| 78-24 |
| October 27, 1978 |
| REFERENCE: |
| 29 CFR 2605. Guaranteed Benefits |
| 4022(a) Benefits Guaranteed. Type of Benefits Guaranteed |
| 4044 Allocation of Assets |
| OPINION: |
| This is in response to your letter requesting reconsideration of our opinion of May 23, 1978, concerning the treatment to be |
| accorded benefits payable to the beneficiaries of * * * We stated that * * * death benefit must be treated as a liability that |
| arose prior to the plan termination and as such is payable out of plan assets prior to the allocation of assets under Section |
| 4044 of the Employee Retirement Income Security Act ("ERISA"). We have considered the arguments raised in your letter |
| of June 19, 1978, but must reaffirm our earlier opinion. |
| You have characterized the death benefit here as an annuity that is subject to the limitations applicable to guaranteed |
| benefits. Section 2605.3 of the regulations provides that a benefit is guaranteed if (a) the benefit is nonforfeitable; (b) the |
| benefit qualifies as a pension benefit; and (c) the participant is entitled to the benefit. The * * * death benefit is not |
| guaranteed because it does not qualify as a pension benefit. Section 2605.2 defines a pension benefit as "a benefit |
| payable as an annuity . . . which payments. . . provide a substantially level income to the recipient." The thrust of the |
| guaranteed benefits regulation is the protection and maintenance of nonforfeitable retirement income for participants and |
| their dependant survivors. Most pension plans are built around a level annuity commencing at retirement and payable for |
| the life of the participant. Some plans, however, have provisions (e.g., integrated benefits) or retirement options (e.g., |
| joint and survivor annuities) that result in payments that are not level over the lifetime of the participant. The definition of |
| a pension benefit in the final regulation reflects these plan variations by providing for "substantially" level income. |
| The fundamental concept of a guaranteed benefit is that of a life income for a retired participant. Survivor benefits are |
| guaranteed if they relate to the retired participant's pension benefit. Some plans provide that if a participant dies prior to |
| retirement, the survivor is entitled to a pension. If such death benefits are in pay status when the plan terminates, they |
| are guaranteed. Similarly, a disability benefit is guaranteed because it provides income maintenance for a participant. |
| Payments in a lump-sum (or substantially so) provide no assurance of on-going income and therefore do not conform to |
| the fundamental concept of a guaranteed benefit. The * * * death benefit was payable, at the election of the employer, in |
| a lump sum or in up to five annual installments. While such payments might meet the regulation's definition of an annuity, |
| they were not intended as maintenance income for the recipients and certainly do not provide a substantially level income |
| for the beneficiaries. The payment terms were simply an administrative and financial convenience for the employer. |
| You further contend that the * * * benefit, whether or not it is guaranteed, is subject to the Section 4044 allocation. |
| According to your analysis of ERISA's legislative history, the only permissible reduction of plan assets before application |
| of the allocation rules is "for investment liabilities such as mortgages and commercial borrowings." |
| Section 4044(a) provides that, in the event of the termination of a defined benefit plan, the assets of the plan that are |
| available to provide benefits shall be allocated among the participants and beneficiaries of the plan in accordance with |
| defined priorities. The phrase "available to provide benefits" is not further defined in the statute, and the legislative history |
| provides only limited guidance in interpreting the phrase. However, references to plan liabilities in the legislative history |
| indicate that assets needed to satisfy obligations that arose prior to the plan's termination are not to be considered |
| available for allocation on the date of termination. It is our view that benefits due before the date of termination are such |
| obligations and must be met from plan assets before the Section 4044 allocation. * * * died two years prior to the proposed |
| date of termination of the * * * (the "Plan"). Subsection 6.4 of the Plan's Death Benefits section provides that if a |
| participant dies prior to retirement but after reaching retirement age, his beneficiaries would receive the actuarial reserve of |
| his retirement income. Thus, at death, a liability arose against the Plan for a fixed amount (i.e., his actuarial reserve) and |
| the Plan assets needed to satisfy that liability should have been earmarked. The fact that the Plan Administrator chose to |
| pay the death benefit in installments rather than in a lump sum does not change the nature of the liability. |
| It is, therefore, our opinion that the assets needed for the * * * benefit are not "abailable to provide benefits" and must be |
| deducted from the Plan's assets before the Section 4044 allocation is undertaken. We understand that the litigation |
| regarding the * * * life insurance benefit has been settled. The parties have agreed that * * * already received by the |
| beneficiaries shall be credited against the death benefit. Thus, the amount still owed the beneficiaries by the Plan is to be |
| Please do not hesitate to contact us if you have further questions or comments. |
| Mitchell L. Strickler |
| Deputy General Counsel |