In Estate of Thomas Angelo Altobelli v. International Business Machines Corp., 77 F.3d 78 (4th Cir. 1996), a married employee of IBM participated in the company's pension and life insurance plan. According to the terms of the pension plan, if the participant failed to designate a beneficiary, the beneficiary of the life insurance plan became a "default beneficiary" of the pension plan. Some time later, the employee and his wife divorced and disposed of their property according to the terms of a settlement agreement that provided: "'All of the following property is hereafter the sole and exclusive property of the Husband, and the wife hereby waives and transfers to the Husband any interest that she may have in the property: (g) Husband's IBM pension and other deferred compensation plans, if any.'" (Id. at 79.) Nonetheless, the ex-wife was a "default beneficiary," according to the terms of the employee's plan, as the husband failed to designate a new beneficiary. Thus, upon the death of the employee, IBM sought to distribute the proceeds of the pension plan to the former wife, claiming that it "must administer the pension plans only according to their terms, without regard to the separation agreement." Id. The Fourth Circuit determined that the ex-wife had waived all rights to the plan, and therefore the benefits were payable to the husband's estate. The court considered whether a deceased employee's beneficiary could alienate his or her rights to the benefits of an ERISA governed pension plan, pursuant to a settlement agreement. Although ERISA contemplates an "anti-alienation" clause, requiring that "each pension plan shall provide that benefits under the plan may not be assigned or alienated," 29 U.S.C. 1056(d)(1)(1988), the court determined that the clause "did not apply to a beneficiary's waiver." Id. at 81. Rather, the provision applied to the participant of the plan, not the participant's beneficiary. Id. Moreover, the court determined that giving effect to a waiver embodied in a domestic relations order "did not burden plan administrators" so as to violate ERISA. Id. The court concluded: "In this case, each party clearly intended to relinquish all interests in the pension plans of the other. Congress's provision for QDROs reveals that, in some situations, it deems the intent of the parties sufficiently important to override the policy of simplified administration. Because enforcement of a divorce agreement's specific waiver of ERISA pension-plan benefits would require no marginal infringement of that policy beyond the infringement already necessitated by the QDRO provision, and since ERISA does not directly address the issue, we join the Seventh Circuit in holding as a matter of federal common law that such a waiver is to be given full effect." (Id.)