Project 2025 Tracker / What’s done, what’s next

18. Department of Labor and Related Agencies · Minor

Make PBGC file its annual report on time with fair-market value data

Not started

610 18. Department of Labor and Related Agencies

“The PBGC’s annual report must be submitted on time, and with timely data that uses fair-market value principles to calculate the PBGC’s finances. The PBGC has been submitting portions of statutorily required annual reports many months late and using out-of-date data.”

What has happened

  1. Not started

    The Pension Benefit Guaranty Corporation's reporting got later, not more timely. Its FY2025 Annual Report was transmitted to the President and the Congress on 2026-01-22, more than two months after the November deadline the Corporation met the year before — the FY2024 report went out on 2024-11-14 — and the transmittal letter records that the ERISA section 4008 actuarial report, which is where the valuation of the Corporation's finances sits, "will be issued as soon as practicable". It was issued on 2026-03-03. The Quote's second limb — that the report use fair-market-value principles rather than out-of-date data — was assessed on 2026-09-06 against the FY2025 Actuarial Report itself, and it did not change inside the window either. The Corporation values the present value of future benefits on a market spot-rate curve as of the financial-statement date (4.30 percent at year one for 30 September 2025, rising to 5.71 percent at year 23) with fully generational mortality, and states in terms that "[g]enerally, except for the changes in interest and mortality, we used the same methods and procedures as in fiscal year 2024". The one assumption change it records is the implementation of a pre-window rulemaking — "[s]tarting in fiscal year 2025, PBGC updated the DOPT plan valuation assumptions to comply with the final rule issued June 6, 2024". So there is no in-window switch to fair-market valuation to level on, and the ask stays live on its first limb, where the record moved the other way.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • “Moved the other way” under §3b: the Status stays not started and the dated Primary Evidence shows the direction of travel. The comparison is like for like — the FY2024 transmittal letter (https://www.pbgc.gov/documents/fy-2024-annual-report-transmittal-letters) is dated 1 November 2024 in its own text as “NOV 14 2024”.
  • The FY2025 Actuarial Report’s own PDF metadata gives its creation date as 2026-03-03 (pdfinfo on https://www.pbgc.gov/sites/default/files/documents/2025-actuarial-report.pdf, title “Fiscal Year 2025 Actuarial Report”), against 2025-01-06 for the FY2024 edition.
  • Second limb assessed 2026-09-06 (read-queue ticket 07). The FY2025 Actuarial Report (23 pages, PDF title “Fiscal Year 2025 Actuarial Report”, created 2026-03-03) was read at pbgc.gov/sites/default/files/documents/2025-actuarial-report.pdf. Its “Overview of Valuation Results” and “Actuarial Assumptions, Methods, and Procedures” sections are the answer: PBGC’s liability measure is already market-consistent — a curve of spot interest factors set at the fiscal year end, fully generational mortality, an expense load of 0.68 percent of benefit liability — and it is unchanged from FY2024. The Corporation therefore neither adopted fair-market-value principles inside the window (it already used a market curve) nor moved away from them, so the second limb produces no dated event and the item is leveled on the first limb alone.
  • The Status is not started and not pre_satisfied, even though the valuation limb was already satisfied on 2025-01-20: §3b’s pre_satisfied rule requires that nothing in the ask remain outstanding, and the timeliness limb is both outstanding and moving the wrong way.
Action
other
Object
PBGC annual report
ID
1682