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Withdrawal Liability Collection Scope Expanded

Takeaway Related Links Article The Third Circuit’s recent ruling enhanced a pension fund’s ability to pursue withdrawal liability collection against affiliated employers. The decision underscores the evolving nature of ERISA,...more

The End of Chevron Deference and the Anticipated Impact on Withdrawal Liability

The U.S. Supreme Court recently overturned the decades-old Chevron doctrine of judicial deference to a federal agency’s interpretation of an ambiguous statute. (See “Go Fish! U.S. Supreme Court Overturns ‘Chevron Deference’...more

DOL’s Controversial Retirement Security Rule Faces Immediate Legal Challenge

On April 23, 2024, the United States Department of Labor (DOL) issued updates to the investment advice fiduciary regulation, formally called the “Retirement Security Rule” and generally referred to as the “DOL Fiduciary...more

Seventh Circuit Orders Pension Fund to Return Withdrawal Liability to Employer

An employer can contest a withdrawal liability assessment and ultimately prevail. That is the moral of Bulk Transport Corp. v. Teamsters Union No. 142 Pension Fund, No. 23-1563 (7th Cir. Mar. 22, 2024). Withdrawal...more

Impact of Critical Withdrawal Liability Interest Rate Assumption on Construction Industry Employers

Withdrawal liability is a major concern for many employers with collectively bargained operations. While special rules applicable to the construction industry can limit the circumstances under which liability can be imposed,...more

Withdrawal Liability and The Building and Construction Industry Exception

Withdrawal liability is a statutory obligation under the Employee Retirement Income Security Act (ERISA) that any unionized employer may have to confront. Exemptions from liability include one applicable to construction...more

Second Circuit Grants Fund’s Audit Request Well Beyond CBA Coverage

In a decision that bodes poorly for unionized employers, the U.S. Court of Appeals for the Second Circuit recently held that a union benefit fund was contractually entitled to conduct an audit whose scope far exceeded the...more

More Bad News For Employers In The PBGC Final Rule

The recently published final regulation implementing last year’s massive multiemployer pension plan bailout contains a very thin silver lining, but overall, more bad news for already overburdened employers....more

Withdrawal Liability Interest Rate Must Reflect Projected Investment Return, D.C. Circuit Holds

Under the Employee Retirement Income Security Act (ERISA), as amended by the Multiemployer Pension Plan Amendments Act (MPPAA), a company incurs withdrawal liability when it withdraws from a multiemployer pension plan....more

District Court Upholds New York City Hotel Severance Law

In a decision of great import to the New York City hospitality industry, a federal court has held that a New York City statute mandating payment of severance benefits to certain covered hotel service employees was not...more

Third Circuit Joins Sister Circuits in ‘Employer’ Definition under Multiemployer Pension Plan Amendments Act

Turning an “American Dream Project” into a nightmare for a New Jersey contractor, the U.S. Court of Appeals for the Third Circuit has held that, under ERISA’s multiemployer pension plan provisions (the Multiemployer Pension...more

Deferential Review Determinative in Severance Spat

In a decision illustrating the importance of a deferential standard of review in an ERISA plan document, the Second Circuit affirmed the dismissal of severance claims by a disabled employee, concluding that the complaint pled...more

‘Segal Blend’ Withdrawal Liability Calculation Violates ERISA, Court Holds in Milestone Decision

The use of the “Segal Blend” to calculate a company’s withdrawal liability when it withdrew from a multiemployer pension plan violated the Employee Retirement Income Security Act (ERISA), as amended by the Multiemployer...more

Third Circuit Upholds Withdrawal Liability Arbitral Award Under MPPAA’s Evade Or Avoid Provision

Under the provisions of the Employee Retirement Income Security Act (“ERISA”) as modified by the Multiemployer Pension Plan Amendments Act of 1980 (“MPPAA”), an employer who withdraws from a multiemployer pension plan is...more

Successor Liability Claims Found Insufficient To Establish Federal Question Jurisdiction

As a general rule, an asset purchaser does not assume the seller’s liabilities, including its ERISA obligations. Courts, however, have formulated an exception to this general rule via the doctrine of successor liability. ...more

Multiemployer Pension Plan Reform/Bailout May Be Greater Than Expected; Guidance Still Forthcoming

The Emergency Pension Plan Relief Act of 2021 (EPPRA), enacted as part of the American Rescue Plan Act of 2021 (ARPA), contained unprecedented financial relief for the most troubled multiemployer pension plans (MEPPs). The...more

New Mandatory Retirement Plan Requirement For Certain New York City Employers

On May 11, 2021, the City Council of New York enacted a local law to establish a retirement savings program for certain employees of private entities. What are the Details? The new law creates a mandatory...more

Multiemployer Plan Audits During A Pandemic — Mitigating The Employer’s Risk

A global pandemic has not stopped multiemployer plans from conducting employer payroll audits. To the contrary, an uptick in the number of these payroll audits is noticeable. While employers are under no statutory mandates to...more

Will New Stimulus Bill Include Multiemployer Pension Reform?

What could be in the next stimulus bill in response to the COVID-19 pandemic? Congress reportedly is working on a bill (dubbed “Stimulus 3.5”) that includes additional funding for the Paycheck Protection Program created by...more

COVID-19 And Withdrawal Liability

The effect of the coronavirus (COVID-19) on businesses and individuals is unprecedented and staggering. Many employers have or soon will be forced to implement some type of COVID-19-related workforce reduction, which can have...more

North Carolina Court Awards $41 Thousand-Plus Penalty For Failure To Produce Documents Requested By Plan Participants

Section 104(b)(4) of ERISA provides that a plan administrator must respond to a written request for certain documents (including the plan documents and summary plan description) by a participant or beneficiary by providing...more

Segal Blend Litigation, Part Two: New Jersey District Court Holds That Use Of Segal Blend Did Not Violate MPPAA

As our earlier article reported, Judge Robert W. Sweet of the U.S. District Court for the Southern District of New York had recently held that a multiemployer pension fund’s use of the “Segal Blend” to calculate a withdrawn...more

Constructive Notice Enough For Successor Withdrawal Liability, Ninth Circuit Holds

The expansion of the multiemployer pension plan successor withdrawal liability doctrine continues for asset purchasers. Establishing a constructive notice standard, the federal appellate court in San Francisco has ruled that...more

Calculating Withdrawal Liability With ‘Segal Blend’ Violated Multiemployer Pension Plan Amendments Act, Judge Rules

In a decision that could have far-reaching implications for multiemployer pension plans and employers, a federal district court has held that the use of the “Segal Blend” to calculate a company’s withdrawal liability when it...more

Multiemployer Pension Plans: Potential Successor Liability From Buyer’s Attempts To Continue Seller’s Business

The district court erred in finding a multiemployer pension plan did not show sufficient continuity of business operations to support imposing successor liability on an asset purchaser, the federal appeals court in Chicago...more

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