| 78-13 |
| June 30, 1978 |
| REFERENCE: |
| 4004(f)(4) Temporary Authority. Waiver of Employer Liability |
| OPINION: |
| We have reviewed your request of April 29, 1975, on behalf of * * *, that the Pension Benefit Guaranty Corporation (the |
| "PBGC") waive, pursuant to Section 4004(f)(4) of the Employee Retirement Income Security Act of 1974 ("ERISA"), the |
| employer liability imposed pursuant to Section 4062 of ERISA as a result of the termination of the * * * Pension Plan. In |
| the course of this review, we have considered the information submitted in connection with the termination of the pension |
| plan, additional written submissions from you, and information presented by you during meetings with PBGC staff. The |
| information submitted concerned the overall financial condition of * * * and the partnership that owned * * * prior to and |
| during the plan termination. |
| Section 4004(f)(4) gives the PBGC authority to waive or reduce employer liability resulting from the termination of a |
| pension plan during the first 270 days after enactment of ERISA if the PBGC determines (1) that the employer was unable |
| as a practical matter to continue the plan and (2) that a waiver or reduction is necessary to avoid unreasonable hardship. |
| We have concluded in this case that the liability of the employer should be reduced, based on the factors and |
| considerations set forth below. |
| * * * located at * * * * * * was an acute care hospital operated by a general partnership, the members of which are * * * * * |
| * and * * * maintained a pension plan for its employees, which was terminated on May 15, 1975. As of the date of plan |
| termination, the value of guaranteed benefits under the plan exceeded the value of plan assets allocable to such benefits |
| by $135,891. Consequently, pursuant to Section 4062 of ERISA, was liable to the PBGC in that amount. Information |
| submitted to PBGC shows that in 1973 the employer failed to make a contribution of $45,000 to the plan. In 1974 it made |
| a contribution of only $24,150, and for the four months of 1975 that the plan was in effect it made no contribution. In light |
| of the facts set forth below, the PBGC has determined that * * * was not able, as a practical matter, to continue its |
| At the time of plan termination, * * * was in a declining financial condition with scant prospects for a financial turnaround. |
| Specifically, * * * was located in a rapidly declining inner-city neighborhood of * * *. The hospital has stated that: "Because |
| of the change in the background of the residents of the area surrounding the hospital there has been a sharp decline in |
| patient census." Added to the effect on patient census produced by demographic changes in the area was the fact that |
| there was a surplus of hospital beds in the * * * metropolitan area. This decline in patient census resulted in a relative |
| decline in cost reimbursements from Blue Cross, Medicaid and Medicare (the principal source of hospital revenues), and as |
| a consequence, * * * had experienced operating losses during three of the four years preceding plan termination; also the |
| hospital earned no return on assets during this period. |
| Other factors, too, show a declining financial condition. In slightly more than three years preceding plan termination |
| (December 31, 1971 - March 31, 1975), * * * working capital declined from a deficit of $70,464 to a deficit of $138,012. |
| While the current ratio remained essentially the same during this period (approximately .81), the quick ratio declined from |
| .73 to .58. It further appears that at the time of plan termination, * * * could not obtain bank credit since it was not |
| profitable and had a negative cash flow. Finally, it is noted that the equity account of the partnership itself was in a deficit |
| position during the four-year period preceding termination. |
| * * * prospects were made even more bleak by the fact that due to the age of the hospital, the facility was not in |
| compliance with applicable * * * Department of Health requirements. * * * has alleged that it would have been necessary to |
| construct a new facility in order to achieve compliance with the * * * standards. At the time of plan termination, * * * was |
| operating under a temporary waiver granted by the State Department of Health. |
| In light of the above, it is apparent that at the time of plan termination * * * financial condition was precarious, and it |
| appeared unlikely that the hospital would be able to restore profitability and a sound financial condition. This very poor |
| financial condition existed independently of the imposition of any employer liability under Section 4062 of ERISA. It |
| follows that the waiver or reduction of this liability would not appreciably improve this gloomy financial forecast. As noted |
| above, a prerequisite to granting relief under Section 4004(f)(4) of ERISA is a finding that a waiver or reduction of liability |
| is necessary to avoid unreasonable hardship. |
| However, in determining what is an "unreasonable hardship," we are mindful of the fact that in the instant matter, because |
| we are dealing with a general partnership and not a corporation, any liability imposed by PBGC will ultimately be borne by |
| the partners directly; the liability does not rest solely with a business entity - a corporation. Because of the personal |
| liability of general partners for partnership debts, we believe that consideration must be given to the impact of the |
