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Multiemployer

  • Opinion Letter 90-04

    Addresses whether interest rate changes subsequent to the mass withdrawal valuation date may be considered in determining the reallocation liability upon a mass withdrawal. It also addresses the burden of proof a multiemployer plan must satisfy to show an amendment increasing benefits was adopted earlier than the formal date of adoption which would make payment of the benefit increase covered by the PBGC guarantee.

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  • Opinion Letter 83-17

    Pending regulations, plans have the ability to adopt reasonable rules to abate an employer’s withdrawal liability.

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  • Opinion Letter 95-02

    Addresses the interpretation of the special rule for partial withdrawals for certain employers and plans in the building and construction industry.

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  • Opinion Letter 89-02

    Addresses (1) whether transfers of contributions between multiemployer plans under a reciprocity agreement are covered by rules on transfers of assets; and (2) whether a reciprocity agreement can create withdrawal liability obligations.

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  • Opinion Letter 83-19

    Addresses whether, under the presumptive method of allocating withdrawal liability, if a plan's assets exceed its vested liabilities, the unfunded vested benefit amount is zero.

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  • Opinion Letter 85-15

    Addresses whether the rule against transactions with a principal purpose to avoid withdrawal liability can apply when a transaction meets the sale of assets exception requirements.

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  • Opinion Letter 93-02

    Discusses the calculation of partial withdrawal liability following a 70 percent decline in contributions.

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  • Opinion Letter 87-08

    Addresses whether a contributing employer to a multiemployer plan withdraws by subcontracting out its work to another contributing employer such that contributions are unaffected.

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  • Opinion Letter 81-27

    Addresses the special rules governing a transfer between multiemployer plans where an employer withdraws from a plan because the union bargaining with that employer has been changed as a result of the certification of a different union.

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