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Presidential Memorandum

Providing an Order of Succession Within the Pension Benefit Guaranty Corporation

This memorandum establishes a new order of succession for the Pension Benefit Guaranty Corporation (PBGC), designating the Chief Financial Officer, Chief Management Officer, and General Counsel to act as Director if that position becomes vacant. It revokes a 2013 Obama-era memorandum that had previously established the succession order.

Impact dates

  1. Publication in Federal Register

Key directives

  • Establish order of succession: CFO, then CMO, then General Counsel
  • Revoke February 1, 2013 presidential memorandum
  • Authorize and direct publication in Federal Register

Who is ordered

Timeline

Immediate

  • New succession order takes effect upon signing
  • 2013 memorandum revoked immediately

Near term (90d)

  • Director of PBGC to publish memorandum in Federal Register

Long term

  • Succession rules remain in place until superseded by future presidential action

Risks & tensions

  • Minimal substantive tension; routine administrative update to succession planning
  • Potential uncertainty if acting officers are ineligible under Federal Vacancies Reform Act
  • Preservation of presidential discretion to depart from this order may create ambiguity in practice
Presidential Memorandum: Providing an Order of Succession Within the Pension Benefit Guaranty Corporation · Executive Orders