| 87-11 |
| October 22, 1987 |
| REFERENCE: |
| 4044(a) Allocation of Assets. Requirement of Following Statutory Allocation Provisions |
| 4044(a)(6)All Other Benefits Under the Plan |
| 4044(d) Allocation of Assets. Distribution of Residual Assets |
| 4044(d)(1) Allocation of Assets. Distribution of Residual Assets to Employer |
| OPINION: |
| This is in response to your request for an opinion concerning the benefits to which the plan administrator of a terminated |
| single-employer defined benefit pension plan must allocate assets under Section 4044(a) of ERISA before any residual |
| assets may be distributed to the employer pursuant to Section 4044(d). You specifically asked whether Section 4044(a)(6) |
| requires the payment of any benefits that participants have not accrued by the date of plan termination, but to which they |
| might have become entitled in the future if the plan had not terminated and they had continued working in covered |
| The facts, as we understand them from your request, are as follows. * * * is terminating two defined benefit pension |
| plans, the Retirement Benefit Plan for Salaried Employees of * * * Incorporated and the * * * Incorporated Retirement |
| Income Plan for Hourly-Rated Employees (collectively, the "Plans"). The respective dates of termination are April 30, |
| 1987, and June 30, 1987. The plan administrator proposes to annuitize benefits under the Plans by purchasing group |
| annuity contracts from an insurance company in consideration of the payment of a one-time premium for each contract. |
| All benefits accrued under the Plans as of their respective dates of termination will be guaranteed under the annuity |
| contracts as the unconditional, irrevocable and noncancellable obligation of the insurance company from which the |
| contracts will be purchased. The annuity contracts will provide for all optional forms of benefit payments available under |
| the Plans, as well as early retirement benefits, other benefits protected from cutback by Section 301(a) of the Retirement |
| Equity Act of 1984, and preretirement survivor annuities. Early retirement benefits in amounts based on the participants' |
| accrued benefits as of the date of plan termination will be provided under the annuity contracts to participants who then |
| meet the age and service requirements for the subsidy or who will meet those requirements in the future. If the insurance |
| company fails to pay benefits at the time or in the manner set forth in the Plans and the annuity contracts, affected |
| participants will have a cause of action against the insurance company to enforce the payment of benefits. |
| Section 4044(a) of ERISA governs the allocation of plan assets to plan benefits in the case of the termination of a single- |
| employer pension plan. Plan assets must be allocated in succession to the benefits described in each of the six priority |
| categories established in Sections 4044(a)(1) through (a)(6). Section 4044(d)(1) of ERISA provides that any residual |
| assets remaining after satisfaction of all benefits in priority categories 1 through 6 of Section 4044(a) may be distributed |
| to the employer if all liabilities of the plan to participants and their beneficiaries have been satisfied, the distribution does |
| not contravene any provision of law, and the plan provides for such a distribution in these circumstances. Each of the |
| Plans you submitted with your request satisfies the second and third of these conditions. |
| After assets have been allocated to the benefits assigned to priority categories 1 through 5 of Section 4044(a), Section |
| 4044(a)(6) requires that the remaining assets be allocated to the payment of "all other benefits under the plan." Under the |
| PBGC's regulation on the Allocation of Assets to Benefit Categories (29 C.F.R. Part 2618, Subpart B), "the benefits |
| assigned to priority category 6 with respect to each participant are all of the participant's benefits under the plan, whether |
| forfeitable or nonforfeitable." 29 C.F.R. § 2618.16. As the PBGC explained in the preamble to the proposed form of the |
| regulation, "priority category 6 will contain the value of accrued forfeitable benefits of a participant." 40 Fed. Reg. 51368, |
| 51370 (Nov. 4, 1975). The PBGC accordingly construes Section 4044(a)(6) to include only accrued benefits, or, in the |
| case of subsidies protected by the Retirement Equity Act, benefits to which participants may become entitled in the |
| future. n1 See, e.g., Opinion Letters 86-1 (Jan. 15, 1986), 85-28 (Dec. 2, 1985), 85-9 (April 5, 1985). |
| n1 ERISA, as amended by the Retirement Equity Act, requires the payment of early retirement benefits and retirement- |
| type subsidies "with respect to benefits attributable to service before" plan termination. 29 U.S.C. § 1054(g); see 26 |
| U.S.C. § 411(d)(6). In the case of a retirement-type subsidy, ERISA requires such payments of benefits accrued at the |
| date of plan termination to any participant who meets, either before or after plan termination, the pretermination conditions |
| for the subsidy. Id. Assets accordingly must be allocated under Section 4044(a) to the payment of these benefits. Section |
| 4044(a) does not create benefit entitlements not otherwise provided for elsewhere in ERISA or under the plan. ERISA |
| does not require benefit accruals per se based on service not actually completed under a plan. Moreover, the Plans that |
| are the subject of your request for an opinion do not provide for the present award of benefit accrual credit based on hours |
| of service not yet completed, nor for the payment, either before or after plan termination, of "unaccrued benefits" based |
| on such unearned service. Section 4044(a)(6) accordingly does not require the allocation of assets to pay benefits that |
| might have accrued in the future if the Plans had not terminated and the participants had continued performing covered |
| service. Consequently, such "unaccrued benefits" cannot be considered "liabilities of the plan to participants and their |
| beneficiaries" under Section 4044(d)(1). |
|
You should be aware that panels of the United States Courts of Appeals for the Fourth and Eleventh Circuits, |
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respectively, have decided otherwise in Tilley v. Mead, 815 F.2d 989 (4th Cir. 1987) and Blessitt v. Dixie Engine Co., No. |
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86-8123 (11th Cir. June 1, 1987), although both cases are currently pending on petitions for rehearing. In each of these |
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cases, the PBGC has filed an amicus curiae brief in support of rehearing. |
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I hope this letter is of assistance. If you have further questions on this matter, please contact Jeanne Beck of my staff |
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at the above address or at (202) 778-8824. |
|
Gary M. Ford |
|
General Counsel |