Understanding an Employer’s Bankruptcy Impact on …...– Debtor obtains a discharge for...

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Understanding an Employer’s Bankruptcy Impact on Trust Funds

Neil J. Gregorio, Esq.ShareholderTucker Arensberg, P.C.Pittsburgh, Pennsylvania

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Audience

• Trust Fund Representatives– Trustees– Administrators– Office Employees

• Auditors• Attorneys

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Types of Bankruptcies

• Chapter 7— Liquidation for individuals/ businesses

• Chapter 9— Municipal bankruptcy• Chapter 11— Corporate reorganization• Chapter 12— Farmers and fishermen

Reorganization• Chapter 13— Individuals’ reorganization• Chapter 15— Foreign debtors

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Chapter 7 Bankruptcy

When an Employer/Debtor is in a Chapter 7 Bankruptcy:• Business stops operating• A trustee is appointed by the court to liquidate

its assets and pay creditors

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Bankruptcy Trustee

Bankruptcy Trustee• In a Chapter 7 Bankruptcy (“Liquidation”),

the court appointed Trustee:– Is motivated by money to maximize the payments

made to creditors since a Chapter 7 trustee gets roughly 10% off the top.

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• Employer/Debtor files Chapter 11 Bankruptcy to:1. Reorganize business and restructure debt; or2. Liquidate its assets outside of a Chapter 7

liquidation

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In a Chapter 11, the employer/debtor remains “in possession” of the business.• Current management stays in place

– Management continues to collect salaries

• Good and bad aspects of current management staying in charge– Good—Asset sales may yield more money for creditors– Bad—Debtor may not include all assets in bankruptcy estate

• Debtor supposed to act as fiduciary for creditors, however, a Trustee is not always appointed so there is little to no oversight.

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• Ultimately, debtor may confirm a plan of reorganization to:– Pay its creditors; and – Emerge from bankruptcy.

• Many times, debtor starts out in a Chapter 11 Bankruptcy that is later converted to a Chapter 7 Liquidation– Employer fails to reorganize and shuts down

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• If Plan of Reorganization is successful . . . – Debtor obtains a discharge for pre-bankruptcy

debts, except for those debts to be paid under the plan of reorganization.

– Unpaid creditors are out of luck• They may not later enforce claims against the

debtor.

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• Enables individuals with regular income to develop a plan to repay all or part of their debts.– 3-5 year payment plan

• Saves home from foreclosure.– Allows cure of delinquent mortgage payments

over time.– Must stay current

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What Is Bankruptcy Fraud?

• Federal white collar crime• Includes:

– Concealment of assets • Not listing all assets in schedules

– Destruction of documents– False statements or declarations

• Filing multiple bankruptcies is not a criminal offense, but it may violate bankruptcy law.

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Bankruptcy Fraud

Concealment of Assets • All assets must be disclosed in “bankruptcy schedules”

whether or not the debtor believes the asset has any value. – It is for the creditors, not the debtor, to decide whether a

particular asset has value. – Omitting assets from schedules can cause a closed bankruptcy

to be reopened by a creditor or the Bankruptcy Trustee. – Trustee may seize the unlisted assets and liquidate them for the

benefit of the (formerly discharged) creditors.

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Bankruptcy Fraud

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Bankruptcy Fraud

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What Happens When an Employer Improperly Shed Assets Before

Filing for Bankruptcy?Preference Action• Generally, when a bankruptcy trustee seeks to recover any property

transferred by a debtor within 90 days before filing for bankruptcy. • Transfer must:

1. Be made while debtor is insolvent; and 2. Give specific creditor more than it would obtain in a liquidation of the

debtor's assets in bankruptcy.

• Trustee can look back 1 year if transfer is made to an insider/relative.

• Contributions made to funds are not a preference because they are made in the ordinary course of business.

