We agree with the district court that the factual allegations do not support Rubber Associates' claims of collusion and self-dealing, and so we decline to decide whether theories of collusion and self-dealing would justify equitable relief. The PBGC complied, and in 1991 issued its study on union-mandated withdrawals (the Report).2 The Report stated that a complete withdrawal occurs when an employer permanently ceases to have an obligation to contribute under the plan or permanently ceases all covered operations under the plan. Id. In particular, Barbara Caruso (Caruso) was employed by the Union at the same time she served as a Fund trustee. 1391. Id. The UFCW Unions & Employers Legal Assistance Fund is a valuable pre-paid legal services benefit and is available to eligible participants in Georgia and Alabama. The arbitrator found that although Rubber Associates was guilty of no unfair labor practices concerning the bargaining process, he was powerless to grant the equitable relief sought by Rubber Associates, and he ultimately awarded the Fund the full withdrawal liability in the amount of $1,713,169, as calculated according to the applicable statutory provision. United Food and Commercial Workers - Wikipedia Rubber Associates next argues that there is an awkward gap in ERISA's statutory scheme. After the United Food and Commercial Workers Union (the Union) disclaimed interest in representing the company's employees, Rubber Associates was deemed to have withdrawn from the Fund, pursuant to the Multiemployer Pension Protection Amendments Act of 1980 (MPPAA). 1384; id. It is important to know who the stewards are at your workplace so you know who to turn to if you have any questions or concerns. The Union proposed a $2,000 signing bonus for each employee, increased employer healthcare costs, and a modification of management rights that would allow Union employees to determine the rubber that the company would use. Legal notice: Courts have enjoined non-Associate UFCW agents from entering Walmart property, except to shop, in AR, CO, FL, OH, TX, and MD and from doing non-shopping activity inside CA stores. We agree with the district court that ERISA contains a comprehensive statutory and regulatory scheme for determining withdrawal liability and is not silent or ambiguous on the subject. Rubber Associates, 2015 WL 778781, at *5. at 22. The Report rejected suggestions that an employer be given the total forgiveness of all withdrawal liability and that the union have to pay withdrawal liability. Mut. Congress knew about the possibility of union-mandated withdrawals, was presented with several suggestions for legislative action, but ultimately chose not to act. Rubber Associates goes further, asserting that granting such relief would be inconsequential and could hardly be described as eroding ERISA policy goals. Id. T-c9KsB6lcBQYvD Z9nn3aPx/2 F D^hI>opT*tw~,N `:Gz (quoting 29 U.S.C. We will only be able to respond if you are a participant of the UFCW National Health and Welfare Fund. at 38. Learn more about FindLaws newsletters, including our terms of use and privacy policy. ), 8(a)(3) Changes in Terms and Conditions of Employment, 8(a)(5) Repudiation/Modification of Contract[Sec 8(d)/Unilateral Changes], 8(a)(5) Repudiation/Modification of Contract [Sec 8(d)/Unilateral Changes], 8(a)(1) Concerted Activities (Retaliation, Discharge, Discipline), 8(a)(1) Interrogation (including Polling), 8(b)(1)(A) Coercion, incl'g Statements and Violence, 8(b)(1)(A) Union Dues and/or Membership Related (including excessive fees), 8(a)(4) Changes in Terms and Conditions of Employment, Federal Mediation and Conciliation Service, Retail Sales / Distribution / Warehousing (Includes Food). . 282 0 obj <> endobj 1391, and there can be no gap where ERISA's text addresses the issue before the court. Allowing employers to reduce or eliminate their withdrawal liability even when faced with a union-mandated withdrawal is not essential to the promotion of fundamental ERISA policies. 5:14cv183, 2015 WL 778781, at *4 (N.D.Ohio Feb.24, 2015). Life Ins. The UFCW Consolidated Pension Fund is located in Atlanta, Georgia and provides Pension benefits for eligible Union employees across the United states. Instead of wondering what I would do to pay the bills, my local worked with me, they fought for me. N .]