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    Filed August 14, 2000
    
    UNITED STATES COURT OF APPEALS
    FOR THE THIRD CIRCUIT
    
    No. 99-3775
    
    HARRY BELLAS
    
    v.
    
    CBS, INC.; WESTINGHOUSE PENSION PLAN,
    
           Appellants
    
    On Appeal from the United States District Court
    for the Western District of Pennsylvania
    (D.C. Civ. No. 98-1455)
    District Judge: Hon. Donetta W. Ambrose
    
    Argued June 15, 2000
    
    BEFORE: GREENBERG and McKEE, Circuit Judges,
    and SHADUR,* District Judge
    
    (Filed: August 14, 2000)
    
    Henry W. Ewalt
    George M. Medved
    David J. Kolesar
    Pepper Hamilton LLP
    50th Floor, One Mellon Bank Center
    500 Grant Street
    Pittsburgh, PA 15219-2502
    
    
    
    _________________________________________________________________
    * Honorable Milton I. Shadur, Senior Judge of the United States District
    Court for the Northern District of Illinois, sitting by designation.
    
    
           Brian T. Ortelere
           Pepper Hamilton LLP
           3000 Two Logan Square
           18th and Arch Streets
           Philadelphia, PA 19103-2799
    
           Andrew M. Kramer
           Glen D. Nager (argued)
           Gregory G. Katsas
           Charles V. Stewart
           Todd C. Amidon
           Jones, Day, Reavis & Pogue
           51 Louisiana Avenue, NY
           Washington, D.C. 20001-2113
    
           Dennis Derr
           CBS Corporation
           11 Stanwix Street
           Pittsburgh, PA 15222-1384
    
            Attorneys for Appellants
    
           Theodore Goldberg
           David B. Rodes (argued)
           John T. Tierney, III
           Goldberg, Persky, Jennings & White
           1030 Fifth Avenue
           Pittsburgh, PA 15219
    
           William T. Payne
           Schwartz, Steinsapir, Dohrman
            & Sommers
           1007 Mount Royal Boulevard
           Pittsburgh, PA 15223
    
            Attorneys for Appellee
    
                                    2
    
    
           Trevor W. Swett
           Kent A. Mason
           Albert G. Lauber
           Michael T. Doran
           Jason K. Bortz
           Caplin & Drysdale
           One Thomas Circle, N.W.
           Washington, D.C. 20005-5802
    
            Attorneys for Amicus Curiae
           Association of Private Pension and
           Welfare Plans
    
    OPINION OF THE COURT
    
    GREENBERG, Circuit Judge.
    
    I. INTRODUCTION
    
    This matter has been certified for interlocutory appeal to
    address a question of first impression in this court, i.e.,
    whether a permanent job separation benefit contained
    within a pension plan constitutes an early retirement
    benefit or retirement-type subsidy protected by the anti-
    cutback provisions of the Employee Retirement Income
    Security Act of 1974 ("ERISA"), 29 U.S.C.SS 1001 et seq.,
    as amended by the Retirement Equity Act of 1984 ("REA")
    and the Omnibus Reconciliation Act of 1987. The district
    court had jurisdiction pursuant to 28 U.S.C. S 1331 and
    ERISA section 502(e), 29 U.S.C. S 1132(e).
    
    On June 29, 1999, the district court granted plaintiff-
    appellee Harry Bellas's motion for partial summary
    judgment, see Bellas v. CBS, Inc., 73 F. Supp.2d 500 (W.D.
    Pa. 1999), and denied defendants-appellants CBS, Inc.'s
    and Westinghouse Pension Plan's motion to dismiss the
    complaint. See Bellas v. CBS, Inc., 73 F. Supp.2d 493 (W.D.
    Pa. 1999). On July 13, 1999, appellants filed a motion to
    certify the order granting Bellas's motion for partial
    summary judgment for an interlocutory appeal pursuant to
    28 U.S.C. S 1292(b) which the district court granted on July
    29, 1999. Subsequently, the appellants filed a petition for
    
                                    3
    
    
    permission to appeal under section 1292(b), which we
    granted on September 10, 1999.
    
    a. Parties and Factual Background
    
    Bellas, a former employee of CBS and Westinghouse
    Electric Corporation, on August 31, 1998, filed this action
    on behalf of himself and all others similarly situated
    against CBS and the Westinghouse Pension Plan, alleging
    that the Westinghouse Plan was amended impermissibly by
    first the narrowing, and then the elimination entirely, of a
    "Special Retirement Provision" in the plan that was
    applicable to senior employees terminated as a result of a
    "Permanent Job Separation." See J.A. at 269. Because CBS
    is the plan sponsor and administrator and is a successor to
    Westinghouse, CBS and Westinghouse may be considered
    one entity for purposes of this appeal and thus we will refer
    to the corporate defendant as CBS even though
    Westinghouse previously employed Bellas. Bellas contends
    that these amendments had the effect of eliminating or
    reducing an early retirement benefit or retirement-type
    subsidy in contravention of the REA amendments to ERISA
    codified at section 204(g), 29 U.S.C. S 1054(g). Bellas
    further claims that in adopting and implementing these
    amendments, CBS violated its fiduciary duties of acting
    solely in the interest of plan participants and beneficiaries
    in administering the plan in accordance with both the
    governing documents and instruments and ERISA, and of
    exercising care, prudence, and diligence in the performance
    of its responsibilities and thereby violated ERISA.
    
    Section 20 of the pre-1994 version of the Westinghouse
    Plan provided a "Special Retirement Provision" for
    employees meeting stated age and service requirements
    who were terminated as a result of a "Permanent Job
    Separation" (the "PJS Benefit"). In particular, Section 20 of
    the pre-1994 version of the plan provided in relevant part:
    
           B. 1. An Employee whose employment is terminate d
           as a result of a Permanent Job Separation, who at the
           time of such Permanent Job Separation does not
           satisfy any of the requirements for retirement pursuant
           to Section 2 of the Plan, may retire on his Special
    
                                    4
    
    
           Retirement Date or on the first day of any month
           following his Special Retirement Date if, by the end of
           the calendar year in which he is separated, he would
           have satisfied one of the age-and-service combinations
           set forth below had he remained continuously
           employed to the end of such year:
    
           -- Age 50 or over with twenty-five (25) or mor e years
           of Eligibility Service,
    
           -- Age 51 or over with twenty-two (22) or more y ears
           of Eligibility Service,
    
           -- Age 52 or over with nineteen (19) or more yea rs of
           Eligibility Service,
    
           -- Age 53 or over with sixteen (16) or more year s of
           Eligibility Service,
    
           -- Age 54 or over with thirteen (13) or more yea rs of
           Eligibility Service,
    
           -- Age 55 or over with ten (10) or more years of
           Eligibility Service.
    
           2. The amount of monthly pension payable to an
           Employee who satisfies the requirements set forth in
           Subsection 20.B.1 above shall be the sum of (a), (b) and
           (c) below:
    
           (a) Any amounts computed pursuant to Section 4 of
           the Plan [Section 4 is entitled "Normal Retirement
           Pension"].
    
           (b) Ten ($10.00) dollars multiplied by his Credite d
           Service.
    
           (c) If the Employee had twenty-five (25) years o f
           eligibility Service and his Special Retirement Date is on
           or before September 1, 1994, an additional $100.
    
           The amounts calculated in accordance with Subsection
           20.B.2 above shall be based on the provisions of the
           Plan in effect on the Employee's Special Retirement
           Date.
    
           3. The amount calculated in accordance with
           Subsection 20.B.2 (a) shall be payable for the lifetime of
    
                                    5
    
    
           the Employee and shall be subject to all of the optional
           forms of payments described in Section 10.
    
           4. The amounts calculated in accordance with
           Subsections 20.B.2 (b) and 20.B.2 (c) shall be payable
           up to and including the month in which the Employee
           attains his 62nd birthday. These amounts shall not be
           subject to any of the optional forms of payment
           described in Section 10, except the Lump Sum form
           described in Subsection 10.C.5.
    
    J.A. at 74-75.
    
    The pre-1994 version of the Westinghouse Plan, in
    pertinent part, defined the term "Permanent Job
    Separation" as meaning "the termination of the employment
    of an Employee . . . through no fault of his own through
    lack of work for reasons associated with the business for
    whom [the employer] determines there is no reasonable
    expectation of recall." Id. at Section 1, J.A. at 38. Further,
    the Pre-1994 Summary Plan Description explains with
    respect to this provision:
    
           [t]he amount of your special retirement pension is the
           full amount you have earned to the date you are
           permanently separated. There are no reductions
           applied to your pension, even though you are retiring
           early. If you are under age 62, you receive a monthly
           early retirement supplement of $10 for each year of
           credited service. This supplement stops when you turn
           age 62.
    
           If you have at least 25 years of eligibility service, you
           receive an additional $100 per month until you turn
           age 62. This additional $100 per month is available
           only if your special retirement pension begins on or
           before September 1, 1994.
    
    J.A. at 110.
    
    The pre-1994 version of the Plan also contained a
    "Normal Retirement Pension" provision and an"Early
    Retirement Pension" provision. See pre-1994 version of the
    Westinghouse Plan, Sections 4-5, J.A. at 42-48.
    
    On January 1, 1994, the Westinghouse Plan was
    
                                    6
    
    
    amended to alter participants' entitlement to the PJS
    Benefit in two respects: (1) the amendments made it harder
    to qualify for the PJS Benefit after January 1, 1997, by
    narrowing the definition of "Permanent Job Separation" to
    apply only if an employee's employment termination was
    due to a job movement, product line relocation, or location
    close-down and (2) the amendments eliminated the PJS
    Benefit in toto for terminations on or after September 1,
    1998.1 More specifically, the definition of the term
    "Permanent Job Separation" was redefined in the 1994
    version of the plan, in relevant part, to read as follows:
    
           Permanent Job Separation means, for periods prior to
           January 1, 1997, the termination of the employment of
           an Employee with an Employer . . . through no fault of
           his own for lack of work for reasons associated with
           the business for whom such Employer . . . determines,
           on a uniform and nondiscriminatory basis, that there
           is no reasonable expectation of recall.
    
           . . . .
    
           For periods on or after January 1, 1997 and before
           September 1, 1998, a Permanent Job Separation
           means solely the termination of the employment of an
           Employee with an Employer. . . because of job
           movement or product-line relocation, or location
           closedown, as those terms are defined below. . . .
           Layoffs due to adjustments in the workforce caused by
           changes in production requirements, manufacturing
    _________________________________________________________________
    
    1. With respect to the total elimination of the Special Retirement Pension
    after September 1, 1998, appellants, without providing any supporting
    documentation, explained in their opposition to Bellas's motion for
    summary judgment that "[t]he Plan was amended in 1998 to extend the
    1994 PJS [Permanent Job Separation] benefit because of job movement
    or product-line relocation, or location closedown until the year 2000."
    See Bellas, 73 F. Supp.2d at 502-03 n.2 (citing Defendants' Opposition
    to Plaintiff 's Motion for Summary Judgment, p. 6 n.7). For purposes of
    its decision, the district court concluded it was immaterial whether or
    not the amendments totally eliminated the Special Retirement Pension
    after September 1, 1998, because appellants did not dispute that by
    amending the Westinghouse Plan to narrow the definition of "Permanent
    Job Separation," a participant's ability to receive a PJS Benefit under the
    Westinghouse Plan was reduced.
    
