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Unfunded vested benefits

Opinion Letter 82-34

Pension Benefit Guaranty Corporation 82-34 November 10, 1982 RE FERENCE: [*1] 4 211 Withdrawal Liability4211(b )(1) Withdrawal Liability - Computation OP INION: This responds to your inquiry on the operati on of the presumptive method of allocation under § 4211 of theMultiemploy er Pensi on Plan Amendments Act of 1980.

Opinion Letter 82-14

Pension Benefit Guaranty Corporation 82-14 April 20, 1982 RE FERENCE: [*1] 4211(b)(3) Withdrawal Liability - Proportional Fraction421 2(a) Obligation to Contribute - Definitions OP INION: This r esponds to your letter pertaining to methods for computing employer withdrawal li ability under theMultiemploy er Pension Plan Amendm ents Act of 1980 (the "Act").

Opinion Letter 94-05

Pension Benefit Guaranty Corporation 94-5 Septembe r 27, 1994 RE FERENCE: [*1] 4 211 Withdrawal Liability >29 CFR 2644 .2(d)> OP INION: I writ e in response to your letter requesting clarification o f PBGC Opinion Letter 90-2 to the extent it addressescalc ulation of unf unded vested benefits for purposes of section 4211 of the Employee Ret irement Income Securit y Actof 1974, as amended ("ERISA"). There, we wrote that the value of unfunded vest ed benefi ts cannot be modifiedretroa ctively if the plan's actuary later finds an error in its calculation.

Simplified Methods for Applying the Requirement to Disregard Benefit Reductions in Determining Withdrawal Liability - Multiemployer Pension Plans - Pension Protection Act of 2006

Section 432(e)(9) of the Internal Revenue Code ("Code"), added by the Pension Protection Act of 2006, directs PBGC to provide guidance on simplified methods for the application of the statutory requirement that multiemployer plans in critical status disregard certain benefit reductions in determining the plan's unfunded vested benefits for purposes of determining an employer's withdrawal liability under section 4201 of ERISA. This Technical Update provides such guidance.

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