We also continue to see enhanced protection for plan members that recognizes more fully the character of
pension benefits as deferred compensation that requires greater recognition as secured debt of the company and enhanced consideration in the creditor hierarchy. Consistent with earlier submissions to the Department of Finance, we contend that deliberate clarification is required regarding
the following: the ownership and distribution of surpluses on plan termination, letters of credit, the time span for the funding of deficits, and
...[+++] the prescribed solvency ratio levels.