                                    7
    
    
           processes, sales volume, inventory levels, make or buy
           decisions, decisions to discontinue a product line, or
           any other reasons associated with the business shall
           not be a job movement or product-line relocation. . . .
           In no event shall a Permanent Job Separation occur
           after August 31, 1998.
    
    1994 Version of the Westinghouse Plan, J.A. at 131-32.
    
    CBS employed Bellas in its nuclear division from 1964
    until December 31, 1997, during which employment he was
    a participant in the Westinghouse Plan at all relevant times
    before December 31, 1997, including the time of the
    adoption of the 1994 amendments. Bellas was notified of
    the amendments either in late 1994 or upon the
    distribution of the January 1, 1995 Summary Plan
    Description of the Westinghouse Plan.
    
    CBS terminated Bellas's employment on December 31,
    1997, through no fault of his own, for lack of work for
    reasons associated with CBS's business and with no
    reasonable expectation of recall. At the time of his
    termination, Bellas was over 50 years of age and had 30
    years of service with CBS. Under the pre-1994 version of
    the Westinghouse Plan, upon his termination Bellas would
    have satisfied all of the conditions necessary to receive the
    PJS Benefit (i.e. age, years of service, and reason for
    termination).
    
    b. Procedural History
    
    Bellas filed this class action on August 31, 1998, against
    CBS and the Westinghouse Pension Plan. Count one of the
    complaint alleged that the 1994 amendments to the
    Westinghouse Plan, which amended eligibility conditions for
    receipt of PJS Benefits, violated section 204(g) of ERISA.
    See J.A. at 275. Count two of the complaint alleged that, in
    adopting and implementing those amendments, CBS
    violated fiduciary duties imposed under ERISA. See id. at
    275-76. While appellants deny that they violated ERISA,
    they do not dispute that the amendments greatly reduced
    Bellas's benefits.
    
    Appellants moved to dismiss the complaint, and Bellas
    moved for partial summary judgment on the question of
    
                                    8
    
    
    whether the 1994 plan amendments violated section 204(g).
    As we have indicated, on June 29, 1999, the district court
    denied appellants' motion to dismiss, see Bellas v. CBS,
    Inc., 73 F. Supp.2d 493, and granted Bellas's motion for
    partial summary judgment. See Bellas v. CBS, Inc., 73 F.
    Supp.2d 500.
    
    In reaching its decision that the plan amendments
    violated ERISA section 204(g), the district court adopted
    reasoning directly contrary to the Internal Revenue
    Service's interpretation of IRC S 411(d)(6), the IRC's
    counterpart to section 204(g), as set forth in its General
    Counsel's Memorandum ("GCM") 39869 dated April 6,
    1992, a memorandum that we consider later as a central
    matter on this appeal. Recognizing the direct conflict
    between its ruling and the IRS interpretation, the district
    court granted appellants' motion to certify the partial
    summary judgment order for an interlocutory appeal. See
    J.A. at 316-17. As we have indicated, we granted
    appellants' subsequent petition for permission to appeal.
    See id. at 1.
    
    The district court set forth the controlling question of law
    in its order granting appellants' motion to certify the partial
    summary judgment order for interlocutory appeal, as:
    
           Whether the Permanent Job Separation benefit
           contained in the pre-1994 version of the Westinghouse
           Pension Plan is a retirement-type subsidy protected by
           section 204(g) of ERISA, 29 U.S.C. S 1054(g).
    
    J.A. at 316.
    
    II. DISCUSSION
    
    We exercise plenary review with respect to the district
    court's order on the motion for partial summary judgment.
    See Seibert v. Nusbaum, Stein, Goldstein, Bronstein &
    Compeau, 167 F.3d 166, 170 (3d Cir. 1999); Petruzzi's IGA
    Supermarkets, Inc. v. Darling-Delaware Co., 998 F.2d 1224,
    1230 (3d Cir. 1993). We will affirm only if we conclude that
    the pleadings, depositions, answer to interrogatories and
    admissions on file, together with the affidavits, show that
    the party who obtained summary judgment on a point was
    
                                    9
    
    
    entitled to that judgment as a matter of law and that there
    was no genuine dispute of material fact standing in his or
    her way. See Fed. R. Civ. P. 56(c). Here, however, it is clear
    that we are not concerned with disputed questions of fact
    and thus our determination is essentially legal in nature.
    
    We start our discussion of the issues by recognizing that
    ERISA neither mandates the creation of pension plans nor
    in general dictates the benefits a plan must afford once
    created. See Smith v. Contini, 205 F.3d 597, 602 (3d Cir.
    2000); Dade v. North Am. Philips Corp., 68 F.3d 1558, 1561
    (3d Cir. 1995) (citing Hlinka v. Bethlehem Steel Corp., 863
    F.2d 279, 283 (3d Cir.1988); H.R.Rep. No. 807, 93d Cong.,
    2d Sess., reprinted in 1974 U.S.C.C.A.N. 4639, 4670, 4677).
    Only the plan itself can create an entitlement to benefits.
    Consequently, "[this court is] required to enforce the Plan
    as written unless [it] can find a provision of ERISA that
    contains a contrary directive." Dade, 68 F.3d at 1562.
    
    The protection of retirement benefits reflects the
    underlying policy goals of ERISA. Congress's chief purpose
    in enacting the statute was to ensure that workers receive
    promised pension benefits upon retirement. See Nachman
    Corp. v. Pension Benefit Guaranty Corp., 446 U.S. 359, 375,
    100 S.Ct. 1723, 1733 (1980); see also Smith, 205 F.3d at
    604. In constructing ERISA, Congress perceived the
    statute's accrual and vesting provisions as the heart of that
    protection. See Hoover v. Cumberland, Maryland Area
    Teamsters Pension Fund, 756 F.2d 977, 985 (3d Cir. 1985).
    Accordingly, it recognized that
    
           `Unless an employee's rights to his accrued pension
           benefits are nonforfeitable, he has no assurance that
           he will ultimately receive a pension. Thus, pension
           rights which have slowly been stockpiled over many
           years may suddenly be lost if the employee leaves or
           loses his job prior to retirement. Quite apart from the
           resulting hardships, . . . such losses of pension rights
           are inequitable, since the pension contributions
           previously made on behalf of the employee may have
           been made in lieu of additional compensation or some
           other benefit which he would have received.'
    
    Smith, 205 F.3d at 604 (quoting S.Rep. No. 383, 93d Cong.,
    2d Sess., reprinted in 1974 U.S.C.C.A.N. 4890, 4930).
    
                                    10
    
    
    Therefore, in Hoover, we concluded that a plan amendment
    that retroactively reduced benefits promised to plaintiffs for
    almost seven years was precisely the sort of inequity
    Congress designed ERISA to prevent. See 756 F.2d at 985-
    86.
    
    As we have indicated, this appeal presents the question
    of whether the PJS Benefits provided for in the
    Westinghouse Plan constitute accrued benefits protected by
    the anti-cutback provisions of ERISA section 204(g). Section
    204(g) prohibits an employer from decreasing or eliminating
    a participant's accrued benefits by plan amendment. See 29
    U.S.C. S 1054(g). Before 1984, ERISA did not protect early
    retirement benefits or retirement-type subsidies because
    they were not considered to be accrued benefits. See
    Bencivenga v. Western Pa. Teamsters and Employers
    Pension Fund, 763 F.2d 574, 577 (3d Cir. 1985). 2
    
    While the definition of an accrued benefit has not been
    modified, Congress did modify section 204(g) in 1984 to the
    end that early retirement benefits and retirement-type
    subsidies were defined as being accrued for purposes of
    ERISA's anti-cutback provisions. See Retirement Equity Act
    ("REA"), Pub.L. No. 98-397. Thus, ERISA section 204(g), as
    amended, provides:
    
           (g) Decrease of accrued benefits through amendme nt of
           plan
    
            (1) The accrued benefit of a participant und er a plan
           may not be decreased by an amendment of the plan,
           other than an amendment described in section
           1082(c)(8) or 1441 of this title.
    
            (2) For purposes of paragraph (1), a plan amen dment
           which has the effect of--
    _________________________________________________________________
    
    2. ERISA defines an accrued benefit as "in the case of a defined benefit
    plan, the individual's accrued benefit determined under the plan and . . .
    expressed in the form of an annual benefit commencing at normal
    retirement age." 29 U.S.C. S 1002(23)(A). ERISA defined normal
    retirement age as the earlier of the normal retirement age under the plan
    or the age of 65. See id. S 1002(24). Because an early retirement
    provided a benefit commencing before normal retirement age, such a
    benefit was found not to fall within the definition of an "accrued benefit."
    See Bencivenga, 763 F.2d at 577.
    
                                    11
    
    
             (A) eliminating or reducing an early retir ement
           benefit or a retirement-type subsidy (as defined in
           regulations), or
    
             (B) eliminating an optional form of benefit,
    
           with respect to benefits attributable to service before
           the amendment shall be treated as reducing accrued
           benefits. In the case of a retirement-type subsidy, the
           preceding sentence shall apply only with respect to a
           participant who satisfies (either before or after the
           amendment) the preamendment conditions for the
           subsidy. The Secretary of the Treasury may by
           regulations provide that this subparagraph shall not
           apply to a plan amendment described in subparagraph
           (B) (other than a plan amendment having an effect
           described in subparagraph (A)).
    
            (3) For purposes of this subsection, any--
    
             (A) tax credit employee stock ownership pl an (as
           defined in section 409(a) of Title 26), or
    
             (B) employee stock ownership plan (as defined in
           section 4975(e)(7) of Title 26),
    
           shall not be treated as failing to meet the requirements
           of this subsection merely because it modifies
           distribution options in a nondiscriminatory manner.
    
    29 U.S.C. S 1054(g).3
    _________________________________________________________________
    
    3. IRC S 411(d)(6) which parallels section 204(g) is relevant to our
    discussion. Section 411(d)(6) provides:
    
           Accrued benefit not to be decreased by amendment.--
    
           (A) In general.--A plan shall be treated as not satisfying the
           requirements of this section if the accrued benefit of a participant is
           decreased by an amendment of the plan, other than an amendment
           described in section 412(c)(8), or section 4281 of the Employee
           Retirement Income Security Act of 1974.
    
           (B) Treatment of certain plan amendments.--For p urposes of
           subparagraph (A), a plan amendment which has the effect of--
    
           (i) eliminating or reducing an early retirement be nefit or a
           retirement-type subsidy (as defined in regulations), or
    
                                    12
    
    
    After 1984, a plan sponsor could eliminate prospectively
    an early retirement benefit by amendment, but under
    section 204(g) the amendment could not adversely affect
    that portion of an early retirement benefit that already had
    accrued to a plan participant who satisfied the pre-
    amendment conditions for the benefit either before or after
    the amendment. See 29 U.S.C. S 1054(g); Dade, 68 F.3d at
    1562. Thus, if the 1994 Westinghouse Plan amendments
    reduced or eliminated early retirement benefits or
    retirement-type subsidies, the amendments would have had
    to allow employees who remained employed by CBS after
    the amendments to "grow into" the benefit. See id. at 1562.
    
    Of course, we are required to enforce the Westinghouse
    Plan as written unless we can find a provision of ERISA
    that contains a contrary directive. See Dade, 68 F.3d at
    1562. The question then is whether section 204(g) is such
    a directive and this in turn depends on the contingent
    nature of the PJS Benefits.
    