~lux`VGNWe[e7b2dK+4tv The right to retire - The United Food & Commercial Workers For example, under certain conditions, the employer will either not incur any withdrawal liability or will have reduced withdrawal liability if it ceases contributing to a plan due to a sale of its assets to another employer. Section 1451(a) provides that [a] plan fiduciary, employer, plan participant, or beneficiary, who is adversely affected by the act or omission of any party under this subtitle with respect to a multiemployer plan, or an employee organization which represents such a plan participant or beneficiary for purposes of collective bargaining, may bring an action for appropriate legal or equitable relief, or both. However, the Fund does not dispute standing, and as recognized by the district court, Statutory standing does not confer a substantive right. Rubber Associates, 2015 WL 778781, at *7. at 22. This is a profile preview from the PitchBook Platform. Insurance Email: insurancedepartment@ufcwemprfund.org, Pension Email: pensiondepartment@ufcwemprfund.org, Toll-Free: Those who do not have an Hour of Service on or after November 1, 2016, or who Win whats next. Rubber Associates is an Ohio corporation which manufactures custom rubber parts and whose employees were represented by the Union since 1973. The district court assumed that Rubber Associates was subjected to a union-mandated withdrawal as defined in the Report, and we assume the same. During arbitration, Rubber Associates contended that due to the nature of the union-mandated withdrawal, the calculation of its liability should be in accordance with a proposed alternative calculation. Each worksite has a Union Representative (sometimes called a Business Agent) union staff who regularly visit your worksite to inform you about whats happening around the union, and help make sure everyones rights are protected. If you arent sure, you can call your local union office and they will help you find out who to talk to. )ehlbjfnaiUXT\RZV^QY5yighXj-[msC=vS._z=~/_}o%qh3TD8A0&bqj#'\X{p@8-f;v0@K.K;zT%fYaQy2}RhcIc=V]}f[B!4v[ ,*V[ApKQjF3100i9a~_}P8#kh%K2=,'$Y2OHd4dh>!|B%$KF I,'$Y2OHd4dh>!|B%$KF I,'$Y2OHd4dh>!|B%$KF I,'$Yr}Tu3.RkQyv$9vV0Yia The Southern California United Food & Commercial Workers Unions and Food Employers Pension Fund and the United Food & Commercial Workers Unions and Food Employers Benefit Fund (the "Funds") were created more than 40 years ago, as a result of collective bargaining between the Southern California Retail Food Employers and the Southern California UFCW Union Locals. United Food and Commercial Workers Local 152 Benefit Funds Retail Meat Pension Fund Note: The Independent Packing Houses (IPH) Pension Fund has merged into the United Food and Commercial Workers Union Local 152 Retail Meat Pension Fund 1381(b)(1)). I{u\l]7P6#=S9dtMF`7 /` 3085, 87 L.Ed.2d 96 (1985) (We are reluctant to tamper with an enforcement scheme crafted with such evident care as the one in ERISA.). Jackson v. Sedgwick Claims Mgmt. United Food and Commercial Workers Unions & Employers Midwest Pension Fund Had Congress intended to create equitable relief for a union-mandated withdrawal, it certainly knew how to do sothe Report suggests possible rules for union-mandated withdrawals. In a 63 decision released on June 24, 2022, Dobbs v. Jackson Womens Health Organization, the Supreme Court majority overturned Roe v. Wade, holding that the authority to regulate abortion belongs to the states and not the federal government. The PBGC conclude[d] that a union-mandated withdrawal occurs in only the rarest of circumstances, and that any effect that such a withdrawal would have is minuscule when compared to the many thousands of ongoing collective bargaining relationships that are at work in the multiemployer pension plan setting. Id. Read orders here. Congress commissioned the Report and heeded its recommendation not to act. While working with each other and with our staff, their knowledge and experience come together to make a difference for all our Participants, Trustees and Employees. HWnF}cR}(6(HUbZ],Eu3s~-QfL7p&~[//_lDj)%*r.{fx;+=;O9]&4)oL%MG5I- More than 85% of all retirees have Electronic Funds Transfer of their Pension Benefit, Participating Local Unions across the United States. Union-mandated withdrawals fall into the category of complete withdrawals, and therefore ERISA is not silent or ambiguous on this issue. If you are, the steps to joining the UFCW are simple. 