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NOTICE: This opinion is subject to formal revision before publication in the
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SUPREME COURT OF THE UNITED STATES
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No. 93-768
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MILWAUKEE BREWERY WORKERS' PENSION
PLAN, PETITIONER v. JOS. SCHLITZ BREWING
COMPANY and STROH BREWERY COMPANY
on writ of certiorari to the united states court
of appeals for the seventh circuit
[February 21, 1995]

  Justice Breyer delivered the opinion of the Court.
  The Multiemployer Pension Plan Amendments Act of
1980 (MPPAA), 94 Stat. 1208, 29 U. S. C. 1381-1461,
provides that an employer who withdraws from an
underfunded multiemployer pension plan must pay a
charge sufficient to cover that employer's fair share of
the plan's unfunded liabilities.  The statute permits the
employer to pay that charge in lump sum or to -amor-
tize- it, making payments over time.  This case focuses
upon a withdrawing employer who amortizes the charge,
and it asks when, for purposes of calculating the
amortization schedule, interest begins to accrue on the
amortized charge.  The Court of Appeals for the Seventh
Circuit held that, for purposes of computation, interest
begins to accrue on the first day of the year after
withdrawal.  We agree and affirm its judgment.

                            I
  We shall briefly describe the general purpose of
MPPAA, the basic way MPPAA works, and the relevant
interest-related facts of the case before us.
                            A
MPPAA's General Purpose
  MPPAA helps solve a problem that became apparent
after Congress enacted the Employee Retirement Income
Security Act of 1974 (ERISA), 88 Stat. 829, 29 U. S. C.
1001 et seq.  ERISA helped assure private-sector
workers that they would receive the pensions that their
employers had promised them.  See, e.g., Concrete Pipe
& Products of Cal., Inc. v. Construction Laborers Pension
Trust for So. Cal., 508 U. S. ____, ____ (1993) (slip op.,
at 2-6).  To do so, among other things, ERISA required
employers to make contributions that would produce
pension-plan assets sufficient to meet future vested
pension liabilities; it mandated termination insurance to
protect workers against a plan's bankruptcy; and, if a
plan became insolvent, it held any employer who had
withdrawn from the plan during the previous five years
liable for a fair share of the plan's underfunding.  See
26 U. S. C. 412 (minimum funding standards); 29
U. S. C. 1082 (same); 29 U. S. C. 1301 et seq. (termi-
nation insurance); 29 U. S. C. 1364 (withdrawal
liability).
  Unfortunately, this scheme encouraged an employer to
withdraw from a financially shaky plan and risk paying
its share if the plan later became insolvent, rather than
to remain and (if others withdrew) risk having to bear
alone the entire cost of keeping the shaky plan afloat.
Consequently, a plan's financial troubles could trigger a
stampede for the exit-doors, thereby ensuring the plan's
demise.  See Connolly v. Pension Benefit Guaranty
Corporation, 475 U. S. 211, 216 (1986); Pension Benefit
Guaranty Corporation v. R. A. Gray & Co., 467 U. S.
717, 722-723, n. 2 (1984); see also 29 U. S. C.
1001a(a)(4); H. R. Rep. No. 96-869, pt. 1, pp. 54-55
(1980); D. McGill & D. Grubbs, Fundamentals of Private
Pensions 618-619 (6th ed. 1989).  MPPAA helped
eliminate this problem by changing the strategic consid-
erations.  It transformed what was only a risk (that a
withdrawing employer would have to pay a fair share of
underfunding) into a certainty.  That is to say, it
imposed a withdrawal charge on all employers withdraw-
ing from an underfunded plan (whether or not the plan
later became insolvent).  And, it set forth a detailed set
of rules for determining, and collecting, that charge.

                            B
                 MPPAA's Basic Approach
  The way in which MPPAA calculates interest is
related to the way in which that statute answers three
more general, and more important, questions: First, how
much is the withdrawal charge?  MPPAA's lengthy
charge-determination section, 1391, sets forth rules for
calculating a withdrawing employer's fair share of a
plan's underfunding.  See 29 U. S. C. 1391.  It explains
(a) how to determine a plan's total underfunding;
and (b) how to determine an employer's fair share
(based primarily upon the comparative number of that
employer's covered workers in each earlier year and the
related level of that employer's contributions).