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Claims Are Categorized by Their Relationship to the

Petition Date• Petition Date

– Specific date that a company or individual files for bankruptcy

• Pre-Petition Claim– Claim that arose before the bankruptcy was filed

• Post-Petition Claim– Claim that arose after the bankruptcy was filed

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Funds’ Bankruptcy Claims

• Funds’ bankruptcy claims fall into the following categories:1. Administrative Priority Claim

• Monthly contributions for post-petition work• Post-petition withdrawal liability

2. Unsecured Priority Claim• Contributions for pre-petition work within 180 days of

petition date

3. General Unsecured Claim• Contributions for work performed more than 180 days

before petition date • Pre-petition withdrawal liability

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Administrative Claims

1. Administrative Priority Claims• Post-petition claims• “the actual, necessary costs and expenses of

preserving the estate, including wages . . . “– Section 503(b)(1)(a)

• Most likely to receive payment

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Include: • Costs of preserving the estate• Wages (fringes constitute wages)• Salaries• Court costs• Attorneys’ fees• Accountants’ fees• Trustees' expenses

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• In re Marcal Paper Mills, Inc., 650 F.3d 311 (3d Cir. 2011).

– A portion of a pension fund’s withdrawal liability claim constitutes an administrative claim if the debtor continues to employ union employees in Chapter 11.

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• Administrative claims must be paid in full under a Chapter 11 Plan, or – In manner agreed upon by debtor and creditor.

• Generally, funds’ administrative claims must be paid on the first effective day of a Chapter 11 Plan, however, it is possible to get immediate payment of monthly contributions via a motion.

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Priority Claims

2. Pre-Petition Priority Claims– Contributions owed for work performed

within 180 days prior to bankruptcy filing (petition date) or when employer ceased covered work • Whichever is earlier

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Priority Claims

3. General Unsecured Claims– Contributions owed for work performed

more than 180 days prior to bankruptcy filing (petition date)

– Least likely to receive payment from bankruptcy

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The Automatic Stay

• Bankruptcy Code § 362 imposes an automatic stay at the moment a bankruptcy petition is filed.

• Absent specific bankruptcy court relief to a creditor, the automatic stay prohibits any further collection efforts.

– Things that must stop include: 1. Funds’ on-going lawsuit against employer to collect

delinquent monthly contributions;2. Funds’ garnishment action against employer’s bank

account;3. Funds’ monthly automated delinquency letters; and4. Any lawsuit against employer/debtor that was (or could

have been) commenced prior to bankruptcy.

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Exceptions to Automatic Stay

Funds’ lawsuits against parties not in bankruptcy:1. Bonding company2. Successor3. Alter ego

– Pavers & Road Builders District Council Welfare Fund v. Core Contracting of N.Y., LLC., Case No. 15-cv-0207, 2015 U.S. Dist. LEXIS 108924 (E.D. N.Y. August 18, 2015).

4. Individual owners/officers for ERISA Breach of Fiduciary Duty5. Controlled group members

not in bankruptcy – Withdrawal liability

• In re Caesar’s Entertainment Op. Co., Inc., 540 B.R. 637 (Bankr. N.D. Ill. 2015).

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Does a Union Boycott Violate the Automatic Stay?

• Trump Entertainment Resorts, Inc.– Case No. 14-12103 (Bankr. D. Del. July 21,

2015)– Owned and operated the Trump Taj Mahal

casino in Atlantic City

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Does a Union Boycott Violate the Automatic Stay?

• Trump Entertainment Resorts, Inc.– 534 B.R. 93 (Bankr. D. Del. July 21, 2015)– Filed for Chapter 11 bankruptcy in September

2014 due to competition from online gambling and legalized gambling in surrounding states

– Court allowed Trump to reject the expired CBA with UNITE HERE Local 54

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Trump Entertainment Resorts, Inc.

• To bring pressure on Trump to enter into a new CBA by informing customers of union’s dispute with casino, the union:– Organized a phone bank to communicate with potential

customers;– Emailed and wrote letters to organizations with scheduled

conferences and encouraged them to cancel their contracts;– Emailed and wrote letters to prospective convention attendees

and encouraged them to demand that their organizations relocate their conferences.

• At least one organization cancelled its contract due to the union’s efforts.

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• Trump filed a motion to stop the union’s boycott efforts, arguing that:– The union’s conduct violated the bankruptcy code’s

automatic stay’s prohibition against acts taken to obtain or exercise control over estate property or to collect monies owed from the debtor.