980, 190 L.Ed.2d 835 (2015) (quoting HandyClay v. City of Memphis, 695 F.3d 531, 538 (6th Cir.2012)). Congress enacted ERISA to ensure that if a worker has been promised a defined pension benefit upon retirementand if he has fulfilled whatever conditions are required to obtain a vested benefithe actually will receive it. Id. When considering a motion to dismiss, this court must accept all well-pleaded factual allegations of the [counterclaim] as true and construe the [counterclaim] in the light most favorable to the [claimant]. Reilly v. Vadlamudi, 680 F.3d 617, 622 (6th Cir.2012) (quoting Dubay v. Wells, 506 F.3d 422, 426 (6th Cir.2007)). The district court granted the Fund's motion to dismiss Rubber Associates' counterclaim, holding that Rubber Associates failed to state a claim for relief because [t]he Sixth Circuit has not heretofore recognized a claim under the federal common law of ERISA for equitable relief in the case of union-mandated withdrawals, and this Court finds no basis for doing so. United Food & Commercial Workers UnionEmployer Pension Fund v. Rubber Associates, Inc., No. Find your local union - The United Food & Commercial Workers International Union | The United Food & Commercial Workers International Union Start a Union Members Find your local union The UFCW has local union offices all across the contiguous United States, Alaska, Hawaii, Puerto Rico, and Canada. If you need assistance with your retirement benefits, please contact us at (800) 531-2385. Copyright 2023Present The United Food and Commercial Workers International Union (UFCW). You dont realize this until you get your bill and see the charges. 5. The remedy for Rubber Associates is to lobby Congress to carve out a special remedy for employers facing union-mandated withdrawals, not to ask this court to create law outside of the ERISA frameworkespecially where, as here, ERISA is not silent or ambiguous. If you need assistance with your retirement benefits, please contact us at(800) 531-2385. Have a question about the Covid-19 vaccine? The parties do not dispute that the Union's disclaimer of interest caused Rubber Associates' withdrawal from the Fund. Even if ERISA's failure to provide a remedy for the special subset of complete withdrawals at issue in this case could be described as a gap in the statutory scheme, there is no reason to believe the gap is awkward. Local 60682, 342 F.3d at 610; see also Bd. Estimate your retirement income and explore payment options for any projected future retirement date. Learn more about how your union contract works. hbbd``b`$@,~ $@D`@,GqD/ qa%#RG~ 1001a(c)(3)-(4). Kroger withdraws from UFCW pension fund to start new variable plan at 327, Page ID 2856. The Union acted unilaterally in disclaiming interest without any involvement by Rubber Associates. This Fund has approximately 300 contributing Employers, 81,000 active Participants and 68,000 retired Pensioners and Beneficiaries. Welcome to the family! A ]{;Nl(;JjQY8^Ceu This court has previously created federal common law under ERISA to provide for restitution claims, see Whitworth Bros. WASHINGTON, DC 20006, Source: Office of Labor-Management Standards, Year Covered: 2019 Last Updated: April 8th, 2021, Source: Office of Labor Management Standards, See All Employees' Compensation and Salary History. 'https://':'http://') + 'secure.wufoo.com/scripts/embed/form.js'; s.onload = s.onreadystatechange = function() { var rs = this.readyState; if (rs) if (rs != 'complete') if (rs != 'loaded') return; try { xti77mu0yuyuar = new WufooForm(); xti77mu0yuyuar.initialize(options); xti77mu0yuyuar.display(); } catch (e) { } }; var scr = d.getElementsByTagName(t)[0], par = scr.parentNode; par.insertBefore(s, scr); })(document, 'script'); All hours are EST for New Jersey office and PST for California office. N {'g-jVv NLT?kh,ki+$p1-O A shared lunchroom, or shared office space, between the Fund and the Union is surely not enough, nor are Rubber Associates' additional allegations, even when considered together as circumstantial proof. 1405(a). Please use this contact form for general questions and comments only. The Center for Union Facts is a 501(c)(3) nonprofit organization that fights for transparency and accountability in Americas labor movement. Appellant Br. hUO[U>}Be\"FJ uPelyln .27c"/44) QXK_:>DOKEd'M= 3pL$! Investigations are initiated based on various sources such as complaints from union members; information developed by OLMS as a result of reviewing reports filed; information developed during an OLMS audit of a unions books and records; and information obtained from other government agencies. Contact Information Home - The United Food & Commercial Workers International Union | The United Food & Commercial Workers International Union How We Make Work Better How to get better wages and benefits Work-Life Balance Fair scheduling and leave Access to affordable health care Workplace safety & keeping workers safe