  One might expect 1391 to calculate a withdrawal
charge that equals the withdrawing employer's fair share
of a plan's underfunding as of the day the employer
withdraws.  But, instead, 1391 instructs a plan to
make the withdrawal charge calculation, not as of the
day of withdrawal, but as of the last day of the plan
year preceding the year during which the employer
withdrew-a day that could be up to a year earlier.  See
29 U. S. C. 1391(b)(2)(A)(ii), (b)(2)(E)(i), (c)(2)(C)(i),
(c)(3)(A), and (c)(4)(A).  Thus (assuming for illustrative
purposes that a plan's bookkeeping year and the calen-
dar year coincide), the withdrawal charge for an em-
ployer withdrawing from an underfunded plan in 1981
equals that employer's fair share of the underfunding as
calculated on December 31, 1980, whether the employer
withdrew the next day (January 1, 1981) or a year later
(December 31, 1981).  The reason for this calculation
date seems one of administrative convenience.  Its use
permits a plan to base the highly complex calculations
upon figures that it must prepare in any event for a
report required under ERISA, see 29 U. S. C.
1082(c)(9), thereby avoiding the need to generate new
figures tied to the date of actual withdrawal.
  Second, how may the employer pay the withdrawal
charge?  The statute sets forth two methods:
(a) payment in a lump sum; and (b) payment in install-
ments.  The statute's lump-sum method is relatively
simple.  A withdrawing employer may pay the entire
liability when the first payment falls due; pay install-
ments for a while and then discharge its remaining
liability; or make a partial balloon payment and after-
wards pay installments.  See 29 U. S. C. 1399(c)(4).
The statute's installment method is more complex.  The
statutory method is unusual in that the statute does not
ask the question that a mortgage borrower would
normally ask, namely, what is the amount of each of my
monthly payments?  What size monthly payment will
amortize, say, a 7% 30-year loan of $100,000?  Rather,
the statute fixes the amount of each payment and asks
how many such payments there will have to be.  To put
the matter more precisely, (1) the statute fixes the
amount of each annual payment at a level that (roughly
speaking) equals the withdrawing employer's typical
contribution in earlier years; (2) it sets an interest rate,
equal to the rate the plan normally uses for its calcula-
tions; and (3) it then asks how many such annual
payments it will take to -amortize- the withdrawal
charge at that interest rate.  29 U. S. C.
1399(c)(1)(A)(i), (c)(1)(A)(ii), (c)(1)(C).
  It is as if Brown, who owes Smith $1000, were to ask,
not, -How much must I pay each month to pay off the
debt (with 7% interest) over two years?--but, rather,
-Assuming 7% interest, how many $100 monthly pay-
ments must I make to pay off that debt?-  To bring the
facts closer to those of this case, assume that an
employer withdraws from an underfunded plan in mid-
1981; that the withdrawal charge (calculated as of the
end of 1980) is $23.3 million; that the employer nor-
mally contributes about $4 million per year to the plan;
and that the plan uses a 7% interest rate.  In that case,
the statute asks: -How many annual payments of about
$4 million does it take to pay off a debt of $23.3 mil-
lion if the interest rate is 7%?-  The fact that the
statute poses the installment-plan question in this way,
along with an additional feature of the statute, namely
that the statute forgives all debt outstanding after 20
years, 29 U. S. C. 1399(c)(1)(B), suggests that maintain-
ing level funding for the plan is an important goal of
the statute.  The practical effect of this concern with
maintaining level payments is that any amortization
interest 1399(c)(1)(A)(i) may cause to accrue is added to
the end of the payment schedule (unless forgiven by
1399(c)(1)(B)).