    There is no question but that a standard early retirement
    benefit, provided exclusively upon the satisfaction of certain
    age and/or service requirements, is an accrued benefit that
    is protected by section 204(g). See, e.g., Gillis v. Hoechst
    Celanese Corp., 4 F.3d 1137, 1143-44 (3d Cir. 1993); see
    _________________________________________________________________
    
           (ii) eliminating an optional form of benefit,
    
           with respect to benefits attributable to service before the
           amendment shall be treated as reducing accrued benefits. In the
           case of a retirement-type subsidy, the preceding sentence shall
           apply only with respect to a participant who satisfies (either before
           or after the amendment) the preamendment conditions for the
           subsidy. The Secretary may by regulations provide that this
           subparagraph shall not apply to a plan amendment described in
           clause (ii) (other than a plan amendment having an effect described
           in clause (i)).
    
    IRC S 411(d)(6). "Regulations prescribed by the Secretary of the Treasury
    under section[ ] . . . 411 . . . of Title 26 . . . shall also apply to the
    minimum participation, vesting, and funding standards set forth in
    [ERISA]." 29 U.S.C. S 1202(c). Accordingly, the interpretation of section
    411(d)(6) is relevant to the instant appeal; section 204(g) and section
    411(d)(6) are meant to be interpreted consistently. See id.
    
                                    13
    
    
    also Ahng v. Allsteel, Inc., 96 F.3d 1033, 1034 (7th Cir.
    1996); Richardson v. Pension Plan of Bethlehem Steel, 67
    F.3d 1462, 1467-68 (9th Cir. 1995); Constantino v. TRW,
    Inc., 13 F.3d 969, 977 (6th Cir. 1994); Hunger v. AB, 12
    F.3d 118, 120 (8th Cir. 1993); Harms v. Cavenham Forest
    Indus., Inc., 984 F.2d 686, 692 (5th Cir. 1993); Aldridge v.
    Lily-Tulip, Inc., Salary Retirement Plan Benefits Comm., 953
    F.2d 587, 590 (11th Cir. 1992). Despite the agreement that
    surrounds this general principle, the extension of section
    204(g)'s coverage to benefits whose payment is contingent
    upon the occurrence of an unpredictable event,4 as are the
    PJS Benefits at issue on this appeal as their availability
    was triggered by employment termination, has led to a split
    of authority.
    
    a. Defining the Terms Early Retirement Benefit and
    Retirement-Type Subsidy
    
    ERISA does not specifically set forth the definition of
    early retirement benefit or retirement-type subsidy. Rather,
    Congress contemplated that the Treasury Department
    would promulgate regulations setting forth the definition of
    retirement-type subsidy. See 29 U.S.C. S 1054(g)(2)(A). To
    date, the Treasury has not promulgated or proposed any
    such regulations.5 Nevertheless, on a general level, the
    _________________________________________________________________
    
    4. In this case, the Pre-1994 Westinghouse Plan provided benefits
    contingent upon certain involuntary job losses. The courts, and the
    appellants and the amicus, refer to this form of benefit as a plant
    shutdown benefit even though the actual benefit provided may be
    triggered by events other than a plant shutdown. Because there is no
    relevant distinction between terming the benefit a plant shutdown
    benefit or a job loss benefit, we adopt the use of the term "plant
    shutdown" to facilitate discussion, though we recognize that Bellas
    himself was not terminated as a result of a plant shutdown, as that term
    may be commonly understood. Notwithstanding the concerns raised in
    the concurring opinion, we find that the resolution of the questions
    presented here turns not upon the nature of the contingent event that
    triggered payment of the benefit, but on whether the benefit continues
    beyond normal retirement age and therefore qualifies as an early
    retirement benefit or retirement-type subsidy. The nature of the event
    that caused the employee's termination does not control this inquiry
    
    5. While regulations have not been promulgated that define what is an
    accrued benefit protected by the anti-cutback provision, the Treasury
    
                                    14
    
    
    definitions of early retirement and retirement-type subsidy
    appear to be the subject of some agreement.
    
    ERISA provides that normal retirement age usually is 65.
    See 29 U.S.C. S 1002(24). The Westinghouse Plan also
    considers the age of 65 to be the normal retirement age.
    See Westinghouse Plan S 2.A, J.A. at 40."[A]llowance . . .
    for retirement at an earlier age legally creates an`early'
    retirement benefit. The fact that the plan does not expressly
    use the word `early' is not consequential." Hlinka v.
    Bethlehem Steel Corp., 863 F.2d 279, 281 (3d Cir. 1988).
    
    We have defined a retirement-type subsidy to be the
    excess in value of a benefit over the actuarial equivalent of
    the normal retirement benefit. See Ashenbaugh , 854 F.2d
    at1521 n.6; see also Dade, 68 F.3d at 1562 n.1. We explain
    this concept immediately below.
    
    Pension plans frequently provide for early retirement
    benefits. See Dan M. McGill & Donald S. Grubbs, Jr.,
    Fundamentals of Private Pensions (6th ed. 1989) at 131-35,
    App. 2 to Amicus Br. Such early retirements often
    commence at age 55 and possibly require the fulfilment of
    a minimum period of service. See id. The value of the early
    retirement benefit is calculated by first determining the
    amount that would be payable to the participant at normal
    retirement age, given the participant's service and
    compensation as of the date of early retirement. See id.
    This value then is reduced by a factor reflecting that benefit
    payments will begin earlier than was contemplated and,
    therefore, are likely to continue for a longer period of time.
    _________________________________________________________________
    
    Department has issued a regulation in which it sets forth certain
    benefits that are not accrued benefits for purposes of IRC S 411(d)(6).
    The list of benefits that are not accrued benefits includes: (1) ancillary
    life insurance protection, (2) accident or health insurance, (3) certain
    social security supplements, (4) the availability of loans, (5) the right to
    take after-tax employee contributions or elective deferrals, (6) the right to
    direct investments, (7) the right to a particular form of investment, (8)
    the allocation of dates for contributions, forfeitures, and earnings, the
    time for making contributions, and the valuation dates for account
    balances, (9) administrative procedures for distributing benefits, and (10)
    rights that derive from administrative and operational provisions. See 26
    C.F.R. S 1.411(d)-4 (in particular subsection (d) to Answer 1).
    
                                    15
    
    
    See id. This reduction of the normal retirement benefit in
    the case of an early retirement often is termed an actuarial
    reduction. See id. The provision of an early retirement
    benefit greater than the actuarial equivalent of the normal
    retirement benefit is referred to as a subsidized early
    retirement. See id.; see also Ashenbaugh , 854 F.2d at 1521
    n.6; Dade, 68 F.3d at 1562 n.1.
    
    b. The Legislative History of Current Section 204(g)
    
    The legislative history of the REA provides some insight
    into the definition of the term "retirement-type subsidy" and
    the reach of section 204(g). In the Senate Report addressing
    the REA, the purpose for the amendment was set forth as
    follows:
    
           Reasons for Change
    
           The committee believes that the protection of accrued
           benefits, which are essentially retirement benefits,
           against reduction by plan amendments is an essential
           safeguard for plan participants and their beneficiaries.
           The committee also believes that valuable rights of the
           participants should not be lost through the elimination
           of benefit options because options of equal actuarial
           value may not be of equal value to people whose
           particular circumstances are not taken into account in
           determining actuarial equivalence.
    
    S.Rep. No. 98-575, 98th Cong., 2d Sess., at 27 (1984),
    reprinted in 1984 U.S.C.C.A.N. 2547, 2573.
    
    The scope of section 204(g) was described in the following
    manner:
    
           Accordingly, the bill makes it clear that the prohibition
           against reduction of a benefit subsidy (the excess of the
           value of a benefit over the actuarial equivalent of the
           normal retirement benefit) applies to a participant only
           if the participant meets the conditions imposed by the
           plan on the availability of the subsidy. If the protection
           is afforded, an employee's accrued benefit is not to be
           less than the protected level or the accrued benefit
           determined under the plan without regard to the
           protection, whichever is greater. For example, if a plan
    
                                    16
    
    
           is amended to eliminate a subsidized early retirement
           benefit for employees who have completed 30 years of
           service, then the plan would not be required to provide
           the subsidy to an employee who never completes 30
           years of service and it would not be required to provide
           benefits to such an employee before the normal
           retirement age. On the other hand, if the employee
           completes 30 years of service, then the employee's
           accrued benefit is not to be less than the protected
           level or the accrued benefit determined without regard
           to the protection, whichever is greater.
    
    Id. at 28, reprinted in 1984 U.S.C.C.A.N. 2547, 2574.
    
    With respect to retirement-type subsidies, the Senate
    Report stated:
    
           The bill provides that the term `retirement-type
           subsidy' is to be defined by Treasury regulations. The
           committee intends that under these regulations, a
           subsidy that continues after retirement is generally to
           be considered a retirement-type subsidy. The
           committee expects, however, that a qualified disability
           benefit, a medical benefit, a social security supplement,
           a death benefit (including life insurance), or a plant
           shutdown benefit (that does not continue after
           retirement age) will not be considered a retirement-type
           subsidy. The committee expects that Treasury
           regulations will prevent the recharacterization of
           retirement-type benefits as benefits that are not
           protected by the provision.
    
    Id. at 30, reprinted in 1984 U.S.C.C.A.N. 2547, 2576
    (emphasis added). Accordingly, Congress clearly expressed
    its intent that the term "retirement-type subsidy" not be
    defined in such a way as to exclude a benefit that is
    essentially a retirement-type benefit from the protections of
    section 204(g).
    
    c. Cases Finding Job Separation Benefits Are
    Not Accrued Benefits
    
    We are aware of three published opinions which arguably
    support appellants' position that the PJS Benefits provided
    
                                    17
    
    
    under the Westinghouse Plan are not subject to the anti-
    cutback provisions of section 204(g): Ross v. Pension Plan
    for Hourly Employees of SKF Industries, Inc., 847 F.2d 329
    (6th Cir. 1988); Roper v. Pullman Standard, 859 F.2d 1472
    (11th Cir. 1988) (per curiam); and Blank v. Bethlehem Steel
    Corp., 758 F. Supp. 697 (M.D. Fl. 1990).6
    
    In Ross, the Court of Appeals for the Sixth Circuit
    considered a plan that provided employees meeting certain
    age and service requirements with the immediate payment
    of pension benefits in the event of a plant shutdown. See
    Ross, 847 F.2d at 330. The Ross court was concerned with
    the determination of whether the plant shutdown benefits
    were an early retirement benefit, retirement-type subsidy or
    optional form of benefit for purposes of section 204(g). See
    id. at 333.
    
    The court explained that:
    
           Early retirement benefits are generally benefits that
           become available upon retirement at or after a specified
           age which is below the normal retirement age, and/or
           upon completion of a specified period of service. An
           optional form of benefit is generally one that involves
           the power or right of an employee to choose the way in
           which payments due to him under a plan will be made
           or applied. The . . . plant shutdown benefit becomes
           due and payable only to a participant whose active
           service ceases by reason of a permanent shutdown of
           the plant, and who at the date of such cessation of
           service has at least 15 years of Benefit Service and
           either (a) is at least 55 years old or (b) has a combined
           age and years of Benefit Service equal to 80 or more.
    
    Id. The court concluded that a plant shutdown benefit is
    not one that falls within the category of either an early
    retirement benefit or an optional form of benefit. See id.
    
    Observing that the REA also provided protection for
    retirement-type subsidies, the court noted:
    _________________________________________________________________
    
    6. Independent research has found that these three opinions cited by the
    appellants are the only court opinions which arguably support their
    appeal.
    
