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Seventh Circuit Affirms that Employer’s Withdrawal Liability Cannot Be Based on Post-Rehabilitation Plan Contribution Increases

We recently reported on a district court decision holding that the Central States Pension Fund’s calculation of withdrawal liability should not have included contribution rate increases imposed after the Fund’s implementation...more

SECURE 2.0’s Required Changes to Annual Funding Notices Become Effective in 2025

SECURE 2.0 introduced many changes for retirement plans, including updated disclosure requirements for a defined benefit plan’s annual funding notice (AFN). These updated AFN disclosure requirements apply for all plan years...more

District Court Rules Employer’s Withdrawal Liability Cannot Be Based on Post-Rehabilitation Plan Contribution Increases

In Central States, S.E. & S.W. Pension Fund v. McKesson Corp., No. 23-cv-16770, 2025 WL 81358 (N.D. Ill. Jan. 13, 2025), the district court affirmed that a multiemployer pension plan’s calculation of withdrawal liability...more

PBGC Technical Update on Accelerated Premium Filing Due Dates for 2025

As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025. This...more

PBGC Provides One-Time 4010 Filing Waiver for Certain Employers

ERISA Section 4010 requires a contributing sponsor of certain single-employer pension plans, as well as the sponsor’s controlled group members, to provide controlled group, financial, and actuarial information to the PBGC...more

DOL Proposes Self-Correction Option and Other Changes to Voluntary Fiduciary Correction Program

The U.S. Department of Labor (the “DOL”) proposed changes to its Voluntary Fiduciary Correction Program (the “VFCP”) in November for the first time since 2006. The most significant change is the addition of a self-correction...more

PBGC Issues Guidance on New Special Financial Assistance Program for Troubled Multiemployer Pension Plans

As we previously reported, the American Rescue Plan Act of 2021 (“ARPA”) created a special financial assistance program that is administered by the Pension Benefit Guaranty Corporation (“PBGC”) and intended to extend the...more

ERISA Newsletter - First Quarter 2020

Editor’s Overview - Of course, on the top of everyone’s minds these days is COVID-19. In this edition of Proskauer’s ERISA Newsletter, our colleagues discuss some of the legislation and guidance that has been issued over...more

ERISA Newsletter - Fourth Quarter 2019

Editor's Overview - Happy New Year. We wrap-up 2019 with an article that reflects on significant developments in ERISA litigation during 2019, and takes a look at what's on the horizon for 2020. The courts (at all levels)...more

Second Circuit Prohibits Retroactive Changes to Withdrawal Liability Interest Rate Assumptions

The Second Circuit Court of Appeals recently issued a withdrawal liability decision of which both multiemployer pension plans and their contributing employers should be aware. Specifically, in National Retirement Fund v. Metz...more

PBGC Adopts AAA’s Amended Withdrawal Liability Arbitration Rules

Beginning January 1, 2020, the American Arbitration Association (AAA) will: (i) reduce filing fees charged to parties initiating arbitrations of withdrawal liability disputes; (ii) change how costs of arbitrations are...more

Sun Capital Update: First Circuit Reverses District Court’s “Partnership-in-Fact” Holding and Finds Private Equity Funds Not Part...

Last Friday, the U.S. Court of Appeals for the First Circuit ruled that two co-investing Sun Capital private equity funds (the Sun Funds) had not created an implied “partnership-in-fact” for purposes of determining whether...more

PBGC Proposes Simplified Methods for Withdrawal Liability Calculations

On February 6, 2019, the Pension Benefit Guaranty Corporation ("PBGC") issued a proposed rule that impacts how multiemployer pension plans in endangered or critical status calculate withdrawal liability. The rule is not yet...more

Sun Capital Redux: Private Equity Fund Seeks Declaratory Judgment on Controlled Group Liability for Portfolio Company's Pension...

In light of the recent decisions by the U.S. Court of Appeals for the First Circuit and the U.S. District Court for the District of Massachusetts in Sun Capital, private investment funds, multiemployer pension funds and the...more

Sun Capital Court Finds Co-Investing Funds Part of Controlled Group and Liable for Portfolio Company’s Pension Liabilities

District Court finds affiliated funds acted in de facto partnership which controlled portfolio company; Decision may be significant in making private equity acquisition structuring choices. As we previously reported, in...more

PBGC Issues Final Regulations Regarding Rollovers from Defined Contribution Plans to Pension Plans

The PBGC has recently initiated efforts to enhance retirement security for Americans by promoting lifetime income options (i.e., annuitized benefits). As part of these efforts, as well as those of the IRS and U.S. Department...more

The ERISA Litigation Newsletter

Editor's Overview - This month's newsletter focuses on repayment of pension plan overpayments. Our issue discusses pension plan overpayments to participants, a plan administrator's duties to seek repayment, corrections...more

The ERISA Litigation Newsletter - April 2014

This month we discuss the evolving case law on the issue of whether unpaid employer contributions due under a collective bargaining agreement can be viewed as plan assets such that the individuals who decide to withhold such...more

The ERISA Litigation Newsletter - December 2013

This month we look at part two of our three part series on Class Actions. In part two, Robert Rachal, Page Griffin and Madeline Chimento Rea address Wal-Mart's Rule 23(b) principles, including some defenses to plaintiffs' use...more

The PBGC Not Entitled to Administrative Deference for Involuntary Plan Termination

As we previously noted, the PBGC filed a complaint (E.D. Pa. Case No. 13-02069) to involuntarily terminate a defined benefit plan prior to a corporate transaction that would change the plan sponsor’s controlled group. The...more

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