  Third, when must the employer pay?  The statute
could not make the employer pay the calculated sum (or
begin to pay that sum) on the date in reference to which
one calculates the withdrawal charge, for that date
occurs before the employer withdraws.  (It is the last
day of the preceding plan year, i.e., December 31, 1980,
for an employer who withdraws in 1981.)  The statute,
of course, might make the withdrawing employer pay (or
begin payment) on the date the employer actually
withdraws.  But, it does not do so.  Rather, the statute
says that a plan must draw up a schedule for payment
and -demand payment- as -soon as practicable- after
withdrawal.  29 U. S. C. 1399(b)(1).  It adds that
-[w]ithdrawal liability shall be payable . . . no more
than 60 days after the date of the demand.-  29 U. S. C.
1399(c)(2).
  Thus, a plan that calculates quickly might demand
payment the day after withdrawal and make the charge
-payable- within 60 days thereafter.  A plan that
calculates slowly might not be able to demand payment
for many months after withdrawal.  For example, in the
case of the employer who withdraws on August 14, 1981,
incurring a withdrawal charge of $23.3 million (calcu-
lated as of December 31, 1980), the lump sum of $23.3
million, or the first of the installment payments of
roughly $4 million, will become -payable- to the plan -no
later than 60 days- after the plan sent the withdrawing
employer a demand letter.  The day of the first payment
may thus come as soon as within 60 days after
August 15, 1981, or it may not come for many months
thereafter, depending upon the plan's calculating speed.

                            C
                        This Case
  The facts of this case approximate those of our
example.  Three brewers, Schlitz, Pabst, and Miller,
contributed for many years to a multiemployer pension
plan (the Plan).  On August 14, 1981, Schlitz withdrew
from the Plan.  See App. 151-152.  By the end of
September 1981, the Plan completed its calculations,
created a payment schedule, and sent out a demand for
payment (thereby making the first installment payment
-payable-) -on or before November 1, 1981.-  App. 153,
154.  From the outset, the parties agreed that the
annual installment payment amounted to $3,945,481,
and that the relevant interest rate was 7% per year.
After various controversies led to arbitration and a court
proceeding between Schlitz and the Plan, the courts and
parties eventually determined that the withdrawal
charge (calculated as of the last day of the previous
plan-bookkeeping year, December 31, 1980) amounted to
$23.3 million.
  But, the parties disagreed whether interest accrued
during 1981, the year in which Schlitz withdrew.  The
Plan claimed that, for purposes of calculating the
installment schedule, interest started accruing on the
last day of the plan year preceding withdrawal (Decem-
ber 31, 1980).  Schlitz, on the other hand, argued that
accrual began on the first day of the plan year following
withdrawal (January 1, 1982).  Under either reading,
the number of annual payments is eight.  But, under
the Plan's reading, the final payment would amount to
$3,499,361, whereas, in Schlitz's reading, that payment
would amount to $880,331.
  The arbitrator in this case agreed with Schlitz's
reading.  See 9 EBC 2385, 2405 (1988).  The District
Court, reviewing the arbitration award, disagreed, No.
88-C-908 (ED Wis., June 6, 1991) (reprinted in App. 25,
62-69), but the Court of Appeals for the Seventh Circuit
reversed the District Court, 3 F. 3d 994 (1993).  Because
the Seventh Circuit's decision conflicts with a holding of
the Third Circuit, Huber v. Casablanca Industries, Inc.,
916 F. 2d 85, 95-100 (1990), cert. dism'd, 506 U. S. ____
(1993), this Court granted certiorari, 512 U. S. ____
(1994).  Our conclusion, like that of the Seventh Circuit,
is that, for purposes of computation, interest does not
start accruing until the beginning of the plan year after
withdrawal.

                           II
  At first glance, the statutory provision that (the
parties agree) governs this case seems silent on the
issue of withdrawal-year interest.  Indeed, it does not
mention interest directly at all.  Rather, it says that a
withdrawing employer
-shall pay the amount determined under section
1391 . . . over the period of years necessary to
amortize the amount in level annual payments
determined under subparagraph (C), calculated as if
the first payment were made on the first day of the
plan year following the plan year in which the
withdrawal occurs and as if each subsequent pay-
ment were made on the first day of each subsequent
plan year.-  29 U. S. C. 1399(c)(1)(A)(i) (emphasis
added).