                                    18
    
    
           The bill provides that the term `retirement type subsidy'
           is to be defined by Treasury regulations. The committee
           intends that under these regulations, a subsidy that
           continues after retirement is generally to be considered
           a retirement-type subsidy. The committee expects,
           however, that a qualified disability benefit, a medical
           benefit, a social security supplement, a death benefit
           (including life insurance), or a plant shutdown benefit
           (that does not continue after retirement age) will not be
           considered a retirement-type subsidy. The committee
           expects that Treasury regulations will prevent the
           recharacterization of retirement-type benefits as
           benefits that are not protected by the provision.
    
    Id. at 333-34 (citing S.Rep. No. 575 at 30, reprinted in 1984
    U.S.C.C.A.N. 2547, 2576). Without further discussion, the
    court determined the plant shutdown benefits did not fall
    within the category of a retirement-type subsidy as
    contemplated by the legislative history of the REA. See id.
    at 333.
    
    In Roper, the Court of Appeals for the Eleventh Circuit
    considered a pension plan that provided benefits to
    employees whose service was interrupted by a plant
    shutdown, lay-off or disability. See Roper, 859 F.2d at
    1473. The Roper court, however, addressed the plan within
    the context of ERISA section 206(a) and not section 204(g).
    See id.7 Thus, although the court found it was not
    necessary to its decision to address Ross, it noted that Ross
    supported its conclusion that a plant shutdown benefit is
    not an early retirement benefit. See id. at 1474.8
    _________________________________________________________________
    
    7. ERISA section 206(a) provides, in relevant part, "[i]n the case of a plan
    which provides for the payment of an early retirement benefit, such plan
    shall provide that a participant who satisfied the service requirements for
    such early retirement benefit, but separated from the service . . . before
    satisfying the age requirement for such early retirement benefit, is
    entitled upon satisfaction of such age requirement to receive a benefit
    not less than the benefit to which he would be entitled at the normal
    retirement age, actuarially reduced under regulations prescribed by the
    Secretary of the Treasury." 29 U.S.C. S 1056(a).
    
    8. As relevant to this appeal, other than citing Ross, the Roper court did
    not provide any analysis of section 204(g) and the definition of early
    
                                    19
    
    
    The Blank court also addressed a benefits plan that
    provided benefits to participants meeting certain age and
    service requirements separated from their employment as a
    result of layoffs or disability. See Blank, 758 F. Supp. at
    698. The court stated that " `[t]he accrued benefits secured
    by ERISA do not encompass unfunded, contingent early
    retirement benefits or severance benefits." Id. at 700
    (quoting Sutton v. Weirton Steel Div. of Nat'l Steel Corp., 724
    F.2d 406, 410 (4th Cir. 1983)) (relying upon case decided
    prior to passage of REA and not addressing the anti-
    cutback provisions of section 204(g)).9  In a footnote, the
    _________________________________________________________________
    
    retirement benefit or retirement-type subsidy. As noted by the Roper
    court, section 206(a) only applies when a plan participant is separated
    from service with a nonforfeitable right to an accrued benefit. See Roper,
    859 F.2d at 1473-74. The primary basis for the decision of the Roper
    court was not that the plant shutdown benefits were not an early
    retirement benefit, but rather that the plan did not provide for a
    nonforfeitable benefit because it encompassed factors other than age and
    service. See id. (adopting the reasoning of the district court). Accordingly,
    the Roper decision is not precedential on this appeal.
    
    9. Blank also cited to our opinion in Hlinka, 863 F.2d 279, as standing
    for the proposition that the plant shutdown benefits at issue in Blank
    were not an accrued benefit. While we did find that such a plan was not
    an accrued benefit, see Hlinka, at 284-85, we were not concerned with
    the application of amended section 204(g). See id. at 285 n.10. Given
    that the general ERISA definition of accrued benefits is linked to benefits
    commencing at normal retirement age, see 29 U.S.C. S 1002(24), our
    result was clearly appropriate. What we did not address in Hlinka,
    however, was the fact that for purposes of section 204(g) early retirement
    benefits and retirement-type subsidies are defined as being accrued, at
    least for purposes of that section. Thus, while an early retirement benefit
    may not be considered accrued for some purposes, it may be an accrued
    benefit for purposes of the anti-cutback rule of section 204(g). Blank did
    not discuss the import of this distinction.
    
    Given that Hlinka did not address the application of section 204(g), its
    holding is not controlling in this case. Further, the analysis of Hlinka,
    which is limited to the observation that the concept of accrual is defined
    in relationship to normal retirement age, is rendered inapplicable in this
    case by the passage of the REA. See 29 U.S.C. S 1054(g) (defining early
    retirement benefits and retirement-type subsidies as accrued benefits
    despite fact they commence prior to normal retirement age).
    
                                    20
    
    
    court stated that its conclusions were not affected by the
    application of section 204(g). See id. at 700 n.3.
    
    d. Cases Finding Job Separation Benefits
    Are Accrued Benefits
    
    The reported cases found to support the proposition that
    job separation benefits may be treated as accrued benefits
    for purposes of section 204(g) are Harms v. Cavenham
    Forest Industries, Inc., 984 F.2d 686, Wallace v. Cavenham
    Forest Industries, Inc., 707 F. Supp. 455 (D. Ore. 1989),
    and Richardson v. Pension Plan of Bethlehem Steel Corp., 67
    F.3d 1462 (9th Cir. 1995).10 We set forth their reasoning
    below.
    
    In Wallace, the district court addressed supplemental
    benefits that were provided "in lieu of Early Retirement
    Benefits and Vested Benefits to eligible Participants who
    were involuntarily separated under the Severance Program."
    Wallace, 707 F. Supp. at 459. These benefits were found to
    be payable for life, and thus continued beyond normal
    retirement age. See id. at 460. The court reasoned that:
    
           The fact that the [supplemental] benefits are offered `in
           lieu of Early Retirement Benefits and Vested Benefits'
           does not require the court to conclude that they are
           not retirement-type benefits. This language only
           indicates that an eligible participant cannot receive
           both the special benefits provided . . . and the Early
           Retirement Benefits and Vested Benefits under the
           Crown retirement plan.
    
           The fact that eligibility is contingent upon involuntary
           separation does not require the court to conclude that
    _________________________________________________________________
    
    10. The court of appeals vacated its decision in Richardson when it
    granted a petition for rehearing in that case. See Richardson v. Pension
    Plan of Bethleham Steel Corp., 112 F.3d 982 (9th Cir. 1997). On
    rehearing, the court decided that there had not been a plan amendment
    and therefore did not reach the issue of whether shutdown benefits were
    accrued benefits protected by section 204(g). See id. at 987. Accordingly,
    while we note that the court's original opinion does not have precedential
    value, its subsequent opinion did not undermine the logic of its earlier
    ruling.
    
                                    21
    
    
           [the supplemental benefits do] not provide retirement-
           type benefits. Eligibility for [supplemental] benefits is
           conditioned upon age and years of service as well as
           involuntary separation.
    
    Id. The Wallace court concluded that the supplemental
    benefits were retirement-type benefits subject to the
    protections of section 204(g) of ERISA. See id.
    
    Addressing the same plan at issue in Wallace, the Court
    of Appeals for the Fifth Circuit in Harms reached the same
    conclusion as had Wallace. The Harms court found it
    significant that the supplemental benefits were payable for
    life and were calculated similarly to general retirement
    subsidies -- by multiplying the participant'sfinal average
    pay figure by his or her years of service. See Harms, 984
    F.2d at 692. Harms further concluded that the
    supplemental benefits were provided not as a form of
    severance benefit, but rather as a retirement-type subsidy.
    See id. Accordingly, the court determined that the
    supplemental benefits were subject to the protections of
    ERISA section 204(g). See id.
    
    Richardson provides perhaps the most thorough analysis
    of whether shutdown benefits are protected as retirement-
    type subsidies by section 204(g). Richardsonfirst noted that
    Congress indicated that it expected the Treasury
    Department to promulgate regulations defining the term
    "retirement-type subsidy." See Richardson , 67 F.3d at 1468.
    As noted, however, the Treasury Department has yet to do
    so. See id. In that absence, Richardson  observed that courts
    have held that a retirement benefit is a retirement-type
    subsidy if the sum of the monthly payments for the
    participant's life exceeds what the participant would have
    received as normal retirement benefits. See id. (citing
    Ashenbaugh, 854 F.2d at 1516 n.6; Costantino v. TRW, Inc.,
    13 F.3d 969, 972 (6th Cir.1994)).
    
    The shutdown benefits addressed in Richardson  consisted
    of two parts: (1) $400 per month, paid until age 62 and (2)
    an additional amount, equal to the normal retirement
    benefit, paid until death. See id. The court found that these
    shutdown benefits constituted a retirement-type subsidy
    because the sum of the monthly payments for life exceeded
    
                                    22
    
    
    what the plan participants would have received as normal
    retirement benefits. See id.
    
    The Richardson court found that the legislative history for
    section 204(g) supported this conclusion. See id. Quoting
    from the Senate Report, the court noted that:
    
           a subsidy that continues after retirement is generally
           to be considered a retirement-type subsidy. The
           committee expects, however, that a qualified disability
           benefit, a medical benefit, a social security supplement,
           a death benefit (including life insurance), or a plant
           shutdown benefit (that does not continue after
           retirement age ) will not be considered a retirement-
           type subsidy.
    
    Id. (quoting S.Rep. No. 575 at 30, reprinted in 1984
    U.S.C.C.A.N. 2547, 2576). The court read the Senate Report
    to mean that shutdown benefits that do continue after
    retirement age are a retirement-type subsidy.11 See id. The
    pension plan, however, argued that the shutdown benefits
    there at issue did not continue after retirement age because
    at age 62 the participants stop receiving the $400 per
    month and then received only the same amount per month
    as they would have received if they had retired at age 62.
    See id. According to the pension plan, then, the subsidy
    ended at normal retirement age. See id.
    
    The court found that argument unavailing. See id. at
    1469. The shutdown benefits that a plan participant
    received upon a plant shutdown were found not to be
    miraculously transformed into normal retirement benefits
    _________________________________________________________________
    
    11. The Richardson court declined to follow Ross, 847 F.2d 329, where
    the Court of Appeals for the Sixth Circuit read the Senate Report as
    stating that shutdown benefits never can be included in the definition of
    "retirement-type subsidy." See Richardson , 67 F.3d at 1468 n.4. The
    court believed that if Congress had wanted to indicate that shutdown
    benefits were not retirement-type subsidies, it would have said so. See
    id. By contrast, Congress said only that a shutdown benefit "that does
    not continue after normal retirement" was not a retirement-type subsidy.
    See id. That statement, in conjunction with Congress's general assertion
    that a subsidy that continues after retirement is a retirement-type
    subsidy, strongly implies that shutdown benefits that do continue after
    retirement age are retirement-type subsidies. See id.
    
                                    23
    
    
    when the recipient reached age 62. See id. Rather, the plan
    participants received shutdown benefits from the time the
    plant closed until death. See id. While the amount of
    shutdown benefits the plan participant was entitled to
    receive was calculated by reference to normal retirement
    benefits, the court held that that circumstance did not
    transform the shutdown benefits into normal retirement
    benefits. See id.
    
    The Richardson court found additional support for its
    conclusion in Treasury Department General Counsel
    Memorandum 39869 addressing section 411(d)(6) of the
    Internal Revenue Code. See id. The GCM defined different
    types of shutdown benefits as follows:
    
           Some shutdown benefits are provided in a form similar
           to severance benefits. They are short-term in nature
           and are a supplement or replacement of the
           participant's income during the period of
           unemployment. These benefits are provided for a
           limited period of time after the termination of the
           individual's employment and the amount of the benefit
           is generally determined either as a flat amount or as a
           multiple or fraction of the individual's annual
           compensation. . . .
    