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• The issue was whether the bankruptcy court had jurisdiction or authority to stop the Union’s boycotting efforts.

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• Norris-LaGuardia Act of 1932– Prohibits court injunctions against unions for “giving

publicity to the existence of, or the facts involved in, any labor dispute.”

• Federal courts lack jurisdiction to issue labor injunctions.

– This Act prohibited a court injunction against UNITE HERE Local 54, despite Trump’s claim that the union violated the automatic stay.

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• What is the rule of law from Trump?– A union does not violate the automatic stay by

encouraging a boycott, engaging in strikes or picketing to pressure the debtor to negotiate a new CBA or pay contributions owed to union benefit funds.

• Trump Entertainment Resorts, Inc., 534 B.R. 93 (Bankr. D. Del. July 21, 2015) citing In re Petrusch, 667 F.2d 297 (2d Cir. 1981), and In re Crowe & Associates, Inc., 713 F.2d 211 (6th Cir. 1983).

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The Victors’ Roadmap

1. Objecting to discharges in owner’s bankruptcy

2. Withdrawal liabilityA. Construction industry exemption B. Controlled group liabilityC. Pre-bankruptcy evade or avoid transactionsD. Filing of bankruptcy to evade or avoidE. Proofs of claims

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Bankruptcy Terms

Dischargeable Debts• Obligations that can

be wiped out by a bankruptcy case.

• Once a debt is discharged, a creditor cannot collect it from the entity in bankruptcy.

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Bankruptcy Terms

• Nondischargeable Debts• Congress

– Certain obligations too important to be eliminated in bankruptcy.

• These debts survive bankruptcy and are not wiped out by a discharge.

• Owner is responsible for paying even after bankruptcy.

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Bankruptcy Terms

Nondischargeable debts include:• Child support and alimony• Criminal fines• Certain tax obligations• Student loans, and• Debts arising by fraud

or defalcation

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Are Wage Deductions in Owner’s Bankruptcy

Dischargeable?• Bankruptcy Code Section 523(a)(4)

– Discharge does not apply to individual’s “fraud or defalcation while acting in a fiduciary capacity, embezzlement, or larceny.”• Defalcation = Misappropriation

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Are Wage Deductions in Owner’s Bankruptcy

Dischargeable?Bankruptcy Code Section 523(a)(4)• Wage withholdings are nondischargeable• Even after bankruptcy is over,

owner/officer is still liable.

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Are Unpaid Monthly Contributions Dischargeable

in an Owner’s Personal Bankruptcy?

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ERISA Breach of Fiduciary Duty

• ERISA defines “fiduciary” as:– A person is a fiduciary with respect to a plan to the

extent • He exercises any authority or control over plan assets.

– 29 U.S.C. § 1002(21)(A)

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• Delinquent contributions can constitute plan assets if your trust agreements contain the Magic Language.– “No contributing employer shall have any right, title

or interest to any sum payable by such Employer to the Fund, but not yet paid into the Fund. Title to all monies paid into and/or due and owing such Fund shall be vested in the Trustees of such Fund.”

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• Pursuant to ERISA, – A fiduciary must act solely in the interest of the

participants and beneficiaries of the plan.• 29 U.S.C. § 1104(a)(1)(A)(1).

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• ERISA also provides that – A fiduciary that breaches his/her fiduciary duty is

personally liable for the resulting damages. • 29 U.S.C. § 1104(a)

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Failing to turn contributions over to Funds

• Under ERISA, a corporate owner or officer that exercises control of plan assets (such as fringe benefit contributions) may be a fiduciary.

– Not acting in best interest of the participants and beneficiaries.

– Personal liability attaches.– Typically check signing authority is necessary.


Breach of ERISAFiduciary Duty=

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Rejected by pro employer judges– Ohio Bricklayers Heath & Welfare Fund v. Ardit Co.,

No. 13-93, 2016 U.S. Dist. LEXIS (S.D. Ohio, March 22, 2016).

• Rejected claim since “Sixth Circuit has not yet squarely addressed issue of when employer contributions become plan assets”.

