0 0 


To: Mary Averill, Division Manager, TPD 7 

~ 

Through: Ericka DeMarco, Actuarial Case Processing Branch Manager, Signature: ~-=-

From: Tanya Palacio, Actuary, ASD - Case Processing Section D Signature: ~ 

Actuarial Case Memo for: 

Delphi Retirement Program for Salaried Employees 

Case Number: 20637000 

Date of Plan Tennination: July 31, 2009 

Valuation Interest Rates: Lump Sum: 3.75%, Annuity: S.31%for20 years, 5.04% thereafter 

ASD - Case Processing Section D reviewed and accepted Bolton Partners DC Inc.'s valuation of 

this PBGC-trusteed pension plan using ACT 6.7. Unless this memo states otherwise, the valuation 

relied on participant data verified to be accurate and complete. The present values of benefits as of 

the Date of Plan Termination (DOPT) are: 

(I) (2) (3) (4) (5) (6) (7) 

No. Group Present Value of Present Value of Present Value of Present Value Present Value of 

Title IV Benefits Unfunded Non- Total Benefit of 4022(c) Tennination 

Guaranteed Liabilities Benefits Benefits 

Benefits (3) + (4) (3) + (6) 

7,606 Retirees $2,622,665,821 $294,371, 108 $2,917,036,929 $31,733,336 $2,654,399, 157 

Beneficiaries 

and Alternate 

434 Payees in Pay $75,427,852 $1,834,444 $77,262,296 $209,607 $75,63 7 ,459 

Separated 

3,776 Vesteds $217,678, 186 $4,082,377 $221,760,563 $139,978 $217,818,164 

Deferred 

19 Beneficiaries $1,200,982 $0 $1,200,982 $0 $1,200,982 

8,098 Active Vesteds $1,091,880,006 $221,238,069 $1,313,118,075 $8,074,627 $1,099,954,633 

0 Non-Vesteds $0 $0 $0 $0 $0 

19,933 TOTAL $4,008,852,84 7 $521.525,998 $4,530 378,845 $40,157,548 $4,049,0 l 0,395 

A. Present Value ofTitle IV Benefits $4,008,852,84 7 

B. Final Assets Available for Allocation* $2,513,034,548 

C. Unfunded Guaranteed Benefits (UGBs) (A-B) $1,495,818,299 

D. Unfunded Non-Guaranteed Benefits (UNGBs) $521,525, 998 

E. Unfunded Benefit Liabilities (UBLs) (C + D) $2,017 ,344,297 

F. Actual Recovery Ratio 7.70% 

G. 4022(c) Amount (D x F) + $46 $40, 157,548 

H. Present Value ofTermination Benefits (A+G) $4,049,010,395 

"' CMS Final Valuation Net Assets of $2,513, 109,716.74 were reduced by pre-tennination plan liabilities of $75, 168.59 

to account for the difference between the final pre-termination plan liability of $2,295,67 5.59 and the estimated pretennination plan liability of$2,220,507.00 shown on CMS. 

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l(b)(6) Applied to All Redactions on This Page I 

Case Number: 20637000 

1. Relevant Dates I Termination Information 

Notice of Determination (NOD): July 20, 2009 

Notice ofIntent to Terminate (NOIT): NIA 

Proposed DOPT contained in NOIT: NIA 

Bankruptcy Petition Date: October 8, 2005 

Facility Closing Date: As of DOPT, many Delphi facilities were open. For a list of the Delphi 

facilities that were closed as of DOPT, see Appendix A. 

Date of Trusteeship (DOTR): August 10, 2009 

Overpayment Accrual Commencement Date (OACD): July 31, 2009 

The plan administrator did not issue a NOIT in this case. Accordingly, the OACD is July 31, 2009, 

the later of the NOD and DOPT. 

2. Participant Count Reconciliation 

Participant Count as ofDOPT 

The participant count in this report does not agree with the count Maria Caban, Auditor TPD 7, 

reported in the Participant Review Summary, dated April 29, 2013 (Image Viewer Doc. 

#400416348). The auditor's population of20,187 has been changed to 20,160. The 20,160 count is 

different from the 19,933 count that appears on page one because of the method we used for valuing 

QDRO liabilities. The 20, 160 count includes 227 alternate payees in pay at DOPT whose liabilities 

were included with the calculation of the liabilities of the associated participants (see Section 24. 

Qualified Domestic Relations Orders (QDROs)). In summary the participant count reconciliation is 

shown in the following table: 

Populations Count 

Auditor's Population 20,187 

Additions to the Auditor's Population +12 

Subtractions to the Auditor's Population -39 

Valuation Population 20,160 

Alternate Payee's Liabilities included with 

Participant's Liabilities -227 

Case Memo Page One Liability Table Population 19,933 

The adjustments from the 20,187 in the auditor's population to the 20,160 in the valuation 

population are documented as follows: 

Additions: 

+5 

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l(b)(6) Applied to All Redactions on This Page I 

Case Number: 20637000 

participants with employee contributions as of DOPT but they were not included in the 

auditor's o ulation. 

+1 is the deferred beneficiary ofparticipant•••••••• 

- who died on JW1e 28, 2001, before DOPT but was not included the auditor's 

o ulation. 