           Alternatively, shutdown benefits may continue beyond
           normal retirement age, i.e., retirement-type benefits.
           Generally, shutdown benefits provide an incentive to
           employees who are at or near normal retirement age to
           retire at the time of a plant shutdown. For example,
           the employer . . . may supplement the accrued benefit
           of the individual.
    
    Id. (quoting GCM 39869). Accordingly, the court concluded
    that the shutdown benefits there at issue continued after
    normal retirement age, and thus were retirement-type
    subsidies for purposes of section 204(g). See id.
    
    In Richardson the pension plan also argued that even if
    the shutdown benefits were retirement-type subsidies, plan
    participants were not protected by section 204(g) because
    their benefits did not accrue before the amendment. See id.
    That is, the shutdown did not occur until after the pension
    
                                    24
    
    
    plan eliminated the shutdown benefits. See id.  The court
    rejected this argument. See id.
    
    The Richardson court found that section 204(g) explicitly
    provides protection against amendment of retirement-type
    subsidies so long as the participant satisfies the
    preamendment conditions for the subsidy "either before or
    after the amendment." Id. Further, the court observed that
    an IRS revenue ruling concerning retirement-type subsidies
    under IRC S 411(d)(6) states that "[a] participant could,
    after the date of the proposed [amendment], satisfy the
    [preamendment] conditions necessary to receive this
    retirement-type subsidy." Id. (citing Rev.Rule 85-6, 1985-1
    C.B. 133). Because the shutdown benefits were found to be
    a retirement-type subsidy, section 204(g) precluded the
    pension plan from eliminating them. See id.
    
    e. IRS GCM 3986912
    _________________________________________________________________
    
    12. Appellants argue that we should defer to the IRS's interpretation of
    section 411(d)(6) as set forth in GCM 39869 and a favorable
    determination letter from the IRS stating that the plan here at issue did
    not violate section 411(d)(6). See Appellant Br. at 18-30. As we have
    noted, due weight is given to the IRS's interpretation of its statute, and
    such decisions are not disregarded unless they conflict with the statute
    they purport to interpret or its legislative history, or if they are otherwise
    unreasonable. See Gillis, 4 F.3d at 1145. Nevertheless, inasmuch as we
    find that the IRS's interpretation is in conflict with the statute and its
    legislative history, we do not defer to either GCM 39869 or the favorable
    determination letter. Our decision to accord little weight to GCM 39869
    is consistent with the Supreme Court's recent statement that an
    agency's interpretations, which are not the product of a formal
    adjudication or notice-and-comment rulemaking, are entitled only to
    respect, not deference, to the extent that those interpretations have the
    power to persuade. See Christensen v. Harris County, ___ U.S. ___, 120
    S.Ct. 1655, 1662-63 (2000). As noted, the IRS's departure from the
    express language of the statute and its legislative history renders GCM
    39869 unpersuasive on the points most relevant to this appeal.
    
    We also note that Bellas argues that under an IRS manual, General
    Counsel opinions "do not represent the positions of the [IRS]" and thus
    appellants "strive[ ] to puff [GCM 39869] into something it is not." See
    Appellee Br. at 13. Inasmuch as we depart significantly from GCM
    39869, we see no reason to consider the limitations the IRS places on
    such a memorandum.
    
                                    25
    
    
    IRS General Counsel Memorandum 39869, dated April 6,
    1992, addressed two issues relevant to the instant appeal:
    (1) whether shutdown benefits may be provided in a
    qualified pension plan, and (2) if shutdown benefits may be
    provided in a qualified plan, whether they are accrued
    benefits protected under IRC S 411(d)(6). See GCM 39869,
    IRS Pos. (C.C.H.) P 2351 at 7851 (Apr. 6, 1992). The IRS
    found that shutdown benefits may be provided in a
    qualified plan, but found that they were not subject to the
    anti-cutback provisions of section 411(d)(6) until the
    occurrence of the contingent event -- i.e., the plant
    shutdown.
    
    As to the first issue, the IRS stated that the
    determination of whether shutdown benefits may be
    provided in a qualified pension plan is not dependent solely
    on the event that triggers the payment of the benefit, but
    rather on the terms of the benefit, including the form of the
    benefit that is being provided. See id. at 7853. For example,
    shutdown benefits that are retirement-type benefits may be
    provided under a qualified pension plan. Benefits that
    become payable because of a plant shutdown and are in
    the form of annuity payments that continue after
    retirement age were found to be retirement-type subsidies
    that could be provided under a qualified pension plan. See
    id. at 7854.13
    
    In addition, the IRS indicated that shutdown benefits
    that are ancillary benefits (i.e., social security supplements)
    also could be provided. See id. at 7854. These benefits
    must satisfy any necessary requirements to be considered
    an ancillary benefit (e.g., a social security supplement must
    satisfy the requirements of IRC S 411(a)(9) and section
    1.411(a)-7(c)(4) of the regulations). Shutdown benefits that
    _________________________________________________________________
    
    13. The IRS indicated that the determination of whether a shutdown
    benefit may be provided in a qualified pension plan should focus on the
    form of benefit. See id. at 7853. Shutdown benefits may be provided by
    an employer for a number of reasons. For example, if the employer is
    concerned that the employees may need some time tofind a new
    position, the employer may want to provide each employee with a short-
    term replacement of income for several months or more. Alternatively, if
    the employees are near retirement age, the employer may prefer to
    supplement their retirement benefits.
    
                                    26
    
    
    are merely layoff or severance-type benefits, however, may
    not be provided in a qualified pension plan. See id. at 7853.
    
    As to the second issue, the IRS found that shutdown
    benefits that are retirement-type benefits, and not ancillary
    benefits, become accrued benefits and therefore are
    protected benefits under section 411(d)(6) only upon the
    occurrence of the event that triggers the right to payment of
    benefits (i.e., the contingent event). See id. at 7855. Section
    411(d)(6) provides that a qualified pension plan shall not be
    treated as satisfying section 411, and therefore is not
    qualified under IRC S 401(a), if the accrued benefit of a
    participant is decreased or eliminated. See IRC S 411(d)(6).14
    Pursuant to GCM 39869, if shutdown benefits are provided
    as retirement-type subsidies, they are accrued benefits and
    therefore are protected under section 411(d)(6). See id. at
    7855. Shutdown benefits, however, that are provided as
    ancillary benefits are not protected benefits under section
    411(d)(6).
    
    The IRS determined that shutdown benefits that are
    retirement-type benefits, and are not ancillary benefits,
    become an accrued benefit protected under section
    411(d)(6) upon the occurrence of the event that triggers the
    right to the benefits. See id. at 7855. The IRS believed that
    this conclusion was consistent with the treatment of
    shutdown benefits as unpredictable contingent event
    benefits for purposes of the funding requirements under
    IRC S 412. See id. at 7855. In determining a defined benefit
    plan's current liability for purposes of the funding
    requirements under section 412, unpredictable contingent
    event benefits are not taken into account until the event on
    which the benefit is contingent occurs. See IRC
    S 412(1)(7)(B).
    
    The IRS stated that the legislative history of section
    412(1) states that shutdown benefits are unpredictable
    contingent event benefits, citing H.R. Rep. No. 391, 100th
    Cong., 1st Sess. 987 (1987); S. Rep. No. 63, 100th Cong.,
    _________________________________________________________________
    
    14. Plan qualification is important because of the various tax benefits
    afforded qualified plans which will be lost if a plan is disqualified, and
    because of other adverse consequences following disqualification. See,
    e.g., IRC SS 402(b), 404(a) & 501(a).
    
                                    27
    
    
    1st Sess. 171-172 (1987) in this regard. See id.  at 7855.
    Because shutdown benefits are considered to be
    unpredictable contingent event benefits under section
    412(1), a qualified pension plan is not required to fund for
    shutdown benefits until the triggering event occurs.
    
    The IRS found that treating a shutdown benefit as an
    accrued benefit, and therefore as a section 411(d)(6)
    protected benefit at the time that the triggering event
    occurs was consistent with the treatment of this benefit as
    an unpredictable contingent event benefit for purposes of
    the additional funding requirements under sections 412(1)
    and 412(c)(7). See id. at 7855. The plan's definition of the
    shutdown benefit generally will determine the occurrence of
    the contingent event. For example, a plan may provide that
    shutdown benefits will be offered to all affected participants
    upon the resolution by the board of directors to close a
    facility. The IRS determined that in such a case the
    resolution by the board would be the event that triggers the
    shutdown benefit. See id. at 7855. Other plans may provide
    that the actual termination of operations at a particular
    facility is the triggering event. The IRS stated that a plan's
    description of a specific event is also the triggering event for
    determining when the shutdown benefit becomes a section
    411(d)(6) protected benefit.
    
    f. Our Conclusions
    
    After careful analysis of the arguments presented and the
    cited authority, we hold that unpredictable contingent event
    benefits that provide a benefit greater than the actuarially
    reduced normal retirement benefit are retirement-type
    subsidies, and therefore are accrued benefits under section
    204(g), if the benefit continues beyond normal retirement
    age. Such benefits are accrued upon their creation rather
    than upon the occurrence of the unpredictable contingent
    event. Our result is consistent with both the language of
    section 204(g) and its legislative history. For the reasons we
    set forth below, we do not adopt the contrary case law we
    have discussed above and contrary portions of the analysis
    contained in GCM 39869.
    
    As an initial matter, the concept that all plant shutdown
    benefits or any similar contingent benefit, cannot be a
    
                                    28
    
    
    protected retirement-type subsidy runs contrary to the
    legislative history of section 204(g). As noted in the Senate
    Report, "a subsidy that continues after retirement is
    generally to be considered a retirement-type subsidy ."
    S.Rep. No. 575 at 30, reprinted in 1984 U.S.C.C.A.N. 2547,
    2576 (emphasis added). The Senate Report considered only
    a plant shutdown benefit that does not continue after
    normal retirement age not to be a retirement type subsidy.
    See id. Thus, the Senate Report clearly suggests that plant
    shutdown benefits that continue after normal retirement
    age are retirement-type subsidies -- a conclusion
    consistent with Congress's intended general rule that
    subsidies continuing past normal retirement age are to be
    considered retirement-type subsidies.
    
    Cases like Roper -- and Ross, which relied upon Roper --
    use the Senate Report to reach the conclusion that plant
    shutdown benefits do not fall within the category of a
    retirement-type subsidy. See, e.g., Ross, 847 F.2d at 333-
    34. The Ross court, however, did not explain why, in the
    face of Congress's express intention, it chose tofind that
    plant shutdown benefits never may be considered
    retirement-type subsidies. There is no discussion in Ross of
    whether the plant shutdown benefits there continued
    beyond normal retirement age. Accordingly, we believe that
    the Ross court's analysis of the issue does not provide a
    basis upon which to decide this matter.
    
    In addition, the appellants' citation of Blank  adds little to
    this case as the court there relied on pre-REA case law for
    the proposition that contingent early retirement benefits do
    not fall within ERISA's definition of accrued benefits. See
    Blank, 758 F. Supp. at 700. The Blank court relegated its
    discussion of post-REA section 204(g) to a footnote that
    does not address the statutory substance of the REA
    amendments. See id. at 700 n.3. Accordingly, Blank does
    not offer support for its conclusions with respect to ERISA
    as it is now written.
    