Right to work laws vs real job security Source: Federal Mediation and Conciliation Service. UFCW National Health & Welfare Fund Union stewards are fellow coworkers and union members who have been trained to represent their coworkers on management issues, contract violations and at disciplinary meetings. As a result, some of these pension fund may not be associated with the union. For all other matters, please send us an email to: UFCWFundSupport@UFCWNationalFund.org. In this case, creating an equitable remedy for union-mandated withdrawals will not close an awkward gap in the statutory scheme, because there is no gap to close. The PBGC suggested that Congress establish new rules under which a withdrawing employer would be required to pay whatever share of the plan's unfunded vested liabilities was attributable to that employer's participation. Id. All rights reserved. If you are, the steps to joining the UFCW are simple. Quite simply, Rubber Associates overreaches on this point. ERISA subjects such employers to no more and no less withdrawal liability than that determined according to the presumptive method. Find your local union - The United Food & Commercial Workers The Fund calculated Rubber Associates' withdrawal liability obligation to be $1,713,169, which the arbitrator awarded in full to the Fund. United Food & Commercial Workers Union Employer Pension Fund, Youre viewing 5 of 45 commitments. Rubber Associates argues against itself by stating that the fact that this is a case of first impression as no other court has addressed whether relief should be granted where a true union-mandated withdrawal has taken place, highlights the very minimal financial impact that granting such equitable relief would have on pension plans. Appellant Br. After decades of hard work, you deserve the rest and relaxation that comes with a secure retirement. The MPPAA provides that once a fund determines that an employer has withdrawn from its plan, the fund must notify the employer of the amount of the liability, prepare a schedule for liability payments, and demand payment in accordance with the schedule. DiGeronimo, 763 F.3d at 510 (citing 29 U.S.C. Currently, we administer over 70 different plans all over the United States, including: We need your full name, identification number and the name of your employer. The UFCW Consolidated Pension Fund is located in Atlanta, Georgia and provides Pension benefits for eligible Union employees across the United States. Rubber Associates errs in stating the issue at too narrow a level of generality. And [w]here ERISA allows for recovery on an issue under some but not all circumstances, ERISA is not silent on that issue. Girls Scouts of Middle Tenn., Inc. v. Girl Scouts of U.S .A., 770 F.3d 414, 421 (6th Cir.2014) (citing Local 60682, 342 F.3d at 609). at 2829. endstream endobj startxref Unless fund trustees adopt an alternative calculation method for the plan with PBGC approval, or amend the plan to adopt another method in 1391, ERISA requires withdrawal liability to be calculated using the statutory presumptive method, which is the calculation method the Fund correctly applied in this case. The PBGC identified several problems with each of these proposals before recommending no change in existing law. As was customary, Rubber Associates requested an estimate of withdrawal liability from the Fund, and the Fund estimated $1,518,872 in withdrawal liability in January 2007. Treating its factual allegations as true and assuming that collusion would justify equitable relief, Rubber Associates has simply failed to allege collusion and self-dealing. Box 3891 Oak Brook, IL 60522-3891 Fax Number (312) 329-7923 Email Inquiries Corp. v. R.A. Gray & Co., 467 U.S. 717, 720, 104 S.Ct. Rubber Associates requested review of the withdrawal liability assessment and offered to resume making contributions to the Fund on November 1, 2010. In short, if an employer withdraws from a multiemployer fund, it must make a payment of withdrawal liability, which is calculated as the employer's proportionate share of the fund's unfunded vested benefits [. The United Food and Commercial Workers Union is North Americas largest and strongest private sector union. 