+1 is a retired participant in pay as of DOPT but was not 

+5 

, and 

are entitled to benefits but they were not included the auditor's population. 

more infonnation) and are not entitled to benefits from the Delphi Salaried Plan. 

+12 Total Additions 

Deletions: 

4 ,and 

are separated non-vested participants (see table below for 

-32 There are 32 participants who received benefits from the Delphi Hourly Plan and/or GM or a 

purchased annuity (see Appendix B) and are not entitled to benefits from the Delphi Salaried 

Plan. 

-1 was listed twice as an alternate payee and as a participant in the 

auditor's database. She is not a participant. Therefore, we removed her from the valuation as a 

participant. 

-1 the alternate payee of , is 

only eligible for a survivor benefit from the benefits in pay of-Therefore, we 

removed her from the valuation as an alternate payee. 

-1 retired before DOPT and died on DOPT with no survivor 

benefit. Therefore, we removed her from the valuation. 

-39 Total Deletions 

No. Participant Participant SSN Years of Years of Additional Note 

Name Vesting 

Service 

Re uired 

5 

2 5 

3 5 

4 5 

Vesting 

Service 

Earned 

4.3333 

2.5833 

4.1667 

3.3333 

Did not return from educational leave; 

determined to be non~vested by plan 

administrator 

Service at GM is not credited in the Delphi 

plan because she was not active at the spinoff 

date 

Did not return from an unspecified leave; 

determined to be non-vested by plan 

administrator 

Did not return from educational leave; 

detennined to be non-vested by plan 

administrator 

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Case Number: 20637000 

Spectrum Count as ofMarch 26, 2015 

There are 20,871 participants, beneficiaries and alternate payees in Spectrum, 20, 160 of whom are 

included in the valuation. See Appendix C for a list ofthe 377 participants and beneficiaries in 

Spectrum who were excluded from the valuation. See Appendix D for a list ofthe 334 alternate 

payees in Spectrum who were excluded from the valuation. 

3. Data Issues 

The valuation relied on verified plan and participant data. Any changes made to this data are 

documented in the Leo database building tool. The source document used to make these changes 

can be found in either the archive system or in Image Viewer. Output from Leo is located in file 

20637000dl.xlsx in PBGC's Archive Access System. 

Fidelity Investments Data Sources 

Fidelity Investments (Fidelity), the third party administrator hired by Delphi to administer the plan, 

provided PBGC with the participant data tables from their pension administration system. Fidelity 

called these tables "Deconversion" files. PBGC built a data viewer in Access to view this data. The 

primary source of data for calculating service, average monthly base salary, and employee 

contribution account balances are the employment_ events, earnings_hours, and transaction_history 

tables located in the Deconversion files. We also used the Delphi documents pertaining to each 

participant on PBGC's [mage Viewer system and employment information from the Delphi 

participant employment history system (Delphi called this system SAP) as sources of data. The 

Deconversion and SAP files provided to PBGC by Fidelity are located on PBGC's Archive Access 

System (see folder titled Participant Data Review (PDR)). 

Deferred Participants' Part A and Part B Benefit Components Data and Calculations 

We calculated the Part A and Part B accrued benefits (see Section 5, Plan Benefit Formula 

Summary, for a description of Part A and Part B benefits) for all deferred participants. The 

following benefit components are needed to calculate the Part A and Part B accrued benefits: 

a. Part A Credited Service, 

b. Part B Credited Service, 

c. Eligibility Service 1

, 

d. Vesting Service, 

e. Average Monthly Base Salary, 

f. Total Employee Contributions without Interest made before July 1, l 977, 

1 Eligibility service in the plan documents is referred to as credited service. Up until the benefit freeze date, credited 

service for detennining benefits and credited service for detennining eligibility were the same. At the inception of the 

benefit freeze, the plan stipulated that credited service would accrue after the freeze date for eligibility purposes. In 

order to distinguish between the two types of credited service throughout this memo, we use the tenn eligibility service 

to mean credited service that includes credited service earned after the benefit freeze for the purposes of eligibility. 

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Case Number: 20637000 

g. 	 Total Employee Contributions without Interest made on or after July 1, 1977 and before 


October 1, 1979, and 


h. 	 Total Employee Contributions without Interest made on or after October 1, 1979. 

Fidelity calculated all or some ofthe benefit components (a) through (h) for over 9,000 deferred 

participants and the associated accrued monthy benefits from these components. We compared a 

sample (300 participants) ofthe Fidelity calculated benefit components and accrued benefits to 

benefit components and accrued benefits we calculated using participant data from the Delphi 

pension administration system data files. We found that the difference between the accrued benefits 

calculated with benefit components determined by Fidelity and the accrued benefits we calculated 

with benefit components we determined using participant data from the Delphi pension 

administration system data files was always within $5/5% tolerance. That is, the absolute value of 

the difference between the Fidelity accrued benefits and our calculated accrued benefits was never 

more than the greater of $5 or 5% of the lesser of the two accrued benefits. Because we were able to 

reasonably match the Fidelity accrued benefits, we accepted the participant benefit components (a) 

through (h) calculated by Fidelity when available. There are five files with the calculations and 

conclusions for accepting the Fidelity benefit components located on PBGC's Archive Access 

System (see AMB folder). A list of these files is contained in the PBGC File Memorandum, dated 

December 10, 2013 (Image Viewer Doc. #4014 79567). 