    The overarching concept that emerges from the statute
    and the legislative history is that, in the proper
    circumstances, plant shutdown benefits that continue
    beyond normal retirement age should be treated as accrued
    benefits for purposes of section 204(g). As stated, the
    
                                    29
    
    
    Senate Report addressing the amendment of section 204(g)
    suggests that shutdown benefits continuing beyond normal
    retirement age are retirement-type benefits. See S.Rep. No.
    575 at 30, reprinted in 1984 U.S.C.C.A.N. 2547, 2576. Even
    GCM 39869, upon which the appellants heavily rely, notes
    that "benefits that become payable because of a plant
    shutdown and are in the form of annuity payments that
    continue after retirement age are retirement-type subsidies.
    . . ." Given that there does not appear to be any relevant
    distinction between plant shutdown benefits and a more
    broadly defined contingent event benefit, we hold that
    contingent event benefits that continue beyond normal
    retirement age may be either early retirement benefits or
    retirement-type subsidies (or both) within the meaning of
    ERISA section 204(g). See, e.g., Richardson, 67 F.3d at
    1468-69; Harms, 984 F.2d at 692; Wallace , 707 F. Supp. at
    460.15
    
    Appellants argue that even if section 204(g) protects
    contingent event benefits that continue beyond normal
    retirement age, such benefits may not be considered
    accrued until after the contingent event has occurred. See
    Appellant Br. at 16-30; see also Amicus Br. at 12-24. In
    support of this proposition, appellants rely primarily upon
    _________________________________________________________________
    
    15. At oral argument, appellants suggested that the contingent event
    benefits here at issue should not be construed as retirement benefits
    protected by Section 204(g). See Tr. at 50-52 (citing Rombagh v. Nestle
    USA, Inc., 211 F.3d 190, 192-94 (2d Cir. 2000)). We note that the
    Rombagh court addressed disability benefits provided in a pension plan.
    Such benefits were found to constitute a "welfare plan" and not a
    pension plan protected by section 204(g). See id. Accordingly, the issue
    presented to the Rombagh court is distinguishable from the issue
    presented on this appeal. The PJS Benefits provided in the Westinghouse
    Plan are not a temporary benefit provided in the event of unemployment,
    but rather provide covered employees with the option of retiring early
    rather than experiencing a period of unemployment. Such a benefit is
    not a welfare plan, but rather falls within the definition of a pension
    plan. See 29 U.S.C. S 1002(2)(A); see also GCM 39869 (finding that
    certain plant shut down benefits were properly considered to be part of
    a pension plan subject to anti-cutback provisions); cf. S.Rep. No. 575 at
    30, reprinted in 1984 U.S.C.C.A.N. 2547, 2576 (stating that when plant
    shut down benefit does not continue beyond normal retirement age it
    will not be considered a retirement-type subsidy).
    
                                    30
    
    
    GCM 39869. But we believe that to the extent that GCM
    39869 determined that plant shutdown benefits are not
    accrued benefits until after the occurrence of the contingent
    event, it is in conflict with the express terms of IRC
    S 411(d)(6) and the legislative history of its ERISA
    counterpart, section 204(g).
    
    On this point, the district court in this matter stated:
    
           I further find that the Defendants' argument that an
           unpredictable contingent event benefit such as the PJS
           benefit, is not protected until the contingent event
           occurs, is without merit in that it (and the authority it
           relied on) reads into the relevant statute a limitation on
           the protection of retirement-type benefits that simply is
           not supported by either the statutory language or the
           legislative history of S 204(g). More specifically, first, no
           where in plain language of S 204(g) is there any
           distinction made between `contingent' and `non-
           contingent' retirement-type subsidy benefits. Second,
           the legislative history of the amendment to S 204(g)
           expressly states that the amendment was designed to
           `protect[ ] the accrual of benefits with respect to
           participants who have met the requirements for a
           benefit as of the time a plan is amended and
           participants who subsequently meet the preamendment
           requirements.' See S.Rep. No. 575, 98th Cong., 2d Sess.
           28, reprinted in 1984 U.S.Code Cong. & Admin. News
           2547, 2574 (emphasis added). Additionally, such a
           conclusion seemingly would be in direct opposition to
           the Third Circuit court's view of S 204(g) in Dade,
           supra., wherein after noting that the early retirement
           benefit at issue was a retirement-type subsidy, the
           court explained, without any limitations, that after the
           amendment to S 204(g) in 1984, while `a plan sponsor
           could prospectively eliminate an early retirement
           benefit by amendment . . . the amendment could not
           adversely affect the early retirement benefit of a plan
           participant who satisfied the pre-amendment
           conditions for the benefit either before or after the
           amendment' and `[t]hus, if [the plan sponsor] had
           adopted such an amendment, it would have had to
           allow those employees who remained in its employ after
           the amendment to "grow into" the benefit.'
    
                                    31
    
    
    Bellas, 73 F. Supp.2d at 509 (citing Dade, 68 F.3d at
    1562).
    
    The district court was correct in noting that there is
    nothing in the language of section 204(g), or its legislative
    history, to suggest that a contingent event benefit accrues
    only upon the occurrence of the contingency. The plain
    language of the statute reveals that once a benefit is found
    to be a retirement-type subsidy, it is considered an accrued
    benefit. See ERISA section 204(g), 29 U.S.C. S 1054(g). The
    concept expressed in GCM 39869, that a benefit can be
    considered a retirement-type subsidy and yet not accrue
    until the occurrence of some later event, reads additional
    requirements into the language of section 204(g)--
    requirements for which there does not appear to be any
    support.
    
    As the Senate Report made clear, the committee expected
    that any regulations defining the term retirement-type
    subsidy would prevent the recharacterization of retirement-
    type benefits as benefits that are not protected by section
    204(g). See S.Rep. No. 575 at 30, reprinted in 1984
    U.S.C.C.A.N. 2547, 2576. By grafting on the requirement
    that the contingency must occur before certain retirement-
    type benefits may be protected, the IRS in GCM 39869 has
    undertaken just such a recharacterization. GCM 39869
    appears to concede that plant shutdown benefits that
    continue beyond normal retirement age may be retirement-
    type subsidies, yet at the same time removed such
    subsidies from any meaningful protection by finding that
    such benefits did not accrue until the contingent event
    occurs. The legislative history, however, calls for an
    inclusive definition of the term retirement-type subsidy.
    Accordingly, we will not impose an artificial condition, such
    as suggested by appellants, that would have the effect of
    rendering unprotected a benefit that is clearly retirement in
    nature.
    
    Appellants also argue that the concept of accrual
    connotes a benefit that accrues over time by reference to an
    employee's age, years of service, and years of participation.
    See Appellant Br. at 23-24. There can be no disputing this
    point. Appellants proceed to argue, however, that shutdown
    benefits do not steadily accrue in this sense, but rather are
    
                                    32
    
    
    triggered by an unpredictable event such as a qualifying
    termination for lack of work. This argument, however,
    misses its mark.
    
    Appellants appear to have imposed the concept of
    eligibility on the concept for accrual. While it is true that a
    plan participant may not be eligible to receive a shutdown
    benefit until the contingent event occurs, that circumstance
    by no means indicates that the value of that benefit has not
    been increasing over time in relationship to the
    participant's years of service under the plan, as in the case
    of a normal retirement benefit. The fact that a participant
    may not be eligible to receive payments until reaching the
    age of 65 does not mean that his or her retirement benefit
    does not accrue until the age of 65. Rather, as is commonly
    accepted, and as defined in ERISA section 3(23), normal
    retirement benefits accrue over time prior to the date of
    eligibility.
    
    The fact that contingent event benefits accrue over time
    is bolstered by review of the Westinghouse Plan. The value
    of the PJS Benefits provided under the Westinghouse Plan
    is linked to the value of the participant's normal retirement
    benefit. See Westinghouse Plan S 20.B.2(a), J.A. at 74.
    Accordingly, the value of these benefits is linked directly to
    a participant's years of service and participation and may
    be calculated at any point in time. While a participant may
    not be entitled to receive this value until the contingent
    event occurs, that does not mean that such benefits do not
    accrue, as that term is commonly understood.
    
    Appellants point to principles of actuarial practice to
    support their construction of section 204(g). See Appellant
    Br. at 25-28. Actuaries routinely treat traditional early
    retirement benefits (those dependent upon age and service
    only) as benefits that accrue at a fixed rate over time. See
    id. at 25 (citing Actuarial Standards Board, Actuarial
    Standards of Practice No. 4, at 25-26 (1993)). On the other
    hand, because shutdown benefits are contingent upon
    unpredictable events, they largely have defied conventional
    actuarial principles. See id. at 25-26. As a result, under
    ERISA, as amended by the Omnibus Reconciliation Act of
    1987, unpredictable contingent event benefits are not taken
    into account in determining a plan's current liability and
    
                                    33
    
    
    related funding obligations until after the contingent event
    occurs. See 29 U.S.C. S 1082(d)(7)(B); IRC S 412(1)(7)(B).
    Appellants argue that construing the anti-cutback rule not
    to apply to shutdown benefits until the occurrence of the
    unpredictable contingent event -- and recognizing that,
    until then, shutdown benefits are more in the nature of
    insurance than anticipated benefits -- advances one of the
    central objectives of ERISA: ensuring adequate funding for
    all vested and accrued benefits. See Appellant Br. at 26-27
    (citing 29 U.S.C. S 1001(a); Nachman Corp. , 446 U.S. at
    374-75, 100 S.Ct. at 1732-33).
    
    While the construction of section 204(g) proffered by
    appellants would lend some consistency between section
    204(g) and ERISA's funding provisions, it does not appear
    that the statute or its legislative history requires or compels
    such consistency. Appellants assert that until the
    contingent event occurs, shutdown benefits are more akin
    to insurance than an anticipated benefit. See  Br. at 26-27.
    Under this logic, appellants appear to suggest that the
    occurrence of the contingent event somehow transforms
    insurance into a retirement benefit. As we stated above,
    however, Congress discouraged this attempt at
    recharacterizing retirement-type benefits.
    
    In addition, we see no compelling need for consistency in
    this regard as the appellants urge. The question of whether
    a contingent event benefit is protected from reduction or
    elimination does not appear to be connected with the
    concept of funding in either ERISA or the IRC. Accounting
    and actuarial guidelines represent an attempt to account
    for real life events in the best manner possible. Hence,
    unpredictable contingent event benefits are not calculated
    into a plan's current liabilities because there is no means
    of knowing when and if such an event ever will occur. We
    do not understand why this circumstance need be related
    to the question of whether such benefits are protected from
    reduction or elimination.
    
    Appellants suggest that employers will face problems
    funding for contingent event benefits given that ERISA and
    the IRC require funding to be based upon reasonable
    actuarial principles. See Appellant Br. at 27 (citing 29
    U.S.C. S 1082(c)(3); IRC S 412(c)(3)). But if we concluded
    
                                    34
    
    
    that such benefits are not protected by section 204(g) until
    the contingent event occurs, our result would not alleviate
    this problem. The problem cited by appellants will exist
    regardless of whether the contingent event benefit is
    maintained as a result of the plan's own terms or simply is
    a product of the operation of section 204(g)'s anti-cutback
    provisions. Accordingly, the appellants' actuarial and
    funding arguments have no bearing on the determination of
    when contingent event benefits become protected under
    section 204(g).16
    
    When contingent event benefits are provided to continue
    beyond the normal retirement age, they are an early
    retirement benefit within the scope of section 204(g) and
    are accrued benefits within that section. Moreover, under
    section 204(g), once a benefit is found to meet the definition
    of a retirement-type subsidy it is to be considered an
    accrued benefit within that section. Accordingly, for
    purposes of the anti-cutback provisions of ERISA, such
    benefits are protected by section 204(g) with respect to
    employees within the pension plan after their creation and
    not upon the occurrence of the contingent event.
    
