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But they only offloaded a portion of the liability, less than half.? So what does that mean to ERISA coverage???

IBM says that this affects 100,000 retirees. who retired before 2016.? As of the end of 2021:

The total number of participants and beneficiaries covered by the Plan on the Valuation Date
was 257,221. Of this number, 21,398 were current employees, 174,887 were retired and
receiving benefits, and 60,936 were retired or no longer working for the employer and have a
right to future benefits.

So those 100,000 might be the fraction of the 174,887 that retired before 2016.?? I can't quite figure out how that could require only $16 billion in funding.? My simple calculation says that 100,000 retirees would make up $21 billion of the plan's $46 billion in liabilities

All I can think of is that many of those 100,000 are older retirees, some of whom retired in the 80s and 90s when salaries and the corresponding pensions were smaller. ? The remaining 157,000 are younger employees and retirees who benefited from larger salaries, and therefore their share of the pension fund is larger.

In terms of ERISA protections, those retirees whose pensions are converted to an annuity will no longer be protected by ERISA.