We calculated benefit components (a) through (h) for over 1,000 deferred participants for whom 

Fidelity did not provide inputs. We calculated a final benefit component needed for priority 

category 2 benefits, employee contributions with interest as of DOPT, for all deferred participants. 

For each participant, the valuation spreadsheets in PBGC's Archive Access System show whether 

the source of the individual benefit component used to calculate the participant's accrued benefit 

came from Fidelity or PBGC calculations. 

An individual participant could have up to 150 employment event records (each containing code, 

reason, description, and date), 296 earning records (each containing amount and date), and 643 

employee contribution records (each containing amount and date) in the Deconversion files. 1t was 

not practical to enter this volume of data for the deferred vested participants into the Leo database. 

We calculated the service, average monthly base salary, employee contribution balances without 

interest, and employee contribution with interest balance as of DOPT outside of ACT for all of the 

participants with missing benefit components. There are over 30 files with these calculations 

located on PBGC' s Archive Access System (see the Benefit Component Calculations folder). A list 

ofthese files is contained in the PBGC File Memorandum, dated December 23, 2013 (Image 

Viewer Doc. #401717491). 

PCJ Benefit Components Data 

We calculated the average monthly base salary as ofthe date 3 years before DOPT, July 31, 2006, 

for all participants who terminated employment after July 31, 2006 and who were eligible for 

priority category 3 benefits. 

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Case Number: 2063 7000 

We calculated total employee contributions without interest made on or after October 1, 1979 and 

on or before July 31, 2006 for all participants who terminated employment after July 31, 2006 and 

who were eligible for priority category 3 benefits. 

The PC3 Components Data files are located on PBGC's Archive Access System (see the Benefit 

Component Calculations PCJ folder). 

Retired Participants' Part A and Part B Benefit Components Data and Calculations 

Based on the benefit component testing described for deferred vested participants, we relied on the 

individual Part A and Part B data components described above from Fidelity for calculating 

retirees' benefits. If a retiree was missing a component necessary for the calculation of the retiree's 

accrued benefit, but the retiree's accrued benefit was available, then we used the Fidelity stored 

accrued benefit. Ifa retiree was missing a component necessary for the calculation ofthe retiree's 

benefit in pay and the associated accrued benefit, then we calculated the missing benefit component 

from the retiree's raw data. See Section 19, Pre-DOPT Retiree Benefit Changes I Pre-Termination 

Plan Liability, for the discussion of pre-DO PT retiree benefit changes. 

In-Service Withdrawal ofEmployee Contributions with Interest 

The plan allowed participants to withdraw their employee contributions with interest while still 

employed. A participant's Part B credited service was reset to zero years upon such a withdrawal. 

We used the Deconversion data described above to calculate the "ERISA Minimum Benefit" at 

each in-service withdrawal date. Please see Section 11, Benefit I Plan Document Interpretations of 

Note, subsection H. Withdrawal ofEmployee Contributions, for more information regarding the 

"ERISA Minimum Benefit." 

Deferred and Retired Participants' Part C Benefit Components Data and Calculations 

We calculated the Part C cash balance accrued benefit (see Section 5, Plan Benefit Formula 

Summary, for a description of Part C benefits) for all deferred and retired participants. In order to 

calculate the Part C accrued benefit for a participant, the participant's cash balance as of the date of 

the benefit freeze is needed. We calculated this amount using the raw earnings data available for 

participants in the Delphi Deconversion files. We were able to match the Fidelity cash balance 

credit data and cash balance at the date of benefit freeze for over 95% of the Part C population 

within $5/5% tolerance. We sent our findings to John DeMarco, the former Delphi Director of 

Pension and Welfare Benefits. Mr. DeMarco was able to determine that, for some participants, the 

earnings data that Fidelity used to calculate Part C credits were incorrect. Mr. DeMarco obtained 

earnings data from Delphi's SAP employee record keeping system. We accepted the earnings data 

he provided to us for 23 participants and recalculated their Part C credits. The earnings data 

provided by Mr. De Marco is contained in the Leo database. Below is a breakdovm of the source for 

the data we used to calculate the cash balance as of the benefit freeze date for the cash balance 

population. 

Data used to Calculate Partici ant's Cash Balance Number of Partici ants 

Fideli Cash Balance Credit Data I,578 

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0 

Case Number: 20637000 

Data used to Calculate Participant's Cash Balance Number of Participants 

Earnings Data from the Delphi Deconversion File 28 

Earnings Dara Provided by John DeMarco 23 

Fidelity Cash Balance (cash balance credit and earnings data were not 

available for these participants) 

2 

4. Plan Documents 

General Motors Corporation (GM) spun off Delphi Automotive Systems Corporation (Delphi) 

effective January 1, 1999 as a wholly owned subsidiary and, effective May 28, 1999, as an 

independent company. As part ofthe spinoff, Delphi assumed responsibility for the active salaried 

employees of the spun-off units, including employees on layoff. Delphi was not responsible for GM 

employees who terminated employment before January I, 1999, except for prior GM deferred 

vested employees working for divested units of GM as of January 1, 1999 (see Section 5, Plan 

Benefit Formula Summary, for a list of GM divested units). 

