Mr. Norgrove has the power to order directors and shareholders in a company to put up the cash and make compulsory contributions to an underfunded plan.
While Mr. Glazer is not obliged to seek clearance from the pensions regulator to buy the club, he might find himself facing stiff opposition from plan trustees and an unexpected bill for pension payments if he doesn't.
Manchester United participates in the £46 million Football League Limited Pension and Life Assurance Scheme, London, a multiemployer pension plan covering a number of English football clubs.
The football league plan was underfunded at its last valuation, in August 2002. Stephanie Wroe, secretary to the plan trustees, would not say how underfunded the plan is, but Manchester United's share of the shortfall was £2 million, according to the company's annual report for the year ended July 2004. This deficit is expected to be paid off by 2013, the report said.
Richard Farr, an adviser to Mr. Norgrove, would not comment on specific cases, but said participants in an underfunded plan could be disadvantaged in cases where the plan sponsor needs to assign resources to service debt and therefore would have fewer resources available for making pension contributions.
The regulator also believes a plan sponsor's ability to pay pensions could be affected if it carries debt that is more than 25% of the company's gross assets, added Mr. Farr.
Under the new guidelines, 25% is the threshold at which the regulator may force companies to guarantee they will make contributions or to actually pay up the cash.
Mr. Glazer's financing package is leveraged and will use club assets to secure at least half of the debt, estimated at around £550 million of the £790 million acquisition. The club reported total corporate assets of £238.7 million for the year ended July 2004, the most recent complete data available.
Will Swann, a spokesman for N.M. Rothschild & Sons, Ltd., London, acting on behalf of Red Football Ltd., London, the Glazer family's acquisition vehicle for the club, would not say if Rothschild or Red Football had been in contact with Mr. Norgrove.
But Red Football's offer document said it would assure the existing rights of employees, including their pensions.
The deficit in the football league plan might have grown since the 2002 valuation, but Ms. Wroe said trustees were not expecting any "nasty surprises" in the newest valuation, which is due in August.
Seeking clearance for corporate merger and acquisition deals from the new pension regulator will likely be increasingly common for pension trustees and buyers of U.K. companies with pension deficits.
Earlier this month trustees of the £1.6 billion Allied Domecq PLC Pension Plans, Bristol, were given assurance by bidder Pernod-Ricard that, following clearance by the pensions regulator, it would work to protect the pension plan and pay off the deficit. The plan was underfunded by £406 million, according to Allied Domecq's annual report for the year through August 2004. Pernod officials had reportedly approached the regulator to seek clearance for its bid for the firm. Neither Ron Amy, chairman of the trustees of the Allied Domecq plan, nor Louise Crawford, U.K. pensions manager at Allied Domecq, was able to comment by press time.
Mr. Norgrove enforces Pension Act 2004, allowing him to order company executives, directors and shareholders to make good any deficit in their company's pension plan.
Mr. Norgrove does not have the power to approve or block a deal. He can, however, give bidders and trustees guidance as to whether a particular corporate activity will trigger actions against company executives and directors for contributions, said Mr. Farr.