– Bricklayers Funds v. M.A.C. Design (Ali Syed), No. 14-1846, 2015 U.S. Dist. LEXIS 124600 (E.D. NY, April 28, 2015).

• Court took advantage of poor language in trust document.

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Are unpaid monthly contributions dischargeable in an owner’s personal bankruptcy?

• Depends on the jurisdiction.

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Are Unpaid Contributions Dischargeable?

• Sub-Issue:– Whether a “fiduciary” under ERISA constitutes a

“fiduciary” under the Bankruptcy Code.

• Bankruptcy Code Section 523(a)(4)– Discharge does not apply to individual’s “fraud or

defalcation while acting in a fiduciary capacity, embezzlement, or larceny.”

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• In re Fahey, 494 B.R. 16 (Bankr. D. Mass. 2013).– Procedural Posture

• Fahey—sole officer and owner of company that owed contributions

• Bricklayer Funds filed a complaint against Fahey for a determination that contributions owed were nondischargeable.

• Bankruptcy court ruled in favor of Fahey (debt was dischargeable).

• Appellate Panel for the First Circuit reversed– Fahey was acting in a fiduciary capacity– Case remanded for findings on issue of whether nonpayment

was a defalcation under § 523(a)(4).

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• Fahey conceded that wage deductions were nondischargeable.

• Only issue was whether contributions were nondischargeable.

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Massachusetts—In re Fahey

Test—Funds must show, by a preponderance of the evidence, that:1. An express or technical trust existed; 2. Debtor acted in a fiduciary capacity; and3. The debt arises from a defalcation.

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Massachusetts Contributions

NondischargeableCourt’s Analysis1. Under the Funds’ Trust Agreements, unpaid contributions

that were due and owing were plan assets.2. Fahey prioritized payments of corporate expenses that were

beneficial to him over his obligations to the funds.• Citizens Bank loan that he personally guaranteed

3. Fahey violated his duty of loyalty to the beneficiaries of the funds.• Defalcation committed.• Contributions nondischargeable.

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California Personal Bankruptcy

• Ninth Circuit—July 2015– Ruling: An owner was not a “fiduciary”

under ERISA or bankruptcy code with respect to unpaid contributions.

– Contributions dischargeable.• Bos v. Carpenters Funds, 795 F.3d 1006 (9th Cir. 2015).

– Owner can escape liability for unpaid contributions in bankruptcy.

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1. Objecting to discharges in owner’s bankruptcy2. Withdrawal liability

A. Construction industry exemption B. Controlled group liabilityC. Pre-bankruptcy evade or avoid transactionsD. Filing of bankruptcy to evade or avoidE. Proofs of claims

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Building and Construction Industry Exemption

• Doesn’t it just apply all the time?

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Construction Industry Exemption

In the construction industry, a complete withdrawal occurs only when the employer ceases to have an obligation to contribute and either:

1. Continues to perform the same or similar work in the CBA’s jurisdiction; or

2. Resumes work within 5 years but does not resume contributions.

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• In the construction industry, complete withdrawals are usually limited to an employer that goes non-union.– Example:

• A construction company continues working in the same area but not under a CBA.

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• Narrowly Applied– Employer must first qualify as a building and

construction industry employer• Employer must have 85% or more of its covered

work performed on job sites to be eligible.• Shop work can make an employer ineligible.

– Fund’s office may not know about an employer’s shop since employer may have only one CBA that covers both its field and shop work.

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• Narrowly Applied– Material suppliers do not qualify for the exemption.

• Lumber yards

– Watch out for double-breasted entities.• Partial withdrawal—70% decline• Exemption should not apply whenever employer shifts work

to its non-union sister company to evade and avoid CBAobligations.

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Understanding controlled group liability is essential to dealing

with an employer’s bankruptcy!

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Controlled Group Liability Test

Members of a commonly controlled group of trades or businesses are jointly and severally liable for withdrawal liability.

Test1. “Common Control” with the obligated employer

– ≥ 80% ownership

2. Entity must be a “trade or business.”– Generally, individual owners and passive investors are

not liable.