Document Effective Date Adoption Document Phase-In Percentage Phase-In Will Cut 

Description Date Summarized? Benefits? 

Delphi Effective Not Yes 100% No 

Retirement January I, signed or 

Program for 1999 with dated* 

Salaried modifications 

Employees through 

September 30, 

2002 

Delphi October I, Not Yes Benefit Rate increase, $80/80% Yes 

Retirement 2004 signed or based on effective date of 

Program for dated• increase 

Salaried 

Employees Early and Interim supplement No** 

(Restated increases, $80/80% based on 

October l, effective date of increase 

2008) 40l(a)(17) Compensation Limits, Yes 

$80180%, $60160%, $40140%, 

$20/20%, 0% based on effective 

date of the increase 

Immediate Vesting at Freeze Yes 

Date, 0% based on effective date 

of the benefit freeze 

Mutually Satisfactory Yes 

Retirement, September 30, 2008, 

0% 


"' PBGC accepted the unsigned documents above as valid adopted plan documents (see the March 17, 2015 e-mail from 


OCC, Image Viewer Doc. #403829824) . 


.. The Early and Interim supplement increases were not large enough to be reduced by the $80/80% phase-in limitation 


for any participant. 


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Case Number: 20637000 

Plan benefits were frozen effective September 30, 2008. The only plan document containing the 

freeze provisions is the unsigned Restatement effective October 1, 2004, which OCC determined 

was validly adopted (see Section 11, Benefit/Plan Document Interpretations ofNote, subsection S. 

Validity ofBenefit Freeze). 

The two unsigned plan documents listed in the table above are the only formal plan documents 

since January 1, 1999. In many instances, plan benefit changes were made through internal Delphi 

documents, agreements, proposals, and company memorandums without the plan being formally 

amended. These documents are available on PBGC's Image Viewer system in the directory for this 

PBGC case. These other types of plan documents are listed below. 

Career Transition Program and Salaried Retirement Incentive Program Agreements 

At various times, Delphi made retirement windows available to certain participants to encourage 

employee retirement through "Programs." Typically, these retirement windows, in regard to plan 

provisions, contained increases to final average salary and/or subsidized early retirement benefits. 

Listed below are the program descriptions for which we have copies. 

1. 	December 7, 1998 Administrative Guidelines - Delphi Automotive Systems Window 


Retirement Program and Career Transition Program (CTP) 


2. 	January 1, 1999 (Window A and CTP A) and January 1, 1999 - April 1 (Window B and CTP 

B), 1999 Delphi Automotive Systems Window Retirement Programs (Window) and Career 

Transition Programs {CTP) for Salaried Employees 

3. 	February l, 2001 Delphi Salaried Retirement Incentive Program (SRIP) and Career Transition 

Program 

4. April 	1, 2001 Delphi Delco Salaried Retirement Incentive Program and Career Transition 


Program 


5. 	June l, 2001 Delphi Salaried Retirement Incentive Program and Career Transition Program 

6. 	 March 1, 2002 Delphi Salaried Retirement Incentive Program and Career Transition Program 

7. 	March 1, 2004 Delphi U.S. Targeted Salaried Retirement Incentive Program 

8. 	May 1, 2004 Delphi U.S. Information Technology Targeted Salaried Retirement Incentive 


Program 


Benefit increases attributed to the Programs are 100% phased-in. 

Divestiture, Sale and Asset Purchase Agreements 

Listed below are the divestiture agreements for which we have copies. In many cases the available 

agreement documents are missing pages. 

1. 	 January 1, 1985, Sales Agreement between EDS and General Motors Corporation 

2. 	 January 1, 1988, Sales Agreement between Detroit Diesel Technology Corporation and 


General Motors Corporation 


3. 	 October 31, 1992, Sales Agreement between Dayton-Phoenix and General Motors Corporation 

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Case Number: 20637000 

4. 	 February 18, 1994 Asset Purchase Agreement by and between American Axle & 

Manufacturing, Inc. and General Motors Corporation 

5. 	 March 31, 1994 Asset Purchase Agreement between ITT Automotive Electrical Systems, Inc. 

and General Motors Corporation 

6. 	 July 13, 1 994 Asset Purchase Agreement by and among DR International, Inc., and General 

Motors Corporation 

7. 	 June 1, 1995 Asset Purchase Agreement by and between General Motors Corporation, Delphi 

Energy & Engine Management Systems Division and Magnequench International, Inc. 

8. 	 December 10, 1996 Asset Purchase Agreement among General Motors Corporation, Peregrine 

Incorporated and Peregrine U.S., Inc. 

9. 	 August 31, 1998 Master Sale and Purchase Agreement General Motors Corporation and Lear 

Corporation 

10. September 29, 1998 Lightsource Formation Agreement among General Motors Corporation, 

Lightsource Parent Corporation, and PEP Guide, LLC 

11. December 22, 1998 Memorandum of Understanding Regarding the Impact on Employees of 

the Sale of Coil Springs Business of Delphi Chassis Systems - Livonia 

12. September 17, 2007 Asset Purchase Agreement among TRW Integrated Chassis Systems LLC, 

Delphi Automotive Systems LLC and Delphi Technologies, Inc. 