After considering the parties' arguments, which focus
upon the emphasized language, we have become con-
vinced that, for purposes of computation, this provision,
although causing interest to accrue over subsequent plan
years, does not cause interest to accrue during the
withdrawal year itself.

                            A
  The Plan points out, and we agree, that the word
-amortize- normally assumes interest charges.  After all,
the very idea of amortizing, say, a mortgage loan,
involves paying the principal of the debt over time along
with interest.  But the Plan (supported by the Govern-
ment, which is taking a view of the matter contrary to
the view the Pension Benefit Guaranty Corporation took
in the Huber case, see 916 F. 2d, at 96) goes on to claim
that the word -amortize- indicates that interest accrues
during the withdrawal year as well as during subse-
quent years.  We do not agree with that claim.  In our
view, one generally does not pay interest on a debt until
that debt arises-that is to say, until the principal of
the debt is outstanding.  And, the instruction to calcu-
late payment as if the first payment were made at the
beginning of the following year tells us to treat the debt
as if it arose at that time (i.e, the first day of the year
after withdrawal), not as if it arose one year earlier.
  For one thing, unless a loan is involved, one normally
expects a debtor to make a first payment at the time
the debt arises, not one payment cycle later.  Suppose,
for example, that a taxpayer arranges to pay a large tax
debt in four quarterly installments.  Would one not
expect the taxpayer to make the first payment on April
15, the day the tax debt becomes due?  Similarly, would
one not expect a buyer of, say, a business to make the
first payment (a down payment) at the time of the
closing?  By way of contrast, when a loan is involved
(say, when one borrows money on a home mortgage and
repays it in installments), interest accrual normally does
begin before the first payment.  That is because the
borrower has had the use of the money for one cycle
before the first payment.  In the case of a loan, it would
seem pointless, and would simply generate an unneces-
sary back-and-forth transfer of money, for a first
repayment to take place on the very day the lender
disburses the loan proceeds.
  The -first payment- at issue here, however, looks more
like a tax or purchase-money installment than a loan
installment.  Under the statute, the withdrawing
employer's debt does not arise at the end of the year
preceding the year of withdrawal.  In fact, the employer
may not have withdrawn from the plan at the beginning
of the year, but instead may have continued to make its
ordinary contribution until well into the year.  In any
event, the statute makes clear that the withdrawing
employer owes nothing until its plan demands payment,
which will inevitably happen some time after the
beginning of the year.  See 29 U. S. C. 1399(b)(1),
(c)(2).  In fact, the withdrawing employer cannot deter-
mine, or pay, the amount of its debt until the plan has
calculated that amount-which must take place some
time after the beginning of the withdrawal year.  All
these features make it difficult to find any analogy in
withdrawal liability to a loan.
  For another thing, we cannot easily reconcile the
Plan's reading of the statute with the statutory provision
that permits an employer to pay the amount owed in a
lump sum.  That provision says that a withdrawing
employer
-shall be entitled to prepay the outstanding amount
of the unpaid annual withdrawal liability payments
determined under [1399(c)(1)(C)], plus accrued
interest, if any, in whole or in part, without pen-
alty.-  29 U. S. C. 1399(c)(4).
We read this provision to permit an employer, by paying
a lump sum, to avoid paying the amortization interest
that 1399(c)(1)(A)(i) would otherwise cause to accrue.
(Under any other reading, the prepayment provision
would not create much of an -entitle[ment].-  Moreover,
the prepayment provision refers to -payments deter-
mined under [1399(c)(1)(C)]--not 1399(c)(1)(A), the
provision that causes amortization interest to accrue.)
It would seem odd if the prepayment provision enabled
an employer to avoid all interest except the interest
accruing during the year of withdrawal.  And, if interest
accrued from the last day of the year before withdrawal,
there would hardly ever be a time that no interest was
due.  Such a reading would thus make it very difficult
to give meaning to the words -if any- in the phrase
-plus accrued interest, if any.-  (The Third Circuit
suggested that these words might refer to a lump-sum
payment made immediately after a scheduled install-
ment.  See Huber, 916 F. 2d, at 99.  We agree that they
could, theoretically.  But, realistically speaking, it seems
unlikely that Congress inserted -if any- to deal with
such an unusual event.)
