On March 4, 2022, the District Court for the District of Massachusetts dismissed, pursuant to Fed. R. Civ. P. 56, ERISA claims brought by a former employee who retired early at the age of 62 and receives retirement benefits in the form of a joint and survivor annuity. Belknap v. Partners Healthcare Sys., No.
Actuarial equivalence
U.S. Bancorp Defeats Class Certification in Challenge to Early Retirement Benefits
By Stacey C.S. Cerrone & Juan C. Obregon on
Posted in Defined Benefit, ERISA
The District Court of Minnesota declined to certify a class of pensioners seeking to challenge their plan’s early retirement calculations. ERISA requires early retirement benefits to be actuarially equivalent to what participants would receive at their normal retirement age. For participants collecting retirement benefits before age 65 (known as the “Early Commencement Factor” or “ECF”),…