13. October 15, 2007 Master Sale and Purchase Agreement among Delphi Corporation, and 

INTEV A Products, LLC 

14. February 19, 2008 Sale and Purchase Agreement by and between Delphi Automotive Systems 

LLC and Kyklos, Inc. 

15.March 7, 2008 Asset Purchase Agreement by and between Delphi Automotive Systems LLC 

and Tenneco Automotive Operating Company Inc. 

16. November 7, 2008 Amended and Restated Master Sale and Purchase Agreement among Delphi 

Corporation, Strattec Security Corporation, Witte-Velbert GMBH & Co. KG and Vehicle 

Access Systems Technology LLC 

Summary Plan Description and Summary ofPlan Changes Documents 

1. 	 Summary Plan Description for Salaried Employees Hired on or before December 31, 2000 

and/or with a Service Date on or before December 31, 2000 

2. 	 Summary Plan Description for Salaried Employees Hired on or after January 1, 2001 and/or 

with a Service Date on or before January 1, 2001 

3. Important News for Delphi U.S. Salaried Employees for Employees with a Length of Service 

Date on or before September 30, 1983 

4. 	Important News for Delphi U.S. Salaried Employees for Employees with a Length of Service 

Date between October 1, 1983 and December 31, 1987 

5. Important News for Delphi U.S. Salaried Employees for Employees with a Length of Service 

Date between January 1, 1988 and December 31, 1992 

6. 	Important News for Delphi U.S. Salaried Employees for Employees with a Length of Service 

Date between January 1, 1993 and December 31, 2000 

7. 	Important News for Delphi U.S. Salaried Employees for Employees with a Length of Service 

Date on or after January l, 2001 

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Delphi Employee Benefit Plans Committee Memorandums and Minutes 

Case Number: 2063 7000 

I. 	 December 2, 1999, Benefit Modifications Covering Salaried Employees in the U.S. 

2. 	 December I 0, 1999, Proposed Treatment of Employees Transferred Between Delphi 

Automotive Systems and Packard-Hughes Interconnect 

3. 	 March 21, 2000, Proposed Amendment to the Salaried Retirement Program Regarding the 

Treatment of Salaried Employees Who Transferred to GM from Hughes under the GM-Hughes 

Transfer Procedure and Subsequently Became Delphi Employees Due to the Spin-off 

4. 	 September 12, 2000, Proposed SRIP Amendment to the Delphi Automotive Systems (Delphi) 

Retirement Program for Salaried Employees 

5. 	 October 12, 2000, Proposed Amendment to the Delphi Retirement Program for Salaried 

Employees (SRP) Covering Certain Peregrine Employees 

6. 	 January 25, 2001, Proposed SRIP Amendment to the Delphi Automotive Systems (Delphi) 

Retirement Program for Salaried Employees of Delco Electronics Corporation 

7. 	 March 20, 2001, Proposed SRIP Amendment to the Delphi Automotive Systems (Delphi) 

Retirement Program for Salaried Employees 

8. 	 November 20, 2001, Proposed SRIP I CTP Amendments to the Delphi Automotive Systems 

(Delphi) Retirement Program for U.S. Salaried Employees 

9. 	 November 14, 2002, Reinstatement of S-SPP Match and Required Retention Period, Increase 

in Retirement Accumulation Plan Pay Credit 

10. November 14, 2002, Minutes of Employee Benefit Plans Committee Meeting 

11. August 15, 2003, Cash Balance Plan: Delphi Retirement Program for Salaried Employees 

12. November 10, 2003, Benefit Modification Covering U.S. Salaried Employees 

13. February 19, 2004, Proposed SRIP Amendments to the Delphi Retirement Program for 

Salaried Employees 

14. May 21, 2004, Amendment to the Delphi Retirement Program for Salaried Employees 

15. May 21, 2004, Benefit Modification Covering U.S. Salaried Employees 

16. January 25, 2008, Proposed Treatment of Salaried Employees Transferred Between Delphi 

Mechatronics Systems and Delphi Corporation 

17. August 15, 2008, Modifications to Freeze the Delphi Retirement Program for Salaried 

Employees effective September 30, 2008 

18. August 15, 2008, Amendment to the Delphi Retirement Program for Salaried Employees to 

comply with the Pension Protection Act 

19. September 19, 2008, Proposed Treatment of Salaried Retirees of Packard-Hughes Interconnect 

Insurance Company Purchased Annuity Contracts 

1. 	 Aetna Life Insurance Company Group Annuity Contract No. GA-14646 Effective May 1, 

2000 

2. 	 MetLife Transfer Agreement Group Annuity Contract No. 25427 

3. 	 The Prudential Insurance Company of America Group Annuity Contract No. GA-40016 

Effective May 1, 2000 

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Case Number: 20637000 

Fidelity Plan Rules Documents 

Fidelity wrote and maintained two "Plan Rules" documents: Delphi Salaried Programs Defined 

Benefit Plan Rules (Image Viewer Doc. #400914215) and Delphi Divestitures Defined Benefit Plan 

Rules (Image Viewer Doc. #400913994). Upon comparison to actual plan documents, these 

documents reasonably summarized plan provisions. In many cases these documents provide 

historical background and reasonable interpretations to plan issues not contained in the actual plan 

documents. 