  Further, the interpretation under which interest would
accrue from the last day of the year before withdrawal
is difficult to reconcile with the statutory language that
defines a withdrawing employer's basic liability.  Section
1381(a) says that the withdrawing employer becomes
-liable to the plan in the amount determined under this
part to be the withdrawal liability.-  29 U. S. C.
1381(a).  Section 1381(b)(1) defines -withdrawal liabil-
ity- as -the amount determined under section 1391.-
Yet, 1391 says nothing about a year's worth of interest.
Why then read the provision here at issue so that it
inevitably and always creates liability in the amount of
the withdrawal charge plus one year's interest, irrespec-
tive of when the employer, in fact, withdraws and how
or when the employee begins to pay?
  Finally, the provision here at issue asks one to
calculate the installment payments as if the -first
payment- was made, not on the last day of the with-
drawal year, but on the -first day- of the next year, i.e.,
one year plus one day after the withdrawal charge
calculation date.  This choice of time (a year and a day)
would be an odd way to signal that one is to treat the
first payment as if it occurred at the end of a cycle.

                            B
  The Plan (and supporting amici) make several argu-
ments in support of a reading in which, for purposes of
calculation, interest starts accruing on the last day of
the year before withdrawal.  But we are not persuaded.
  First, the Plan argues that our interpretation works
against the basic objective of the statute, requiring a
withdrawing employer to pay a fair share of the
underfunding.  Under our interpretation, says the Plan,
the withdrawing employer will fail to pay a year's worth
of interest on the withdrawal charge, thereby requiring
the remaining employers to make up what, in fact, was
part of the withdrawing employer's fair share.  Suppose,
for example, that an underfunded plan needed exactly
$20 million as of the end of 1980 to create a sum that
would grow to just the amount needed to pay then
vested benefits falling due, say, in 1999.  By the end of
1981 that same plan would need more money; indeed, if
we assume the $20 million would have grown 7% each
year, it would need 7% more to pay those same vested
1999 benefits.  Thus, if the withdrawing employer's fair
share of the $20 million is $3 million as of the end of
1980, its fair share must have grown to $3,210,000 by
the end of 1981.  Why, asks the Plan, should the
remaining employers have to make up for this missing
$210,000?
  One answer to the Plan's question is that the
$210,000 will not necessarily be missing.  For one thing,
until the employer withdraws, it will be required to
make contributions that should contain a component
designed to reduce underfunding.  See 26 U. S. C.
412(b)(2); 29 U. S. C. 1082.  For another thing, if a
plan moves quickly, it may be able to force a withdraw-
ing employer to begin making installment payments
even before the end of the withdrawal year.  Either way,
to charge such an employer a full year's worth of
interest would overcharge that employer and thereby
provide the remaining employers with a kind of
underfunding-reduction windfall.
  Another answer is that we are not convinced that
MPPAA aims to make withdrawing employers pay an
actuarially perfect fair share, namely a set of payments
in amounts that, when invested, would theoretically
produce (on the plan's actuarial assumptions) a sum
precisely sufficient to pay (the employer's proportional
share of) a plan's estimated vested future benefits.  For
one thing, the statute forgives de minimis amounts.  See
29 U. S. C. 1389.  For another thing, it forgives all
annual installment payments after 20 years, see 29
U. S. C. 1399(c)(1)(B)-and that means that, if an
employer's normal annual contribution was low compared
to the withdrawal charge, the presence or absence of
withdrawal-year interest (which shows up at the end of
the payment schedule, see supra, at 5) will make no
difference (for the last payments will never be made).
Finally, in making the first installment -payable- only
after a plan demands it, MPPAA contemplates that an
employer sometimes may pay its actual first installment
long after the withdrawal year-as was the case in
Huber, see 916 F. 2d, at 88 (2--year delay)-in which
case no interpretation of the statute can avoid an
employer's actually paying something less than its fair
share of interest.
