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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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12/31/92 Mem. Dec. at 16-17. As PBGC's financial expert <br />testified, "One of the basic premises of finance is that the <br />discount rate should match the riskiness of the stream." <br />11/12/92 Tr. at 116 (Cornell). Yet "by discounting at this 12.3 <br />rate, you are asking the PBGC to bear the risk and get no <br />compensation for that risk bearing, and that's inconsistent with <br />the way the capital market works." Id. at 117 (Cornell). Thus, <br />based on findings of fact that were adequately supported by the <br />trial record, the Court properly rejected Debtors' "prudent <br />investor" approach as impractical, unrealistic, and economically <br />unsound. <br />This Court has already found, based on a fully <br />developed record, that (1) PBGC's assumptions replicate the <br />relevant marketplace cost of closing out benefit obligations of a <br />terminating pension plan, and (2) Debtor's "prudent investor" <br />approach not only failed by its own terms, but was contrary to <br />basic principles of finance. Given the Court's unchallenged <br />findings of fact, there is only one possible outcome. The Court, <br />making the "independent" evaluation the district court required, <br />should reaffirm its prior determination. <br />- 12 - <br />
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