Miscellaneous Documents 

1. 	 January 29, 1998, GM HR Communications Bulletin Board Memo: Treatment of Salaried 


Employees Transferring Between the U.S. and Canada with Respect to Retirement Benefits 


2. 	 December 22, 1998, GM- Delphi Spin-Off Agreement: U.S. Employee Matters Agreement 

3. 	 September 13, 2007 Internal Revenue Service ruling to Delphi regarding plan freeze benefit 


increases while in bankruptcy 


4. 	 September 15, 2008 Delphi Benefit Freeze Notice to Participants 

5. 	 September 24, 2008 IRS Notice 2008-30 Letter from Fidelity to John DeMarco of Delphi 

6. 	 Undated, Executive Summary, Proposed Delphi Automotive Systems Treatment of Salaried 


Employees Transferred between Delphi Automotive Systems and Delphi Diesel Systems 


7. 	 Questions and Answers Document: Special Provisions of the Delphi Salaried Retirement 

Program for Delphi Salaried Employees who transferred from Hughes to GM Prior to May 28, 

1999 

8. 	 Agreement - Delphi Automotive Systems Treatment of Salaried Employees Transferred 


between Delphi Automotive Systems and ASEC Manufacturing 


9. 	 December 17, 2010, Noble Eagle Document, Compensation and Benefit Treatment for Salaried 

and Hourly Employees Called to Special Active Duty in Armed Forces as a result of the 

Incidents Occurring on September 11, 2001 

10. Occupational Pension Plan In Favor of the Employees ofDelphi Automotive Systems 


Luxembourg S.A. hereafter called the Employer, Rules of the Personal contribution Plan 


11. Rules of the Retirement Plan of Delphi Controladora, S.A. De C.V. 

12. Your General Motors Status and Your General Motors Benefits Following the Sale of the 


Saginaw Actuator Business if You are a Salaried Employee 


13. Your General Motors Status and Your General Motors Benefits Following the Sale ofTerex 

Division if You are a Salaried Employee 

5. Plan Benefit Formula Summary 

The Delphi Salaried Plan benefits are composed of three parts; Part A, Part B, and Part C. Parts A 

and Bare applicable to participants who accrued service before January 1, 2001. Part C is 

applicable to (1) any new salaried employee hired on or after January 1, 2001 or (2) any salaried 

employee who terminated employment before January 1, 2001 and was rehired on or after January 

1, 2001. 

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Case Number: 20637000 

PBGC concluded that the plan sponsor validly froze plan benefits effective September 30, 2008 (see 

Section 11, Benefit/Plan Document Interpretations ofNote, subsection S. Validity ofBenefit 

Freeze). 

Part A Benefits 

Part A benefits are benefits applicable to any salaried employee who accrued service before January 

l, 2001. Employee contributions were not required in order for a participant to accrue Part A 

benefits. Part A benefits are determined based on the participant's Basic Benefit Rate multiplied by 

years of Part A credited service. 

A participant's Basic Benefit Rate is based on the participant's Benefit Determination Date and 

Benefit Class Code. 

The Benefit Determination Date for a participant eligible for immediate retirement at termination of 

employment is the first of the month following the date of termination of employment; otherwise, it 

is the date of termination of employment. [fa participant accrues a Part A benefit, terminates 

employment, and is rehired on or after January l, 2001, and so begins accruing a Part C benefit (see 

Part C Benefits below), then the benefit rate used to calculate the participant's Part A benefit is 

based on the Benefit Determination Date using the participant's final date of termination of 

employment. 

The Benefit Class Code of a participant is determined by the participant's salaried position level for 

the greatest number ofdays during the 24 consecutive months preceding the earlier of the last day 

worked or benefit freeze date. John DeMarco, the former Delphi Director of Pension and Welfare 

Benefits, provided information regarding the determination of the participant's salaried position 

level (see Image Viewer Doc. #404521931 ). 

The Benefit Class Code applicable to an employee is shown in the following table: 

Salaried Position Level Benefit Class Code 

I and 2 A 

3 B 

4 c 

5 and above D 

Over 99% of the participants with Part A benefits had a Benefit Class Code equal to D. There were 

93 participants for whom we did not have their Benefit Class Code and did not have enough 

participant data to determine their Benefit Class Code. We assigned a Benefit Class Code of D to 

these participants. 

Until October 1, 2002, Basic Benefit Rates were determined for more than a one-year period for 

participants eligible for immediate retirement. The Delphi Employee Benefit Plans Committee 

referred to these periods as "rolling" rate periods. A participant eligible for rolling rates would 

initially be placed into pay using the benefit rate in effect at the participant's Benefit Determination 

Date. Thereafter, the participant's benefit in pay would be recalculated each effective date that falls 

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Case Number: 2063 7000 

within the rolling rate period that contains the participant's Benefit Determination Date in 

accordance with the rolling rate benefit tables. 

For example, consider a participant with a Benefit Class Code of D who is eligible for immediate 

retirement and retires on January I, 2001. This retirement date falls in the rolling rate period from 

October 1, 1999 to October 1, 2003. The participant's initial benefit in pay is calculated using a 

benefit rate of $43.25 (taken from the appropriate rolling rate table below). On October 1, 200 I, the 

participant's benefit would be recalculated using a benefit rate of$45.25. On October 1, 2002, the 

participant's benefit would be recalculated using a benefit rate of $47.45. The participant would 

receive no more benefit increases from rolling rates after October 1, 2002. 