    In this matter, the version of the Westinghouse Plan
    before its amendment provided that "[a]n Employee . . .
    may retire" on the first day of the month following the
    month in which an employee's employment was terminated
    as a result of a Permanent Job Separation. See 
    Westinghouse Plan S 20.A, J.A. 74. In order to retire after a
    Permanent Job Separation, an employee must have
    satisfied one of the age and service combinations set forth
    below:
    
           -- Age 50 or over with 25 or more years of Eligi bility
           Service;
    
           -- Age 51 or over with 22 or more years of Eligi bility
           Service;
    _________________________________________________________________
    
    16. We also note that to the extent the value of the PJS Benefits here is
    determined in relationship to the normal retirement benefit, they always
    will be at least partially funded. Thus, the funding concerns appellants
    raise are not as serious as they would have us believe.
    
                                    35
    
    
           -- Age 52 or over with 19 or more years of Eligi bility
           Service;
    
           -- Age 53 or over with 16 or more years of Eligi bility
           Service;
    
           -- Age 54 or over with 13 or more years of Eligi bility
           Service;
    
           -- Age 55 or over with 10 or more years of Eligi bility
           Service.
    
    See id. S 20.B.1.
    
    The amount of monthly pension payable to an employee
    satisfying the above requirements was the sum of (1) the
    employee's normal retirement benefit, (2) $10.00 multiplied
    by the employee's Credited Service, and (3) an additional
    $100.00 if the employee had 25 years of Eligibility service,
    and his Special Retirement Date was on or before
    September 1, 1994. See id. S 20.B.2 (a-c). The normal
    retirement benefit was to be paid for the lifetime of the
    employee, but the additional dollar amounts were payable
    only until the employee reached the age of 62.17 Appellants
    and amicus argue that none of the benefits provided under
    the Westinghouse Plan continue beyond normal retirement
    age. See Appellant Br. at 30-34; Amicus Br. at 3-11.
    _________________________________________________________________
    
    17. Because the $10.00 multiplied by Credited Service and the additional
    $100.00 benefit do not continue beyond normal retirement age, they
    cannot properly be considered a retirement-type subsidy as
    contemplated by section 204(g). Accordingly, those benefits properly
    could be the subject of amendment or elimination without violating
    section 204(g). Neither the district court nor the parties to this appeal
    have expended much time addressing these benefits. Rather, the parties
    and the district court focused on the Westinghouse Plan's provision for
    the payment of normal retirement benefits without any actuarial
    reduction.
    
    In addition, Bellas did not satisfy the condition set forth in the
    Westinghouse Plan for receipt of the additional $100.00, namely that he
    retire on or before September 1, 1994. Because he failed to satisfy the
    conditions for the benefit, either before or after that amendment, Bellas
    has no protected right to this benefit under section 204(g). See 29 U.S.C.
    S 1054(g).
    
                                    36
    
    
    The district court, in addressing this issue stated:
    
           I find that because Subsection 20.B.2 (a) of the pre-
           1994 version of the Plan provided that the monthly
           amount of the PJS benefit included `any amounts
           computed pursuant to Section 4 of the Plan [the
           normal retirement pension provision of the Plan]'
           without any actuarial reduction, even though the
           participant was retiring at an age which would not
           normally entitle him or her to the normal retirement
           pension provided under the terms of the Plan without
           any actuarial reduction and further states in
           Subsection 20.B.3 that `[t]he amount calculated in
           accordance with Subsection 20.B.2(a) shall be payable
           for the lifetime of the Employee,' that, at the very least,
           the amount of the PJS benefit `computed pursuant to
           Section 4 of the Plan' (if not the entire PJS benefit) is:
           (1) a benefit pursuant to which `more is provided . . .
           than any reasonable actuarial equivalent of the plan's
           normal retirement benefit' and (2) `a subsidy that
           continues after retirement.' Therefore, the PJS benefit
           is `a retirement-type subsidy' as that term is used in
           SS 204(g) and 411(d)(6). See Dade, 68 F.3d at 1562,
           n.1; S.Rep. No. 575, 98th Cong., 2d Sess. 30, reprinted
           in 1984 U.S. Code Cong. & Admin. News 2547, 2576.
    
            In so holding, I obviously disagree with the
           Defendants' position that the PJS benefit is not a
           protected retirement-type subsidy because the Plan
           provides that `once the employee reached age 65[the
           normal retirement age under the Plan], this pre-
           retirement subsidy ceased, and he or she received only
           the Plan's "normal retirement" benefit. It is a key fact
           that, when the employee reached age 65, he or she was
           entitled to nothing more than their normal retirement
           benefit.' Defendants' Supporting Brief, p. 6. The
           difficulty I have with the Defendants' argument is that
           `Subsection 20.B.3 expressly provides that "[t]he
           amount calculated in accordance with Subsection
           20.B.2(a) shall be payable for the lifetime of the
           Employee,' " not until the participant turned 65.
    
    Bellas, 73 F. Supp.2d at 508-09. The district court is
    clearly correct that, by its express terms, the Westinghouse
    
                                    37
    
    
    Plan provides PJS Benefits that continue for the life of the
    participant. See Westinghouse Plan S 20.B.3.
    
    The appellants and amicus argue that any subsidy
    provided by the Westinghouse Plan ends when the
    participant reaches normal retirement age, at which point
    the participant merely would receive his normal retirement
    benefit. See Appellant Br. at 32. Appellants argue that the
    PJS Benefits do not provide any increased value to a
    participant once that participant reaches normal retirement
    age.
    
    The logic supporting the appellants' argument appears to
    be as follows. A plan participant is provided with his
    normal retirement benefit upon becoming entitled to his or
    her PJS Benefits. A participant would be entitled to this
    benefit, regardless of the permanent job separation, upon
    reaching normal retirement age. Accordingly, once a plan
    participant reaches normal retirement age, he or she is not
    receiving any increased value as a result of the permanent
    job separation. Therefore, any subsidy provided by the
    Westinghouse Plan must be viewed as ceasing upon a plan
    participant's reaching normal retirement age.
    
    The appellants' argument, however, overlooks one key
    feature -- PJS Benefits provide for the early payment of the
    normal retirement benefit without actuarial reduction.
    Normally, the early commencement of retirement benefits
    would be actuarially reduced. These reduced payments,
    begun earlier, would continue for life, the idea being that a
    greater number of smaller payments are actuarially
    equivalent to a smaller number of larger payments begun at
    normal retirement age. As mentioned, the Westinghouse
    Plan does not reduce the normal retirement benefit in the
    case of PJS Benefits, even though the payment of those
    benefits may begin as much as 10 years before normal
    retirement age. Thus, such payments have been subsidized
    to equal the non-actuarially-reduced normal retirement
    payment. It is this subsidy that continues for life.
    
    Amicus attempts to buttress appellants' argument that
    the subsidy does not continue for life. Amicus explains:
    
           Pension benefits ordinarily are actuarially reduced
           when an employee elects to commence distributions
    
                                    38
    
    
           prior to normal retirement age. The reduction is not a
           penalty; it simply adjusts the vested distributable
           amount to reflect that (1) an amount paid currently is
           worth more than the same amount paid later, (2) the
           periodic benefit is payable over a greater number of
           years, and (3) the risk that an employee will die before
           the payments commence is reduced. The actuarial
           reduction is calculated by determining the benefit
           amount that would be payable at normal retirement
           age (on the basis of the participant's service and
           compensation to the date of the early commencement),
           and multiplying the benefit payable at normal
           retirement age by a discount factor. . . .
    
           For example, a 55-year old employee who terminates
           employment with a vested monthly retirement benefit
           of $1,000 for life commencing at age 65 might be
           entitled to $400 per month for life commencing at age
           55 after the actuarial reduction is made. A full
           actuarial subsidy, such as that provided under the PJS
           benefit, eliminates this actuarial reduction and so
           provides an employee with a level stream of benefits
           before and after normal retirement age, consisting of a
           monthly $1,000 subsidy until normal retirement age
           and the monthly $1,000 normal retirement benefit
           thereafter.
    
    Amicus Br. at 5-6.
    
    Amicus, however, has overstated its case and the data
    upon which it relies. Under its theory, a plan participant
    receiving a subsidized early retirement receives payments
    that consist wholly of the subsidy before retirement age and
    no subsidy after retirement age. While the data presented
    by amicus certainly establishes that the total value of the
    subsidy is less for the person who qualifies for the benefit
    at an age that is closer to normal retirement age, the data
    does not support the conclusion that payments made prior
    to normal retirement age consist wholly of a subsidy.
    
    After reviewing the arguments raised by appellants and
    amicus, and the language of the Westinghouse Plan, we
    conclude that the district court correctly concluded that the
    PJS Benefits in the Westinghouse Plan continue beyond
    
                                    39
    
    
    normal retirement age. As noted, the plan itself states that
    such benefits commence upon the special retirement date
    and continue for life. Because the Westinghouse Plan
    provides for a benefit that continues beyond normal
    retirement age, and is not actuarily reduced by reason of its
    payment before the normal retirement age, it is a
    retirement-type subsidy protected by section 204(g) of
    ERISA. Consequently, to the extent CBS amended the
    Westinghouse Plan in 1994 to eliminate certain plan
    participants from eligibility for PJS Benefits, it violated
    section 204(g).
    
    We note, however, that neither the district court nor any
    other court or body addressing the issue appears to have
    drawn a distinction between contingent event benefits that
    provide for an early retirement and those benefits that
    provide a retirement-type subsidy. The general practice is to
    consider the entire benefit provided to be a subsidy. That
    practice, however, appears to us to be contrary to the
    definition of retirement-type subsidy that we have adopted.
    We have considered only the excess in value of a benefit
    over the actuarial equivalent of the normal retirement
    benefit to be a subsidy. See Dade, 68 F.3d at 1562 n.1;
    Ashenbaugh, 854 F.2d at 1521 n.6. Accordingly, to the
    extent the Westinghouse Plan provided PJS Benefits that
    were not actuarially reduced, the value of the benefit over
    and above the actuarially reduced value is a retirement-
    type subsidy protected by section 204(g). The balance, i.e.
    that portion paid that is equal to the actuarially reduced
    normal retirement benefit, constitutes an early retirement
    benefit protected by section 204(g) but is not a retirement-
    type subsidy.18
    _________________________________________________________________
    
    18. This conclusion is consistent with the terms of the Westinghouse
    Plan, which defines the PJS Benefits in terms of allowing a plan
    participant to retire. It is also consistent with GCM 39869, which notes
    that rather than providing short term benefits to plan participants close
    to retirement age, a plan may offer an incentive for such participants to
    retire at the time of the plant shutdown. See  GCM 39869. This is exactly
    what the Westinghouse Plan provides. Rather than offer some other form
    of severance to employees that are sufficiently close to retirement age,
    the Westinghouse Plan allows such employees to retire early.
    Accordingly, the PJS Benefits provided by the Westinghouse Plan should
    
                                    40
    
    
    Amicus expresses concern that shutdown benefits that
    have been written into plans on the expectation that they
    could be modified or removed prior to an actual plant
    shutdown under the result we reach, will become
    permanent features of those plans. This result, however,
    appears to express the intent of ERISA, at least as concerns
    shutdown benefits that are provided in the form of early
    retirement benefits or retirement-type subsidies. As noted,
    one of the purposes of ERISA was to protect an employee's
    interest in his or her retirement benefits. The"expectation"
    of companies cannot override the language of the statute.19
    
    Additionally, amicus asserts that application of the anti-
    cutback rule to shutdown benefits prior to the occurrence
    of the triggering event would expose many plans to the
    threat of immediate disqualification for federal income tax
    purposes because adoption of an amendment that violates
    IRC S 411(d)(6) causes a plan to be disqualified. Amicus
    further asserts that such disqualification would occur
    regardless of whether an employer reasonably relied upon
    GCM 39869. There can be no doubt that these arguments
    are substantial and we recognize that there may be
    significant adverse tax consequences as a result of this
    opinion if relief from sources other than this court is not
    granted. We hope that the appropriate authorities take note
    of this problem and take steps to alleviate it. Yet section
    _________________________________________________________________
    
    be viewed as a subsidized early retirement benefit, protected as an early
    retirement to the extent of the actuarially reduced value of the normal
    retirement and protected as a subsidy, to the extent the Westinghouse
    Plan provides a benefit of greater value than the actuarially reduced
    value of the normal retirement benefit.
    
