Mass Withdrawal

Addresses whether, based on an employer's date of withdrawal, that employer is subject to reallocation liability in the event of a mass withdrawal termination.

Addresses a plan sponsor’s obligations when a plan terminates by mass withdrawal, including the payment of benefits to participants in a terminated plan.

This opinion letter declines to provide an opinion on the meaning of “substantially all” for the purposes of determining whether a substantially all mass withdrawal has occurred.

Addresses the relevance of events occurring after a plan’s reallocation record date on the reallocation liability calculation.

PBGC must be given a multiemployer plan’s notice of merger.

Review of rules governing plan administration after mass withdrawal; modification of withdrawal liability payment schedules; and recharacterization of contributions as withdrawal liability payments.