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conduct. It held that the written terms of pension contributions to multiemployer plans cannot  be changed orally — and that any revised terms must be placed into a signed wri

Lesson learned: Put it in writing

Lesson learned:  Put it in writing

The facts in the case are detailed, but in essence, the court held that although it has been long understood that the parties to a collective bargaining agreement may change most terms by conduct (i.e., without a signed amendment), by contrast, the precise terms of pension contributions contained in an ERISA (Employee Retirement Income Security Act) multiemployer pension plan document can only be changed in writing.

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