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Parent

Subsidiary w/Withdrawal

LiabilitySubsidiary Subsidiary

Controlled Group Liability

Parent companies and their subsidiaries can be jointly and severally liable.• Parent must own ≥ 80% of employer to be liable• Parent must own ≥ 80% of

other subsidiary for that subsidiary to be liable

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Controlled Group Liability

Joint and several liability also applies to “Brother-Sister” Entities• Owned in sufficiently the same proportions by the same five or few

individuals, estates and trusts.

Person, People or Family

Trusts

Employer w/ Withdrawal

LiabilitySister Sister

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Pre-Bankruptcy Transactions

ERISA 4212(c) • Transactions to evade or avoid withdrawal

liability– “If a principal purpose of any transaction is to evade

or avoid liability under this part, this part shall be applied (and liability shall be determined and collected) without regard to such transaction.”

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Pre-Bankruptcy Transactions

General Rule• A stock sale does not trigger withdrawal liability

because there is no change in the employer’s obligations to the fund.

• Beware of pre-bankruptcy stock sales – Designed to evade and avoid controlled group withdrawal

liability by dropping the parent/owner below 80%.

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Employer’s Bankruptcy Schedule

LIST OF EQUITY SECURITY HOLDERS

Interest Holder % Ownership of Debtor

Pinsler Corp. 76.53%

Interlock Investment Group 20%

David Guetta 1.04%

Calvin Harris 1.0%

Steve Wynn .93%

Ron Nicolli .5%

TOTAL 100%

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Look Behind the Curtain!

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Structuring Transactions to Evade or Avoid

• Multiple courts have imposed evade/avoid liability where:1. A legitimate purpose motivated the decision to enter a given

transaction, but 2. An unlawful purpose (i.e. evade/avoid ERISA

obligations) motivated the decision about how to structure the transaction.

• Sherwin-Williams Co. v. New York State Teamsters Conference Pension, Ret. Fund, 158 F.3d 387 (6th Cir. 1998);

• Santa Fe Pacific Corp. v. Central States, Se. and Sw. Areas Pension, 22 F.3d 725 (7th Cir. 1994);

• P.B.G.C. v. White Consol. Indus., Inc., 215 F.3d 407 (3d Cir. 2000).

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Filing Bankruptcy To Avoid Withdrawal Liability

• Bricklayers Funds v. Wasco, Inc. and Lovell’s Masonry, Inc.– No. 3:15-cv-00977 (M.D. Tenn. December 23, 2015).

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Bricklayers Funds v. Wasco

• Two family owned masonry businesses and a wholly owned subsidiary– Controlled group defaulted on withdrawal

liability payments – Pension fund obtained court ruling for

payment– Before entry of court order, the companies

filed Chapter 11 bankruptcies

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• In the two years prior to bankruptcy filings, when company was failing to make interim withdrawal liability payments:– “Insider” transactions

• Family member shareholders received big bonuses sufficient to cover withdrawal liability payments

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• Once in bankruptcy, – Companies proposed a plan of reorganization

that would pay the pension fund only a fraction of its withdrawal liability claims . . .

• While other creditors would be largely paid in full.

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• Pension Plan Objected– Proposed plan of reorganization violated

requirement that a plan be• “proposed in good faith and not by any

means forbidden by law.”– 11 U.S.C. § 1129(a)(3).

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• Pension plan moved to dismiss entire bankruptcy case “for cause” arguing:– Bankruptcy petition

• Filed in bad faith– 11 U.S.C. § 1112(b).

• Principal purpose to evade or avoid withdrawal liability

– 29 U.S.C. § 1392(c).

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• Bankruptcy Court – Overruled pension plan’s objections – Approved Wasco’s plan of reorganization– Denied pension fund’s motion to dismiss

bankruptcy

• Pension fund appealed

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• District Court for Middle District of Tennessee– Reversed

• Denial of motion to dismiss• Approval of plan of reorganization

– Companies improperly used bankruptcy to stop largest creditor from collecting withdrawal liability.

