| | 94-6 |
| | September 28, 1994 |
| | REFERENCE: |
| | 4007(a) Payment of Premiums. Due Dates |
| | >4007(e)> |
| | >29 CFR 2610.26(b)> |
| | >29 CFR 2617.28(b)> |
| | OPINION: |
| | You have requested an opinion from the Pension Benefit Guaranty Corporation ("PBGC") on whether an individual who |
| | acted as plan administrator is personally liable to PBGC for premiums when the plan sponsor has ceased operations, gone |
| | bankrupt, and been liquidated. You also ask that we identify the parties from whom PBGC will seek payment of |
| | premiums, penalties, and interest under these circumstances. |
| | According to the hypothetical posed in your letters, in 1984 Company X ceased operations, filed for bankruptcy, and was |
| | liquidated. Company X was the plan sponsor of a tax-qualified defined benefit pension plan (the "Plan"). The Plan was |
| | substantially overfunded. Company X's bankruptcy trustee did not terminate the Plan. However, an individual appointed |
| | by Company X prior to the bankruptcy as plan administrator of the Plan (whom you referred to as "A") terminated the Plan |
| | and completed the distribution of the Plan's assets, less a reserve for the Plan's contingent liabilities, by December 31, |
| | 1990. You state, and we assume solely for purposes of this opinion, that the Plan was terminated in a standard |
| | termination, pursuant to section 4041(b) of the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended, |
| | 29 U.S.C. § 1341(b) (1988 and Supp. IV 1992). |
| | A dispute arose over whether A continued as plan administrator after Company X was liquidated. You state that at the |
| | time Company X ceased operations and at all times thereafter A acted as plan administrator, and that A "assumed . . . |
| | responsibility" in 1989 "in order to terminate [the Plan]." For purposes of Title IV of ERISA, the term 'plan administrator' |
| | means either the person specifically designated as such by the plan document, or the plan sponsor if no such designation |
| | is made. ERISA § § 3(16)(A), 4001(a)(1), 29 U.S.C. § § 1002(16), 1301(a)(1). You do not state whether A was |
| | appointed pursuant to the Plan document, or whether the Plan document defines the term "plan administrator." For |
| | purposes of this opinion, however, we will assume that A was the plan administrator as that term is defined in ERISA. |
| | For plan years beginning before January 1, 1988, section 4007(a) of ERISA, 29 U.S.C. § 1307(a) (1982), stated that the |
| | "plan administrator of each plan shall pay the premiums imposed by the corporation under this title with respect to the plan |
| | as they become due." For plan years beginning on or after January 1, 1988, section 4007(a) of ERISA, 29 U.S.C. § |
| | 1307(a) states, "The designated payor of each plan shall pay the premiums imposed by the corporation under this title with |
| | respect to that plan when they are due." n1 |
| | n1 Section 4007 of ERISA was amended by section 9331(c) of the Omnibus Budget Reconciliation Act of 1987 ("OBRA"), |
| | Pub. L. 100-203, 101 Stat. 1330, 1330-368 (1987). The effective date was established by section 9331(f) of OBRA, 101 |
| | Stat. 1330, 1330-369 (1987). |
| | For a single-employer pension plan, the term "designated payor" means the contributing sponsor or plan administrator. |
| | ERISA § 4007(e)(1)(A), 29 U.S.C. § 1307(e)(1)(A). Moreover, each member of the contributing sponsor's controlled |
| | group is jointly and severally liable for premiums. ERISA § 4007(e)(2), 29 U.S.C. § 1307(e)(2); 29 C.F.R. § 2610.26 |
| | (1993). Any entity that is liable for required premiums is also liable for any interest and penalties assessed with respect to |
| | such premiums. 29 C.F.R. § 2610.26(a). |
| | Although the plan administrator has the duty of ensuring that premiums are paid, the payments, along with penalties and |
| | interest, may generally be paid from plan assets. n2 The conference committee report accompanying ERISA makes this |
| | clear. "The plan is to be liable for both the premiums for coverage of benefits and for any penalty assessed for failure to |
| | pay premiums. Besides the penalty, the [PBGC] may also charge interest for unpaid premiums that are past due." H.R. |
| | Rep. No. 93-1280, 93d Cong., 2d Sess. 365 (1974), reprinted. in 1974 U.S.C.C.A.N. 5038, 5145. |
| | n2 However, for single-employer post-1987 plan years, premiums (and any related interest and penalties) may not be paid |
| | from plan assets for any plan year beginning with the plan year in which a distress or involuntary termination is initiated. |
| | 29 C.F.R. § 2610.26(b). |
| |
If a plan is terminated in a standard termination, PBGC has advised that "[d]istribution of a plan's benefit liabilities in a |
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standard termination without taking into account the plan's premium obligation may result in the invalidation of the standard |
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termination or a civil action by the PBGC against the plan administrator in his or her personal capacity." 57 Fed. Reg. |
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59206, 59214 (Dec. 14, 1992). Premiums continue to accrue until a plan's assets are distributed in a termination procedure |
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or until a trustee is appointed pursuant to section 4042 of ERISA, whichever is earlier. ERISA § 4007(a), 29 U.S.C. § |
| |
1307(a). In a standard termination, liability for PBGC premiums for all plan years through and including the plan year in |
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which assets are distributed is a liability that must be taken into account in determining whether plan assets are sufficient |
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to satisfy all benefit liabilities. 29 C.F.R. § 2617.28(b). |
| |
Although this regulation was not in effect when the Plan was terminated, the regulation that was then in effect required the |
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plan administrator to determine the plan's sufficiency for benefit liabilities by reducing the estimated value of plan assets |
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"by the amount (estimated, when necessary) of all expenses, fees, and other liabilities (including benefit payments due |
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before the date the plan administrator proposes to distribute the assets) that the plan has incurred or will incur prior to the |
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proposed date of distribution." 29 C.F.R. § 2617.13(a) (1990). The Plan's liability for premiums, penalties, and interest |
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was plainly a liability that must be taken into account under this regulation. |
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Under the facts of your hypothetical, if the remaining Plan assets, i.e., the reserve, are sufficient to cover the |
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outstanding liability for premiums, interest and penalties, PBGC will look to those assets. However, if the remaining |
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assets are insufficient and the plan administrator disregarded the premium liability in determining whether the statutory |
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requirements for a standard termination had been met, the administrator would be subject to personal liability. |
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I hope this has been helpful to you. If you have any further questions, please contact Ralph Landy of my staff at (202) |
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326-4127. |
| |
Carol Connor Flowe |
| |
General Counsel |