoid burdensome premiums, which is to exit the system by de-risking. Employers lack a competitive market for the service provided by the PBGC. The only options available to plan sponsors to reduce the burden of PBGC premiums are to reduce risk through buyouts and other measures, or exit the DB plan system completely.

• The PBGC premiums represent taxes on employees. While employers face the statutory incidence of these taxes, the impact is ultimately felt by employees if the result is to compel employers to freeze or terminate the DB plan.

Klein adds, “The same abnormally and artificially low interest rates that are inadvertently punishing pension plan sponsors are also distorting the true financial position of the PBGC. We urge lawmakers to avoid a third consecutive year of premium hikes and focus instead on making it easier for employers to stay in the system.”

Revised figures about participant longevity, when combined with potential premium increases, could also negatively affect the DB plan system, according to the report. New mortality tables generated by the Society of Actuaries show that plan participants are living longer. Once the Internal Revenue Service approves these new tables, pension liabilities will significantly increase. As a result, the funding levels of DB plans will decrease, resulting in substantially increased funding requirements and higher PBGC variable rate premiums.

The full text of the report can be downloaded here. The American Benefits Council is a national trade association for companies concerned about federal legislation and regulations affecting all aspects of the employee benefits system.