1001(b) (emphasis added). Ufcw Npf Id. The NLRB ruled in Rubber Associates' favor on the major allegations. You can use this site to download forms and publications, apply online, contact the Fund Office, or access related sites. NF0 #&JY#V Kroger Co. ratified an agreement to withdraw from the United Food and Commercial Workers International Union-Industry Pension Fund and contribute to a new variable annuity pension plan . The email address cannot be subscribed. For the first five, OLMS requires unions to provide detailed information on any recipient that received more than $5,000 per year. UNITED FOOD AND COMMERCIAL WORKERS UNIONEMPLOYER PENSION FUND; Robert W. Grauvogl; Barbara Caruso; Carl Ivka; F. Steven Albrecht; John Halkias; Ray Huber, PlaintiffsAppellees, v. RUBBER ASSOCIATES, INC., DefendantAppellant. UFCW: Retirement of Millions of Americans Threatened by New The district court granted the Fund's motion to dismiss Rubber Associates' counterclaim. zJDybv*Ly-%1W7$ * ,gqq~VzdTad^xV+;)B?&fW^%- Because of our diversity, many of our members may be covered under different retirement funds. Secretary, Treasurer & Union Board Trustee, United Food and Commercial Workers Unions & Employers Midwest Pension Fund, Youre viewing 5 of 28 commitments. Rubber Associates withdrew its proposal for the 30cent rate and agreed to maintain its previous contribution rate of 62 cents, which the Union accepted. However, there is no authority that would forbid Caruso from serving both the Union and the Fund at the same time. endstream endobj 23 0 obj <> endobj 24 0 obj <> endobj 25 0 obj <>stream Our Executive Team brings a wealth of experience and leadership to the day-to-day operations of UFCW Unions & Employers Benefits Administration, LLC. To see a list of these Trustees and the other professional who serve the fundclick here. Retail Meat Pension Fund - Local 152 Benefit Funds The Union did not recommend the contract and authorized a strike.1. hb```a``f`f B@9f @AI!da`I`ee&{z&1?@$9XC\ With minor exceptions a plan determines the amount of unfunded vested benefits allocable to a withdrawing employer in accordance with the presumptive method, unless the plan is amended to adopt an alternative allocative method, which [g]enerally, the PBGC must approve. 29 C.F.R. var xti77mu0yuyuar; (function(d, t) { var s = d.createElement(t), options = { 'userName':'issisite', 'formHash':'xti77mu0yuyuar', 'autoResize':true, 'height':'645', 'async':true, 'host':'wufoo.com', 'header':'show', 'ssl':true }; s.src = ('https:' == d.location.protocol ? Qhidu=p at 17. %%EOF Keep an eye out for our new Participant Portal where you will be able to access more personalized information about your benefits. At least one transport union is objecting to a clause in the Transnet Pension Fund Amendment Bill that is before parliament. %PDF-1.6 % 2709, 81 L.Ed.2d 601 (1984). United Food & Commercial Workers - Union Facts UFCW Unions and Employers Benefits Administration, LLC. In late 2006 or early 2007, Rubber Associates and the Union began negotiations for a new CBA. Get the full list, Morningstar Institutional Equity Research, President of Boards of Trustees & Plan Sponsor. This shall be in accordance with the Participation Agreement letter signed by the Company, dated April 20,1990. These purposes would not be fulfilled by allowing employers to seek equitable relief from their withdrawal liability, even in the event of a union-mandated withdrawal. 29 U.S.C. The Retail, Wholesale and Department Store Union District Council serves members in the retail food and food processing, retail and department stores, service, manufacturing and warehousing industries. United Food & Commercial Workers Union Employer Pension Fund 4211.1(a). g@xrJtrZ@-A-/Cfsk  n{:c9X}}mm'vf=t[=WQf}#wiY\nNd2EV^=\VQ4^j#"*5mX_++ //-f4)/LBs1`m9Bp_bOp$Hv)m%pi+aw")?U{RNhjbtj\~u#dGU4Cx1_MAkD*A%OE'F_$)kWF/`ARXirum R b!U[[%[JBz0DI0gj/,jg"kK= Rubber Associates contends that the Report should be afforded weight as interpretative guidance. Appellant Br. of Calif., Inc. v. Constr. Win whats next. Mid Atlantic Ufcw And Participating Employers Pension Fund, Ufcw - Northern California Employers Joint Pension, Desert States Employers & Ufcw Unions Pension Plan, Rocky Mountain Ufcw Unions And Employers Pension Plan, Ufcw Union Local No.655, Food Employers' Joint Pension Plan, Ufcw Local 1776 & Participating Employers Pension Fund, Central Ohio Ufcw Unions And Retail Employers Pension Plan, Employees Retirement System Of H. J. Heinz Company Plan B/c For Heinz Employees Represented By Ufcw, Ufcw Pharmacists, Clerks And Drug Employers Pension Trust, Ufcw Unions And Participating Employers Pension Plan, Retail Food Employers & Ufcw Local 711 Pension, Ufcw Union & Partcipating Food Industry Employers Tri-state Pension Fund, Ufcw Union Local 919 & Contributing Employers' Food Pension Fund, Kunzler & Company, Inc. Ufcw Union Employees' Pension Plan, Cooperativa de Ahorro y Credito de Cabo Rojo. See 29 C.F.R. Thereafter, negotiations resumed without success. For more information about this Notice, you may contact the Board of Trustees, United Food and Commercial Workers Union and Participating Food Industry Employers Tri-State Pension Fund, 3031 B Walton Road, Plymouth Meeting, PA 19462, telephone (866 . 