The following two tables show the benefit rates for the two rolling rate periods associated with the 

plan after the GM spinoff: 

Table of Rolling Benefit Rates for Participants Eligible for Immediate Retirement On and After 

October 1, 1996 and Prior to October 1, 1999 

Benefit Benefit Class Basic Benefit Rate for Benefit Payments Commencing 

Detennination 

Date 

Code 10/01/1996 

through 

0910 l/1997 

I 0/0 l/l 997 

through 

09/01/1998 

10101/1998 

through 

09/01/1999 

I 0/0I/1999 and 

after 

l0/0l/1996 and A unknown unknown unknown $40.50 

prior to B unknown unknown unknown $40.75 

I 0/01/1999 c unknown unknown unknown $41.00 

D unknown unknown unknown $41.25 

Table of Rolling Benefit Rates for Participants Eligible for Immediate Retirement On and After 

October I, 1999 and Prior to October I, 2003 

Benefit Benefit Class Basic Benefit Rate for Benefit Payments Commencing 

Determination 

Date 

Code 10/01/1999 

through 

09/01/2000 

I 0/01/2000 

through 

09/01/2001 

10/01/2001 

through 

0910112002 

10/0 l/2002 and 

after 

10/0 l /1999 and A $40.80 $42.50 $44.50 $46.70 

prior to 8 $41.05 $42.75 $44.75 $46.95 

10/01/2003 c $41.30 $43.00 $45.00 $47.20 

D $41.55 $43.25 $45.25 $47.45 

Basic Benefit Rates (no rolling rate periods) for participants who terminated employment before 

October l, 2003 and who were not eligible for immediate retirement are shown in the following 

table: 

Benefit Determination Date Basic Benefit Rate by Benefit Class Code 

A B c D 

!0/0111999 and prior to l 0/0 l 12000 $40.80 $41.05 $41.30 $41.55 

I 0/0 l/2000 and prior to l 0/01/200 l $42.50 $42.75 $43.00 $43.25 

10/0 l/200 l and prior to 10/0112002 $44.50 $44.75 $45.00 $45.25 

10/0112002 and prior to l 0/0112003 $46.70 $46.95 $47.20 $47.45 

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Case Number: 20637000 

After October 1, 2003, the Salaried Retirement Program did not adopt any rolling rate periods. 

Basic Benefit Rates for all participants with a date of termination of employment on or after 

October 1, 2003 are shown in the following table: 

Benefit Determination Date 

10/0 l/2003 and prior to 10/01/2004 

IOto I /2004 and after 

A 

Basic Benefit Rate by Benefit Class Code 

B c 

$47.75 $48.00 $48.25 

$48.80 $49.05 $49.30 

D 

$48.50 

$49.55 

Please see Section 11, Benefit/Plan Document Interpretations ofNote, subsection A. Benefit 

Changes Effective October 1, 2003, for more information regarding the adoption of the benefit rates 

effective October 1, 2003. 

Part A credited service is calculated as complete years and months from the participant's date of 

hire where one month is credited ifthe participant works at least 15 days in a month. 

Part B Benefits 

Part B benefits are applicable to any salaried employee who accrued service before January 1, 2001 

and who made employee contributions to the Plan. The contribution rate was 1.25% of monthly 

base salary in excess of$4,200, effective January 1, 2008 ($3,500, effective January l, 2003; 

$3,000, effective January 1, 2000; and $2, 700, prior to January 1, 2000). On September 3 0, 2008, 

the plan freeze date, employee contributions ceased. Interest on accumulated employee 

contributions continued to accrue after the freeze date. There are two Part B benefits, Part B 

Primary and Part B Supplementary. 

Part B Primary 

Part B Primary monthly benefits are calculated using the following formula: (0.05 x employee 

contributions without interest made before July 1, 1977) + (0.0625 x employee contributions 

without interest made on or after July 1, 1977 and before October 1, 1979) + (0.08333 x employee 

contributions without interest made on or after October 1, 1979). 

Under the plan, participants who withdraw their employee contributions after termination of 

employment receive a reduced Part B Primary benefit. The plan reduction offset is the monthly 

benefit attributable to the employee contributions as defined in ERISA. The plan provisions do not 

specify how the benefit attributable to employee contributions at the date ofretirement is calculated. 

Plan practice shows that accumulated employee contributions were converted at the participant's 

normal retirement date to a straight life annuity and plan factors were used to determine the benefit 

at the participant's date of retirement. We followed this method in the valuation. 

Prior to DOPT the plan credited employee contributions with annual interest of 120% of the federal 

mid-term rate from the first day of the plan year. For the purposes of determining the monthly 

benefit attributable to the employee contributions the plan calculated the annuity equivalent of the 

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Case Number: 2063 7000 

employee contributions in accordance with Section 411 of the Code and regulations thereunder, 

using the Applicable Interest Rate and Applicable Mortality Table as defined in IRC §417(e)(3). 

The plan defines the Applicable Interest Rate using a lookback to the third month prior to the first 

day of the plan year preceding the date of determination. 

