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  • Opinion Letter 90-03

    Once irrevocable commitments are purchased, PBGC no longer guarantees the benefits.

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  • Opinion Letter 77-151

    Not appropriate to charge against plan assets legal fees arising from plan termination.

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  • Opinion Letter 93-01

    The obligation to pay premiums ceases when plan assets are distributed under priority categories 1- 6 without regard to whether there are residual assets.

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  • Opinion Letter 75-31

    A proposed plan distribution must be in compliance with § 4044 regardless of whether the IRS has issued a determination letter regarding a plan termination. IRS cannot issue an exception to section 4044.

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  • Opinion Letter 75-89

    Conversion from a covered plan to an individual account plan is a termination.

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  • Opinion Letter 86-27

    PBGC disapproves proposed plans that an employer wishes to adopt because they would effect an impermissible continuation of terminated plans for which guaranteed benefits are being paid.

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  • Opinion Letter 81-10

    A plan that in practice met the criteria for tax qualification for five years prior to its termination date was covered under Title IV at plan termination.

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  • Opinion Letter 87-06

    All affected parties may submit comments to PBGC on a proposed distress termination.

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  • Opinion Letter 80-22

    Discusses the rules governing plan termination and notes that the employers may owe withdrawal liability.

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  • Opinion Letter 81-20

    The sale by a parent corporation with a division that maintains a pension plan with nonforfeitable benefits which are not funded of $1 million or more of an incorporated subsidiary, irrespective of its relative size, results in a reportable event.

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