| 88-5 |
| April 1, 1988 |
| REFERENCE: |
| 29 CFR 2648 - Redetermination on Mass Withdrawal |
| 29 CFR 2648.3 - Liability on Mass Withdrawal |
| 29 CFR 2648.3(c) - Reallocation Liability 29 CFR 2648.6(b) - Amount of UVBs to be Reallocated |
| 29 CFR 2648.6(c)(2) - Amount of Reallocation |
| OPINION: |
| This is in response to your request for the opinion of the Pension Benefit Guaranty Corporation ("PBGC") regarding the |
| powers of trustees of a multiemployer pension plan under the Employee Retirement Income Security Act of 1974 |
| ("ERISA") and the PBGC's regulation on Redetermination of Withdrawal Liability upon Mass Withdrawal (29 CFR Part 2648) |
| (the "reallocation regulation"). |
| The plan in question has been terminated by the withdrawal of all of its contributing employers. For such a plan, section |
| 4209(c) of ERISA provides that certain withdrawn employers lose the benefit of the de minimis reduction that would |
| otherwise apply to their withdrawal liabilities. Also, section 4219(c)(1)(D) of ERISA requires that the liabilities of withdrawn |
| employers be determined without regard to the 20-year limitation on annual payments under section 4219(c)(1)(B) of ERISA |
| and that the plan's total unfunded vested benefits be fully allocated among the withdrawn employers. The reallocation |
| regulation implements these provisions. |
| Under the reallocation regulation, the withdrawal liability that is assessed without regard to the fact that there has been a |
| mass withdrawal termination is called "initial withdrawal liability." The term for the additional withdrawal liability that arises |
| from the fact that the de minimis reduction and the 20-year payment limitation do not apply is "redetermination liability." |
| Finally, the liability arising from the requirement for full allocation is referred to in the reallocation regulation as "reallocation |
| In general, the regulation contemplates that reallocation liability will be based on the plan's unfunded vested benefits as of |
| the "mass withdrawal valuation date," which is the last day of the plan year in which the mass withdrawal termination |
| occurs. The employers to be assessed reallocation liability are identified as of the "reallocation record date," set by the |
| trustees, which may not be later than one year after the mass withdrawal valuation date. The deadline for determining |
| reallocation liability is ordinarily one year after the reallocation record date but may be extended, as it has been for the |
| plan in question. Demand for payment of reallocation liability is to be made within 30 days after the deadline for |
| determining the amount of the liability. (The regulation permits plans to adopt different rules for determining reallocation |
| liability, but your request makes no mention of such rules for the plan in question.) |
| You ask whether the trustees, in computing the reallocation liabilities of all withdrawing employers under the reallocation |
| regulation, may consider certain events occurring after the plan's reallocation record date. The two types of events you |
| mention are (1) a change in a withdrawing employer's financial condition (including the liquidation, dissolution or bankruptcy |
| of the employer) and (2) an arbitration award with respect to a challenge to an employer's initial withdrawal or |
| redetermination liability. |
| In considering these questions, it is important to distinguish between the time when an event or condition affecting |
| reallocation liability occurs or exists and the time when the trustees, having learned of the event or condition, take it into |
| account in computing the liability. In general, the trustees may make decisions about which withdrawing employers are to |
| be assessed reallocation liability, and the amount of reallocation liability to be assessed to those employers, at any time |
| before payment of the liability is demanded (whether or not the deadline for determining the liability has been extended); |
| however, the trustees may not base those decisions on events that occur, or conditions that come into being, after the |
| times specified in the reallocation regulation and ERISA. |
| An employer's financial condition may affect reallocation liability in various ways. For example, under § 2648.3(c)(1) and |
| (c)(2) of the reallocation regulation, an employer is excluded from reallocation liability if, as of the reallocation record date, |
| the employer has been completely liquidated or dissolved or is involved in bankruptcy or insolvency proceedings. This is |
| true even if the trustees do not learn of the liquidation, dissolution or bankruptcy until after the reallocation record date. |
| Any liquidation, dissolution or bankruptcy of an employer after the reallocation record date may not be considered by the |
| trustees in determining whether the employer is liable for reallocation liability under § 2648.3(c)(1) and (c)(2). |
|
Under § 2648.6(c)(2), the trustees may determine that ERISA section 4225 limits the reallocation liability of an employer |
|
that has been involved in a sale, liquidation, or dissolution. In such a case, a portion of the reallocation liability that would |
|
otherwise be assessed to that employer may be reallocated among all other liable employers. The wording of ERISA |
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section 4225(e) makes clear that section 4225(a) and (b) apply only where the employer's withdrawal is "attributable to" the |
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sale, liquidation or dissolution in question. The determination of whether section 4225 applies must thus be based on |
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whether the withdrawal that gives rise to the initial, redetermination, and reallocation liability was in connection with one of |
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the events specified in section 4225. However, under § 2648.6(c)(2), as under § 2648.3(c)(1) and (c)(2), the trustees' |
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determination itself may be made at any time before the demand for reallocation liability. |
|
Section 2648.3(c)(3) is the only rule under which the time for making the trustees' determination ends before the time for |
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demanding reallocation liability. Under § 2648.3(c)(3), an employer is excluded from reallocation liability if, as of the |
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reallocation record date, the plan sponsor has determined that the employer's initial withdrawal liability or its |
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redetermination liability is limited by section 4225 of ERISA. Section 2648.3(c)(3) provides specifically that the |
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determination that section 4225 applies to the initial or redetermination liability must have been made on or before the |
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reallocation record date. As with § 2648.6(c)(2), section 4225 must be applicable at the time of withdrawal. |
|
The time when an arbitration award is made generally has no bearing on whether the trustees may consider it in determining |
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reallocation liability (although an award obviously cannot be taken into account until it has been made). The significance |
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of an arbitration award in this context is that it may represent a finding that an event or condition affecting reallocation |
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liability occurred or existed at some (generally) earlier time. It is the timing of the events or conditions established by the |
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award that is decisive as to whether the trustees may consider them. |
|
You mention in particular arbitration awards with respect to challenges to an employer's initial withdrawal or redetermination |
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liability. The outcome of such challenges, by determining the amount of withdrawal liability owed to the plan, can affect |
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the amount of a plan's assets, and thus its unfunded vested benefits. Under § 2648.6(b), the amount of "unfunded |
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vested benefits to be reallocated" for a plan, upon which the reallocation liability depends, is the amount of the plan's |
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unfunded vested benefits, determined as of the mass withdrawal valuation date, with certain adjustments. Unless an |
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arbitration award respecting an employer's initial withdrawal or redetermination liability is based on facts occurring or |
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existing after the mass withdrawal valuation date (which would be unlikely), the trustees may consider it in determining the |
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"amount of unfunded vested benefits to be reallocated" and thus the withdrawing employers' reallocation liability. |
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If you have any further questions about this matter, you may call Deborah C. Murphy at 202-778-8820. |
|
Gary M. Ford |
|
General Counsel |