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GENERAL55961
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Last modified
8/24/2016 8:40:54 PM
Creation date
11/23/2007 10:58:04 PM
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Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Name
MEMO IN SUPPORT OF MOTION DATED 3/7/95 OF PENSION BENEFIT GUARANTY CORP OF JUDGMENT
Media Type
D
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• "If one portion of the formula is modified, <br />then the presumptions as to the expected <br />retirement age and the mortality rates also <br />required modification." <br />• "Utilization of the interest rate set forth <br />in the prudent-investor approach does not <br />replicate the market price from an insurance <br />company for the close out of annuities from a <br />terminated pension plan." <br />12/31/92 Mem. Dec. at 17. The evidence fully supported these <br />findings. See 11/30/92 Tr. at 2-6 (Gustafson); PBGC Exhibit 19; <br />11/10/92 Tr. at 53-54 (Gustafson). <br />In other words, the Debtors' theory analyzed the wrong <br />market: the earnings of assets held by onaoina pension plans, <br />rather than the cost of closing out the benefit obligations of <br />terminating plans. But even as a measure of pension fund <br />investment return, Debtors' theory failed on its own terms. This <br />Court made these findings of fact regarding the "prudent <br />investor" theory: <br />• It "fails to account for immediate cash draws <br />against the fund. Since [there was no] cash <br />reserve, there was no consideration of how <br />that may affect the yield." <br />• It "produced a rate that was generally higher <br />than many large pension plans projected they <br />would receive on long term investments." <br />12/31/92 Mem. Dec. at 16. <br />Again, these findings have ample record support. <br />Debtors' own witnesses acknowledged that a prudent pension fund <br />manager must have cash available to meet obligations when they <br />come due. "If you invest in a class of assets that might be <br />rather volatile you want to be careful that you don't get <br />- 10 - <br />
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