  Second, the Plan argues that the statute's language
favors its interpretation.  It refers to a dictionary that
defines an amortization plan as -`one where there are
partial payments of the principal, and accrued interest,
at stated periods for a definite time, at the expiration of
which the entire indebtedness will be extinguished,'-
Brief for Petitioner 27 (quoting Black's Law Dictionary
76 (5th ed. 1979)) (emphasis added), and to another
definition that says that, -`[i]f a loan is being repaid by
the amortization method, each payment is partially
repayment of principal and partially payment of inter-
est,'- Brief for Petitioner 27 (quoting S. Kellison, The
Theory of Interest 169 (2d ed. 1991)) (emphasis added).
These definitions accurately describe the repayment of
loans.  But, they do not seem to focus upon whether or
not one would normally include interest in the first
installment of an amortized payment of a debt that is
not a loan.  We have no reason to believe they intend to
define away the issue before us here.
  The Plan adds that our reading of the statute makes
the first -as if- clause in 1399(c)(1)(A)(i) superfluous
because, -if Congress had not intended to include
interest in the first payment, it could have simply
provided that the presumed payment schedule should be
calculated as if payments were made annually.-  Brief
for Petitioner 38.  It seems to us that the premise of
this argument is that, without contrary indication, one
would expect that, in the case of an indebtedness of the
kind here at issue, interest would not start accruing
before the first payment is due-a premise with which
we agree, see supra, at 8-9.  More importantly, had
Congress not used the words -as if the first payment
were made on the first day of the plan year following
the plan year in which the withdrawal occurs,- the
reader might have thought that interest would begin to
accrue immediately upon withdrawal, a reading that has
some intuitive appeal, see 3 F. 3d, at 1004 (-[a]n assess-
ment of interest between the date of withdrawal and the
date on which payments begin . . . would not be trou-
bling-).  But, the first -as if- clause makes clear that
interest does not begin accruing on that date.  (The
same concern may explain the second -as if- clause in
1399(c)(1)(A)(i), concerning subsequent payments.
Without that clause, one might think that one should
calculate the amortization schedule as if the first
payment is made out of order, and as if each successive
payment is made on the anniversary of the date of
withdrawal.)
  We recognize that Congress might have been more
specific.  For example, it could have said: -calculate
amortization as if the first payment is made on the date
the employer's withdrawal liability is due- (had it
intended interest to start accruing on that date); or:
-calculate amortization as if each payment is made on
the last day of the year at the beginning of which it is
due- (had it intended interest to start accruing one cycle
before the first payment is due).  Instead, Congress said
that one should calculate amortization -as if the first
payment were made on the first day of the plan year
following the plan year in which the withdrawal occurs.-
And, that actual language, as we have said, offers more
support for our interpretation than for the alternative.
Were we to read the actual language as does the Plan,
we would have to analogize the valuation date (the last
day of the year preceding withdrawal) to the date on
which liability arises; to the date on which the debt
becomes -payable-; or to the date on which the employer
withdraws.  But, in fact, the calculation date is none of
those things; it is a date chosen simply for ease of
administration; and ease of administration does not
require choosing the same date for interest-accrual
purposes.  See 3 F. 3d, at 1004 (-[e]stablishing a simple
rule for calculating funding shortfalls has nothing to do
with interest-).
  Third, the Plan points to legislative history.  The Plan
says that the original bill provided that interest would
not begin accruing until the date of withdrawal.  And,
the Plan points out, just like the version that ultimately
became law, the bill located the valuation date (the date
as of which the withdrawing employer's share in the
plan's underfunding is determined) at the end of the
plan year before withdrawal.  Thus, the Plan says, the
original bill contemplated a -funding gap--from the
valuation date to the withdrawal date.  Because the
section providing that interest started accruing on the
withdrawal date did not make it into the statute as
enacted, the Plan argues, Congress expressly rejected the
idea of a -gap.-  Brief for Petitioner 41.