– Plan of Reorganization cannot violated ERISA’s “evade or avoid” rule

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• Lesson Learned:– Pension Funds should object to any plan

of reorganization and move to dismiss any bankruptcy that was filed to evade or avoid withdrawal liability

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Withdrawal Liability Deadlines

A. Initial Notice and Demand B. Employer has 90 days from initial Notice and Demand to

submit a Request a Review.– If Request for Review not filed, employer waives defenses.

C. Employer must initiate arbitration within 180 days from its Request for Review or 60 days from fund’s decision following review.– If arbitration is not initiated, employer waives

defenses.

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What Is a “Proof of Claim”?

• Form filed by a creditor (i.e., funds) so as to register a claim against the bankruptcy estate.

• Claim sets out amount that is owed as of the date the bankruptcy was filed (petition date) and the claim’s priority status.

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Proofs of Claim for Withdrawal Liability

• Can a Proof of Claim constitute an initial Notice and Demand for withdrawal liability?– To start the 90-day deadline to submit a Request for

Review.• Note:

– Without filing a timely Request for Review, a timely Demand for Arbitration can NEVER be filed.

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• Although MPPAA ordinarily requires that a Notice and Demand include: 1. The amount of liability, 2. A schedule of payments, and 3. A demand for payment.

• 29 U.S.C. §1399(b)(1).

– Such is not the case where the contributing employer is in Chapter 11 bankruptcy. • Chicago Truck Drivers v. El Paso CGP Co., 525 F.3d 591 (7th

Cir. 2008).

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• A pension plan’s Proof of Claim for withdrawal liability in a bankruptcy is sufficient to trigger the 90 day deadline for the employer to Request a Review.

• Deadline applies to entire controlled group.– Chicago Truck Drivers v. El Paso CGP Co., 525 F.3d

591 (7th Cir. 2008).

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• In Chicago Truck Drivers v. El Paso CGP Co., 525 F.3d 591 (7th Cir. 2008)– The 90-day clock (to submit a Request for Review)

started to run when an attorney for the defendant (an alleged former member of the controlled group) stumbled on the proofs of claim while performing due diligence for a project unrelated to the litigation.

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• Alleged former member of controlled group– “Anyone who suspects that he might be adjudged a

member of a controlled group . . . • Would be well advised to commence arbitration,

so that if a court holds that he is a member of such a group . . .

• He won’t have waived the issues that are reserved for arbitration.”

– Chicago Truck Drivers v. El Paso CGP Co., 525 F.3d 591 (7th Cir. 2008).

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Session #G03

Understanding an Employer’s Bankruptcy Impact on Trust Funds

• Maximize administrative priority claims

• Understanding controlled group liability is essential to dealing with an employer’s bankruptcy

• Look for:– Pre-bankruptcy transactions to evade

or avoid– Bankruptcies filed to evade or avoid

• Don’t assume building and construction industry exemption applies– At least 85% on construction site

• You are the Mockingjay!

Website Resourceswww.ifebp.org/resources/infoQuick/default/htm Records Retention Requirements for Benefit Plans (members only)

Website Resourceshttps://www.ifebp.org/inforequest/ifebp/0166104.pdfhttps://www.ifebp.org/inforequest/ifebp/0166221.pdf

62nd Annual Employee Benefits ConferenceNovember 13-16, 2016Orlando, Florida

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2017 Educational ProgramsGeneral Topics

63rd Annual Employee Benefits Conference October 22-25, 2017 Las Vegas, Nevadawww.ifebp.org/usannual

Trustees and Administrators InstitutesFebruary 20-22, 2017 Lake Buena Vista (Orlando), FloridaJune 26-28, 2017 San Diego, Californiawww.ifebp.org/trusteesadministrators

Fraud Prevention Institute for Employee Benefit PlansJuly 17-18, 2017Chicago, Illinoiswww.ifebp.org/fraudprevention

Construction Industry Benefits ConferenceNovember 13-14, 2017 Santa Monica, Californiawww.ifebp.org/construction

Collection Procedures InstituteNovember 15-16, 2017 Santa Monica, Californiawww.ifebp.org/collections

Related ReadingVisit one of the on-site Bookstore locations or see www.ifebp.org/bookstore for more books.

Employee Benefits Glossary, 13th EditionItem #7570www.ifebp.org/glossary

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