| 92-4 |
| June 18, 1992 |
| REFERENCE: |
| § 4204(a) § 4204(a)(1)(B) § 4204(a)(1)(C) § 4204(c) 29 CFR § 2643.11(a) 29 CFR § 2643.11(d) |
| OPINION: |
| I write in response to your request for the opinion of the Pension Benefit Guaranty Corporation ("PBGC") as to the meaning |
| and operation of section 4204(a)(1)(B) and (C) and 4204(c) of the Employee Retirement Income Security Act of 1974 |
| ("ERISA") and regulations thereunder. |
| Section 4204(a)(1) of ERISA provides that: |
| A complete or partial withdrawal of an employer (. . . the "seller") under this section does not occur solely because, as a |
| result of a bona fide, arm's-length sale of assets to an unrelated party (. . . the "purchaser"), the seller ceases covered |
| operations or ceases to have an obligation to contribute for such operations, if -- |
| (A) the purchaser has an obligation to contribute to the plan with respect to the operations for substantially the same |
| number of contribution base units for which the seller had an obligation to contribute to the plan; |
| (B) the purchaser provides to the plan for a period of 5 plan years commencing with the first plan year beginning after the |
| sale of assets, a bond . . . , or an amount held in escrow . . . , in [a specified amount]; and |
| (C) the contract for sale provides that, if the purchaser withdraws in a complete withdrawal, or a partial withdrawal with |
| respect to operations, during such first 5 plan years, the seller is secondarily liable for any withdrawal liability it would have |
| had to the plan with respect to the operations (but for this section) if the liability of the purchaser with respect to the plan |
| n1 Independently of the provisions of section 4204(a)(1)(C), section 4204(a)(2) provides that -- |
| [i]f the purchaser . . . withdraws before the last day of the fifth plan year beginning after the sale, and . . . fails to make |
| any withdrawal liability payment when due, then the seller shall pay to the plan an amount equal to the payment that would |
| have been due from the seller but for [section 4204]. |
| Under section 4204(c), the PBGC "may by regulation vary" the bond/escrow and contract-language requirements of section |
| 4204(a)(1)(B) and (C). n2 Pursuant to that authority, the PBGC has issued its regulation on Variances for Sale of Assets |
| (29 CFR Part 2643). Section 2643.11(a) of the regulation provides that: |
| A purchaser's bond or escrow under section 4204(a)(1)(B) of [ERISA] and the sale-contract provision under section |
| 4204(a)(1)(C) are not required if the parties to the sale inform the plan in writing of their intention that the sale be covered |
| by section 4204 of [ERISA] and demonstrate to the satisfaction of the plan that at least one of the criteria contained in § |
| 2643.12, § 2643.13 or § 2643.14(a) is satisfied. |
| You first ask for -- |
| an opinion of the scope of the contract for sale requirement of ERISA Section 4204(a)(1)(C), including a determination of |
| whether language, such as the contract language contained in [a document submitted with the request], fulfills section |
| 4204(a)(1)(C) for the application of the sale of assets exemption. |
| Section 4221 of ERISA provides that any dispute between a plan sponsor and an employer concerning a determination |
| made under ERISA sections 4201 through 4219 -- which would include a determination under section 4204 based on the |
| interpretation of a contract provision -- be resolved through arbitration, subject to review in the courts. Accordingly, it |
| would be inappropriate for the PBGC to express an opinion as to the adequacy of specific language under section |
| n2 No variance is provided for, however, with respect to the secondary liability requirement of section 4204(a)(2) that |
| complements the contract-language requirement. You also ask that the PBGC confirm that -- |
| once the Seller and Buyer demonstrate to the Plan that the transaction [meets one of the criteria referred to in § |
| 2643.11(a) for variance of the bond/escrow and contract-language requirements], the Plan cannot insist that a bond be |
| posted or that the contract for sale . . . agreement be renegotiated between the parties to set forth yet another agreement |
| regarding the Seller's secondary liability. |
| In response to this request, we begin by noting that satisfaction of one of the three variance criteria referred to in § |
| 2643.11(a) is not alone sufficient to entitle a seller and buyer to a variance; they must also give the plan written notice of |
| their intent that the sale be covered by section 4204. A plan may therefore agree that one of the three variance criteria is |
| met and yet properly refuse to grant a variance because an appropriate joint notice of intent has not been given. |
| One purpose of the joint notice requirement under § 2643.11(a) is to substitute for the contract-language requirement of |
| section 4204(a)(1)(C) by confirming the seller's acceptance of its secondary liability under section 4204(a)(2). As |
| explained in the preamble to the proposed amendment adding Subpart B (§ § 2643.10 - 2643.15) to the regulation: |
|
[T]he parties to a sale must inform the plan in writing of their intention to be covered by section 4204 of ERISA. In this |
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way, both the seller and purchaser expressly consent to the various responsibilities they assume by operation of law. For |
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example, if section 4204 applies, the seller assumes a secondary liability under section 4204(a)(2) . . . . One purpose of |
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the sale-contract requirement is to require an affirmative action by the parties in order to trigger section 4204. Therefore, |
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the requirement of a joint notice of intention minimizes the need for the sale-contract provision. |
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48 FR 6556 (February 14, 1983). It does not follow that a provision like that required by section 4204(a)(1)(C) must |
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necessarily be in the joint notice, much less in the sale contract itself. It would be illogical to make fulfillment of the |
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contract-language requirement a prerequisite to waiver of the same requirement. On the other hand, if the joint notice or |
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the sale contract can be interpreted as rejecting the secondary liability rule of section 4204(a)(2), it may be necessary to |
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clarify the seller's acceptance of that secondary liability in order to meet the joint notice requirement of § 2643.11(a). |
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The bond/escrow requirement presents different issues. While a contract-language waiver is aimed at retroactively curing |
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an omission, a bond/escrow waiver provides only prospective relief from the section 4204(a)(1)(B) requirement that the |
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bond or escrow be maintained for the specified five-plan-year period. However, as the PBGC stated in Opinion Letter 85- |
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31 (December 30, 1985), -- |
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[s]ection 4204 of ERISA contemplates in general that a bond or escrow will be furnished at the beginning of the five-year |
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period described in section 4204(a)(1)(B), and maintained throughout that period, unless and until it is waived. |
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(Emphasis supplied.) Section 2643.11(d) provides a limited exemption from the bond/escrow requirement for the period |
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before a plan acts on a variance request if the request is submitted before the beginning of the first plan year following the |
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sale. n3 Otherwise, a plan is justified in insisting that the requirement be met until it is waived, and in treating the sale as |
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failing to come within the purview of section 4204 if the bond or escrow is not furnished at the beginning of the five-plan- |
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year period and maintained until the plan acts on the variance request. |
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n3 PBGC Opinion Letter 86-6 (March 11, 1986) also discusses a limited exemption applicable to pre-1981 sales under § |
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2643.12. |
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Finally, we note again (as we did above in connection with your contract interpretation question) that a dispute over a plan's |
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determination not to grant a variance under section 4204 and the PBGC's regulation on Variances for Sale of Assets is |
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subject to the dispute resolution procedures of section 4221. |
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If you have any further questions regarding this matter, you may call Deborah C. Murphy of this office at 202-778-8850. |
|
Carol Connor Flowe |
|
General Counsel |