  For the reasons stated above, see supra, at 12-13, we
doubt that our reading, as a practical matter, will cause
a significant gap to occur.  But, regardless, if we were
to consider legislative history in this case, we would find
that it undermines rather than supports the Plan's
reading.  The Plan's rendering is incomplete, for the
relevant statutory provisions went through not two but
four versions:
  (1)the original bill, calling for a valuation on the last
      day of the year before withdrawal and for interest
      accrual beginning on the date of withdrawal,
        see S. 1076, 96th Cong., 1st Sess., 104 (1979)
        (adding ERISA 4201(d)(1)(A), (e)(5)), reprinted
        in 125 Cong. Rec. 9800, 9803 (1979); H. R.
        3904, 96th Cong., 1st Sess., 104 (1979) (adding
        ERISA 4201(d)(1)(A), (e)(5)), reprinted in
        Hearings on the Multiemployer Pension Plan
        Amendments Act of 1979 before the Task Force
        on Welfare and Pension Plans of the Subcom-
        mittee on Labor-Management Relations of the
        House Committee on Education and Labor, 96th
        Cong., 1st Sess., pp. 3, 21, 25 (1979) (herein-
        after Task Force Hearings);
  (2)a second version, which moved the valuation date
      to the end of the withdrawal year and also said
      that interest shall be determined -as if each
      payment were made at the end of the year in
      which it is due- (thus apparently indicating that
      interest would start accruing one year before the
      first payment fell due),
        see H. R. 3904, 96th Cong., 1st Sess., 104
        (1979) (adding ERISA 4201(e)(2)(E), (f)(2)(C),
        (f)(3)(A), (f)(4)(A), (i)(2)(A)(ii)), reprinted in Task
        Force Hearings 246-247, 249, 251, 252, 256;
  (3)a third version, which kept the valuation date at
      the end of the withdrawal year but changed the
      interest-accrual language to the -as if- clauses
      found in the statute as we now know it,
        see H. R. 3904, 96th Cong., 1st Sess., 104
        (1980) (adding ERISA 4201(e)(2)(E)(i),
        (f)(2)(C)(i), (f)(3)(A), (f)(4)(A), (i)(2)(A)(i)), reprint-
        ed in H. R. Rep. No. 96-869, pt. 1, pp. 12-15
        (1980); H. R. 3904, 96th Cong., 1st Sess., 104
        (1980) (adding ERISA 4201(e)(2)(E)(i),
        (f)(2)(C)(i), (f)(3)(A), (f)(4)(A), 4202(c)(1)(A)(i)),
        reprinted in H. R. Rep. No. 96-869, pt. 2, pp.
        129-131, 135-136 (1980); and
  (4)a final version, which moved the valuation date
      back to the end of the year preceding withdrawal
      but retained the third version's interest-accrual
      language,
        see H. R. 3904, 96th Cong., 1st Sess., 104
        (1980) (adding ERISA 4211(b)(2)(E)(i),
        (c)(2)(C)(i)(I), (c)(3)(A), (c)(4)(A)(i),
        4219(c)(1)(A)(i)), reprinted in 126 Cong. Rec.
        23,003, 23,014, 23,016 (1980).
  This history suggests two things, neither of which
helps the Plan.  First, throughout the bill's history, the
valuation date and interest-accrual date moved about in
an apparently uncoordinated way.  This somewhat
undermines the Plan's suggestion that Congress was
very concerned about the interplay between the two.  It
certainly dispels the notion that the final version should
primarily be viewed as a rejection of the -funding gap-
found in the original bill.  Second, the evolution of the
-as if- clause from -as if each payment were made at
the end of the year in which it is due,- to -as if the
payment were made on the first day of the plan year
[following withdrawal]- suggests that Congress replaced
a scheme in which interest starts accruing a full
payment cycle before the first payment with a scheme in
which interest starts accruing on the first day of the
year following withdrawal.

                           III
  We consequently hold that MPPAA calculates its
installment schedule on the assumption that interest
begins accruing on the first day of the year following
withdrawal.  The judgment of the Court of Appeals is
therefore
                                              Affirmed.