On September 9, 2013, the Department of Labor (DOL) published in the Federal Register a proposed exemption that would allow AT&T Inc. to contribute approximately $9.1 billion of preferred LLC equity interests in its Mobility wireless subsidiary to AT&T’s pension plan.  The exemption, if and when granted, would be retroactive, allowing AT&T to make the contribution immediately.  It can be viewed as a type of “de-risking” strategy.

In-kind contributions of “employer securities” are fairly common, and are permitted to be made under a statutory exemption if certain conditions are satisfied.  DOL has also granted numerous individual exemptions in the past.  However, this one is significant for a number of reasons.  Please see the attached memo for further details.


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