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Withdrawal Liability

  • Opinion Letter 91-007

    Addresses the ability of an employer challenging its withdrawal liability assessment, to raise additional issues for review by the multiemployer plan, or in arbitration, after making its initial submission.

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  • Opinion Letter 90-001

    Addresses whether a withdrawal from a multiemployer plan will be triggered by various circumstances occurring after a 4204 sale of assets such as a second subsequent sale or a change in corporate structure.

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  • Opinion Letter 86-017

    Addresses whether a partial withdrawal occurs when an employer outsources work to a third party.

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  • Opinion Letter 87-001

    Addresses the circumstances under which a bankruptcy proceeding may give rise to withdrawal liability.

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  • Opinion Letter 94-005

    Addresses whether the amount of a multiemployer plan’s unfunded vested benefits may be retroactively corrected when a computational error resulted in overassessment and overpayment of withdrawal liability.

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  • Opinion Letter 88-008

    Addresses determining the date of a construction industry employer's withdrawal from a multiemployer plan in the context of a labor dispute.

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  • Opinion Letter 85-027

    Discusses how pre-MPPAA withdrawals affect the calculation of the annual withdrawal liability payment.

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  • Opinion Letter 86-024

    Addresses (1) whether vested ancillary benefits may be included in the calculation of unfunded vested benefits; (2) the meaning of "nonforfeitable benefit"; (3) what actuarial assumptions may be used to calculate unfunded vested benefits.

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  • Opinion Letter 84-009

    Provides guidance on the meaning of "employer" with respect to withdrawals from multiemployer pension plans; focuses on the garment industry and in particular, the work done by the contractor and the jobber/manufacturer.

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  • Opinion Letter 83-021

    Addresses the definition of the term "building and construction industry" for purposes of the construction industry exception to withdrawal.

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