    19. Other policy concerns militate against accepting the amicus's
    arguments. The ability to eliminate or remove a shutdown retirement
    benefit prior to an actual shutdown seems contrary to the goals of
    ERISA. If a company could provide for shutdown retirement benefits and
    then remove them prior to an actual shutdown, it could persuade its
    employees to stay on board to help overcome difficult financial times,
    secure in the knowledge that if the company fails they can retire, but
    nevertheless could remove such benefits when it became evident the
    company could not be saved. In the absence of ERISA, such actions may
    not have been legally problematic, but the intent of section 204(g) surely
    would take this option away from an employer.
    
                                    41
    
    
    204(g), particularly when considered with the legislative
    history, compels us to reach our result.
    
    Nevertheless, while we do not suggest that employers
    have not relied reasonably on GCM 39869, and thus are
    not entitled to tax relief, we point out that knowledgeable
    persons in this esoteric field might have been aware since
    1989 that section 204(g) was subject to an interpretation
    contrary to that which the IRS later reached. See Wallace,
    707 F. Supp. 455. The Wallace court issued its opinion
    more than three years before the IRS published GCM
    39869. Further, the Court of Appeals for the Fifth Circuit in
    1993 in Harms, 984 F.2d 686, and the Court of Appeals for
    the Ninth Circuit in 1995 in Richardson, 67 F.3d 1462,
    adopted the Wallace position.
    
    Finally, amicus asserts that if we affirm the decision of
    the district court we will discourage employers from adding
    future shutdown benefits. We think that amicus overstates
    the impact of our opinion. The only shutdown benefits
    subject to the anti-cutback provisions under this opinion
    are those provided in the form of early retirements and
    retirement-type subsidies that continue beyond normal
    retirement age. If, notwithstanding this opinion, an
    employer desires to have the flexibility of providing
    shutdown benefits that it easily can modify or amend in a
    qualified plan, it still may provide ancillary shutdown
    benefits that do not continue beyond normal retirement
    age. See, e.g., IRC S 1.401(a)(4)-4(3)(2) (defining ancillary
    benefit to include shutdown benefits not protected under
    section 411(d)(6)). Accordingly, the amicus's concern does
    not compel a conclusion different from the one we adopt.
    
    III. CONCLUSION
    
    For the reasons set forth above, we will affirm the order
    of the district court entered June 29, 1999. Wefind that
    the PJS Benefits offered under the Westinghouse Plan are
    both an early retirement benefit and a retirement-type
    subsidy protected under section 204(g), to the extent that
    they include the lifetime provision of a normal retirement
    benefit commencing after a covered job loss. To the extent
    the Westinghouse Plan provided PJS Benefits that did not
    
                                    42
    
    
    continue beyond normal retirement age, those benefits are
    not protected by section 204(g). We will remand the matter
    to the district court for further proceedings consistent with
    this opinion.
    
                                    43
    
    
    SHADUR, Senior District Judge, concurring:
    
    Westinghouse Electric Corporation ("Westinghouse") fired
    its long-term employee Harry Bellas ("Bellas") on December
    31, 1997. That was of course within Westinghouse's rights:
    Under the common law principles of at-will employment, an
    employer is free to terminate a 32-year employee--just as it
    is free to terminate a probationary employee with just a few
    months under his or her belt--for good reason, bad reason
    or no reason at all. But here it is more than worth noting
    that there was no Westinghouse "plant shutdown" or any
    other kind of "shutdown" involved at all--and that is the
    bizarre mischaracterization that appellants have attached
    to Bellas' layoff (his firing), and that has been referred to in
    the majority opinion at n.4 and then employed throughout
    the opinion. What or who was "shut down"? Bellas? Surely
    not.
    
    Most importantly for present purposes, that acceptance
    of appellants' mischaracterization in the opinion has given
    them (and the amicus in the case) substantially more than
    their due, and has thus made the reaching of our panel's
    conclusions--though clearly correct--needlessly more
    difficult in terms of analysis. And that has in turn
    occasioned this separate concurrence.
    
    For appellants to attach the "shutdown" label to Bellas'
    termination of employment, and then to attempt to use that
    label as a springboard for a flawed analysis, does more
    than violate the home truth contained in one of the
    aphorisms ascribed to Abraham Lincoln:
    
           If you call a tail a leg, how many legs has a dog? Five?
           No, calling a tail a leg don't make it a leg.
    
    After all, from an employee's perspective the occasion for
    his or her being fired is irrelevant--in Gertrude Stein terms,
    "a firing is a firing is a firing." 20 But from an employer's
    _________________________________________________________________
    
    20. There is no question that Bellas was fired, rather than some more
    euphemistic term such as "layoff " being applicable to his termination.
    Bellas' original notice from the employer's Benefits Access Center used
    the language of his being "involuntarily separated from Westinghouse,"
    which was clear enough on its own, and Westinghouse's ultimate
    
                                    44
    
    
    point of view, a plant shutdown is a major economic event
    (as an individual's layoff, or even a number of individual
    layoffs, need not be). And of course every employer is well
    aware of its employee turnover rates, so that although the
    prospect or timing of any individual employee's termination
    cannot be predicted, the inevitability of a reasonably
    anticipatable number of employee terminations can be. And
    that situation contrasts sharply with an entire plant
    shutdown, which is almost always an unusual and
    unpredictable event (at least far in advance) in a company's
    economic life.
    
    It is thus no accident, I believe, that when Congress
    acted to overturn adverse judicial precedent by enacting the
    Retirement Equity Act (ERISA S204(g)'s anti-cutback
    provisions), the Senate Report (which has been quoted in
    the majority opinion's section captioned Legislative History
    of Current Section 204(g), and has also been expressly
    referred to in both Ross v. Pension Plan for Hourly
    Employees of SKE Indus., Inc., 847 F.2d 329, 333 (6th Cir.
    1988) and Richardson v. Pension Plan of Bethlehem Steel
    Corp., 67 F.3d 1462, 1468 (9th Cir. 1995)) proceeded to list
    and explain the types of benefits that an employer could
    continue to control and could hence modify despite the
    Section 204(g) amendment. Importantly, in the course of
    doing so the Senate Report referred only to"a plant
    shutdown benefit (that does not continue after retirement
    age)." It did not speak at all of an employer's right to alter
    such retirement benefits payable on an individual's
    retirement or other termination.
    
    And it is relatedly worth noting that not one of the three
    decisions on which appellants seek to rely, and with which
    _________________________________________________________________
    
    communication (which cut the cord conclusively after a short extension
    that it had granted from the original notice date) left no conceivable room
    for doubt (emphasis added):
    
           Previously you were notified of permanent separation effective
           August 27, 1997. You were subsequently informed that due to
           business conditions, your employment was extended.
    
           This letter is formal notification that your effective date of separation
           will be December 31, 1997
    
                                    45
    
    
    our panel has deliberately parted company in substantive
    terms, involved (as this case does) an individual layoff
    unassociated with a plant shutdown. Instead the two Court
    of Appeals decisions, Ross and Roper v. Pullman Standard,
    859 F.2d 1472 (11th Cir. 1988)(per curiam), did involve
    plant shutdowns and the major employee displacements
    that such events create, while the District Court decision in
    Blank v. Bethlehem Steel Corp., 758 F.Supp. 697 (M.D. Fla.
    1990) involved the sale of a facility to a purchaser that did
    not take over the workforce in toto (thus also being much
    the equivalent, from the selling employer's perspective, of
    an unanticipatable plant shutdown).
    
    In sum, the analysis and result that plainly favor Bellas
    in this case flow easily not only from the facts that the
    benefits at issue here were framed to continue after
    retirement age but also from the fact that such benefits are
    not even hinted at in the Retirement Equity Act or its
    legislative history as subject to modification by an employer
    that must deal with the post-statutory termination of an
    individual employee. Indeed, that conclusion should really
    follow a fortiori from the majority opinion's decision that
    the continuation of such a benefit beyond retirement would
    also insulate a plant shutdown situation from the
    employer's attempted revision of that retirement benefit.
    
    It is also significant, I suggest, that the General Counsel's
    Memorandum that was authored by an anonymous Internal
    Revenue Service lawyer--the GCM on which appellants seek
    to lay such heavy stress and that the majority opinion
    properly finds unpersuasive as a substantive matter--
    becomes an even weaker reed when looked at from the
    perspective set out here. That GCM speaks of "such
    shutdown benefits" in the everyday English meaning of an
    employer's closing of a facility or the like. Westinghouse's
    effort to bootstrap that notion into applying to every
    termination of every employee represents an unjustified
    quantum leap.
    
    It is of course true that Bellas has shaped his Complaint
    as a putative class action to encompass all participants in
    the Westinghouse Plan who were laid off after January 1,
    1997 under circumstances that meet the pre-Plan
    Amendment requirements for the type of pension claimed
    
                                    46
    
    
    by Bellas, or even to encompass some Plan participants
    who are still employed. But because this appeal comes
    before us on an interlocutory basis before the issue of class
    certification has been addressed by the district court, it
    cannot now be known (for example) whether Bellas, with
    his own situation involving an entirely individualfiring,
    would or would not qualify under the Fed. R. Civ. P. 23
    standards of typicality or adequacy of representation for a
    class including such Westinghouse employees who might
    become affected in the future by a now-purely-hypothetical
    plant shutdown. Hence our panel's reaching out to address
    that hypothetical situation poses the problem always
    presented by judicial dictum: the prospect that when an
    actual controversy of that nature presents itself, it may
    present issues that no one has now anticipated fully, and
    that could therefore call for a different analysis (or even
    perhaps a different result).
    
    For those reasons I would limit the present analysis and
    decision to the one before us in real-world terms: Bellas'
    individual termination (although I do want to make it clear
    that my substantive analysis of the hypothetical plant
    shutdown situation, if we were properly called upon to
    reach it, would be no different from what has been said in
    the majority opinion). Accordingly I concur in the majority
    opinion to the extent of its materially less difficult
    resolution of the appeal as to Bellas' individual claim.
    
    A True Copy:
    Teste:
    
           Clerk of the United States Court of Appeals
           for the Third Circuit
    
                                    47

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