| imposition of employer liability on the partners themselves, and not just on the business entity operated by the |
| partnership. n1 In this connection, we note that the business operated by the partnership was losing money, and that the |
| two general partners were incurring further liabilities. As of the date of plan termination, the partnership deficit was |
| $125,000. Imposition by the PBGC of employer liability in the amount of $135,891 would obviously substantially increase |
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n1 This conclusion is limited to the facts of this case. We need not and we do not decide at this time whether, in the case |
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of a limited partnership or a corporation owned by a few people, we would look beyond the business entity involved to the |
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individuals who control that entity in order to apply the "unreasonable hardship" test of Section 4004(f)(4). Turning to the |
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financial condition of the partners, it appears that as of the date of plan termination, (who held 95 percent of the |
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partnership) had a net worth of $ * * * net of partnership deficit. At that time, * * * was nearly * * * years old and was |
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employed as of the hospital. (* * * was not, however, a participant in the pension plan.) Because of * * * age, it would be |
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reasonable to assume that * * * future earning potential was rather limited, and that therefore she would be forced to rely |
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on * * * savings in order to support herself in the future. It also appears that * * * is a few years older than * * *, and it is |
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possible that * * *, too, will have to rely on * * * savings for * * * furture support. |
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Finally, consideration should be given to the purpose of Section 4004(f)(4) in the context of the statutory scheme created |
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by Congress. Specifically, Congress recognized that the imposition of employer liability, even though limited to thirty |
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percent of an employer's net worth, could create hardship. In order to minimize this hardship, Congress, in Section 4067, |
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gave the PBGC authority to permit deferred payment of employer liability. Additionally, in providing in Section 4004(f)(4) |
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for the waiver or reduction of liability with respect to plan terminations occurring during the first 270 days after enactment |
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of ERISA, Congress obviously intended to provide even greater relief from the hardship employers might have |
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experienced during the early days of the new law. |
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The PBGC has adopted a flexible approach in permitting deferred payment of employer liability pursuant to Section 4067, |
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and we recognize that similar flexibility is appropriate in fashioning relief under Section 4004(f)(4). Under the former |
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provision, in the case of a corporate employer with capital value of some $550,000, the PBGC would typically permit |
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deferred repayment of a liability of $135,000. We would not require the liquidation of twenty-five percent of the |
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corporation's capital assets in order that it could pay its employer liability immediately; rather, an attempt would be made |
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to enable the employer to finance the payment of employer liability more from income. This is achieved by permitting |
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payments to be spread over a period of years, typically no more than ten. Similar equitable considerations should be |
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taken into account in determining the amount of a reduction in employer liability under Section 4004(f)(4). |
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In view of the foregoing factors, the PBGC has determined that it should reduce the $135,891 liability of * * * * * * Hospital |
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by $50,000, in order to avoid unreasonable hardship. By waiving this amount, the remaining liability under Section 4062 is |
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$85,891. n2 |
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n2 We note that this liability is probably close to the amount of contributions that the employer failed to make to the |
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pension plan during the 1973-1975 period. |
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This constitutes the final action of the PBGC with respect to the request of * * * for a waiver, pursuant to Section |
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4004(f)(4) of ERISA, of its employer liability under Section 4062. |
|
Matthew M. Lind |
|
Executive Director |