1391(c)(1); 29 C.F.R. All rights reserved. Thank you for being a part of the United Food and Commercial Workers International Union. Plan benefits are comprehensive; they cover legal services related to certain criminal and consumer actions. Bloomberg. Stay tuned! Yi*{l$O=A3. In order to decertify a union, a majority of the unionized employees must vote to remove the union in an election overseen by the National Labor Relations Board (NLRB). Finally, Rubber Associates cites a Third Circuit opinion from 1988 for the proposition that federal courts may fashion equitable relief pursuant to ERISA based on the alleged collusion and self-dealing of the Fund and the Union.5 Although Carl Colteryahn Dairy, Inc. v. Western Pennsylvania Teamsters & Employers Pension Fund, 847 F.2d 113 (3d Cir.1988), dealt with outright fraud, which Rubber Associates admits is not present in this case, Rubber Associates asserts that Colteryahn may serve as the source of law for its claim based on the alleged collusion and self-dealing between the Union and the Fund. PitchBook provides insight into a limited partners preferred investments, including actual and target allocations by strategy, secondary market preferences and interest in first-time funds. K Have a question about the Covid-19 vaccine? Although separate entities, the Union and the Fund are interrelated: The Fund's Board of Trustees is composed of Union and employer trustees, who were named as individual plaintiffs in the complaint. The UFCW is made up of 1.4 million members people working together to improve their lives and their future. To our UFCW Brothers and Sisters, we are here for you. 289 0 obj <>/Filter/FlateDecode/ID[<5217F1833AB74FD0B0B4396888253D80>]/Index[282 10]/Info 281 0 R/Length 47/Prev 662230/Root 283 0 R/Size 292/Type/XRef/W[1 2 0]>>stream Union objects to exclusive membership of Transnet pension fund The Office of Labor-Management Standards (OLMS) conducts investigations to determine if violations of the Labor-Management Relations and Disclosure Act (LMRDA) provisions have occurred. 4211.1(a). 35 0 obj <>/Filter/FlateDecode/ID[<7C696E16A7964E82B88CB654B480D139>]/Index[22 22]/Info 21 0 R/Length 72/Prev 1570117/Root 23 0 R/Size 44/Type/XRef/W[1 2 1]>>stream Congress's failure to provide a special remedy for a subset of complete withdrawals does not evince silence on the issue, and Rubber Associates' argument in this regard is misplaced.4. UFCW Unions & Employers Health & Welfare Fund Atlanta ("Atlanta Fund") is located in Atlanta, Georgia. President Biden recently signed the Inflation Reduction Act into law. The Fund calculated Rubber Associates' withdrawal liability in accordance with the MPPAA's presumptive method, and the parties agree that, if the presumptive method is to be applied, the Fund accurately calculated Rubber Associates' withdrawal liability. You can print your 2022 1095-B tax form in the UFCW Participant Portal! United Food and Commercial Workers Unions & Employers Midwest Pension Fund is a multi-employer defined benefit union pension fund based in Rosemont, Illinois. From negotiating with employers to improve working conditions to organizing community food drives, we know together we can make a difference and improve the lives of those around us. O z^!&M9GS=/@ L~$Wkf%k Congress declared the policy of the MPPAA as follows: (1) to foster and facilitate interstate commerce, (2) to alleviate certain problems which tend to discourage the maintenance and growth of multiemployer pension plans, (3) to provide reasonable protection for the interests of participants and beneficiaries of financially distressed multiemployer pension plans, and (4) to provide a financially self-sufficient program for the guarantee of employee benefits under multiemployer plans. H;>T `(CQDHHZDD_Y_hRe`apA3 # #Y(rl`I$#+@;BR0pEf!P5FAn "*&.! The hospital is in-network, the doctor who treats her is in-network, but the radiologist is out-of-network. "0 kg The Fund initially calculated Rubber Associates' withdrawal liability as $1,707,116, which was eventually revised upward to $1,713,169, using ERISA's presumptive statutory method of allocating unfunded vested benefits to withdrawing employers.

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