For participants with employee contributions remaining in the plan at DOPT, for the purposes of 

determining the monthly benefit attributable to the employee contributions, employee contributions 

are credited with 4.57% interest after DOPT, the rate defined in lRC §417(e)(3) as ofJuly 1, 2008, 

the third month prior to the first day of the plan year preceding DOPT. The employee contributions 

at normal retirement date are converted to a straight life annuity using 4.57% interest and the 

Applicable Mortality Table as defined in IRC §417(e)(3) (1994 Group Annuity Reserving Table 

Mortality, 50% male I 50% female, projected to 2002). 

The plan allowed participants to make employee contribution withdrawals while working. Please 

see Section 11. Benefit I Plan Document Interpretations ofNote, subsection H. Withdrawal of 

Employee Contributions while Working for a discussion of this plan provision. 

Part B Supplementary 

The monthly Part B Supplementary benefit is based on the following formula: 1 % x Part B Credited 

Service x (Average Monthly Base Salary~ Part B Supplementary Compensation Level). 

Benefit Determination Date Part B Supplementary Compensation Level 

!O/Ol/1999 and prior to !0/0112000 $4,155.00 

l 0/0 l /2000 and prior to l 0/0I1200 I $4,325.00 

I01011200 I and prior to l 0/01 /2002 $4,525.00 

I010112002 and prior to I 010 I /2003 $4,745.00 

I 0/01 /2003 and prior to 10/01/2004 $4,850.00 

1010 t/2004 and after $4,955.00* 

• In Part B, Article I, Section 2(a)(2) ofthe 2008 Restatement, the Part B formula compensation level is written as 

$4,745, instead of$4,955. The Plan Rules document and retiree calculations show that $4,955 was used effective 

October l, 2004. John DeMarco, the former Delphi Director of Pension and Welfare Benefits, con finned this was an 

error in the plan document. Note also that a $4,955 Part B formula compensation level maintains the historical 

relationship between the Part B formula compensation level and the Benefit Class Code D benefit rate (100 x $49.55 = 

$4,955). 

Please see Section 11, Benefit/Plan Document Interpretations ofNote, subsection A. Benefit 

Changes Effective October 1, 2003, for more information regarding the adoption of the Part B 

Supplementary Compensation level effective October 1, 2003. 

Ifthe first date the participant made employee contributions is on or before either the date the 

participant attains age 30 or the date the participant is first eligible to make employee contributions, 

then Part B credited service is equal to Part A credited service. A participant is first eligible to make 

employee contributions after the following conditions are met: 

1. Attainment of age 21, 

2. The employee has at least 6 months of continuous service, and 

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Case Number: 20637000 

3. 	The employee's monthly base salary rate is greater than $2,700, prior to January 1, 2000; 


$3,000, effective January 1, 2000; $3,500, effective January 1, 2003; and $4,200 effective 


January 1, 2008. 


[f the participant elects to participate in Part B after the attainment of age 30, then Part B credited 

service begins to accrue on the date of participation. The participant is granted additional Part B 

credited service on a "time for time" basis for any period of employment prior to age 30 for which 

Part A credited service accrued, not to exceed the service accrued after the date of Part B 

participation. This means that Part A credited service earned before age 30 will be credited as Part 

B credited service but this additional service from Part A is limited to the amount ofPart B credited 

service earned after age 30. 

For example consider a participant who earns 10 years of Part A credited service before age 30 and 

did not make any employee contributions. The participant starts making employee contributions at 

age 3 5 and continues making employee contributions until termination of employment at age 40. 

Because the participant earned 5 years of Part B credited service from age 3 5 to age 40, the 

participant will receive 5 additional years of Part B credited service for Part A credited service 

earned before age 30 based on the time for time rule. The participant's total Part B credited service 

is 10 years. 

Ifthe participant in the example above made employee contributions from age 35 to age 55, then 

the participant earned 20 years of Part B credited service for this period. This participant wilt 

receive I 0 additional years of Part B credited service based on the time for time rule because the 

additional service is limited to the participant's Part A service earned before age 30. The 

participant's total Part B credited service is 30 years. 

The plan permitted participants to withdraw their employee contributions with interest. Please see 

Section 11, Benefit/Plan Document Interpretations ofNote, subsection H Withdrawal ofEmployee 

Contributions, for a discussion of the employee contribution in-service and out-of-service 

withdrawal provisions of the plan. 

Average Monthly Base Salary is defined in the plan as the monthly average of the employee's Base 

Salary for the highest 60 months of the 120 months immediately preceding the employee's 

termination of employment. Base Salary is the salary paid for a month of work, including deferred 

compensation, limited to the amount defined in IRC section 401(a)(l 7). Please see Section 11, 

Benefit/Plan Document Interpretations ofNote, subsection N Average Monthly Base Salary, for 

more information. In the case of a participant who accrues a Part B Supplementary benefit, 

terminates employment, and is rehired on or after January 1, 2001 and so begins accruing a Part C 

benefit (see Part C Benefits below), the Average Monthly Base Salary used to calculate the 

participant's Part B Supplementary benefit will be the Average Monthly Base Salary as of the 

participant's final date of termination of employment. 

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Case Number: 20637000 

Part C Benefits 

Part C benefits are non-contributory benefits applicable to salaried employees who have a length of 

service date (see Section 11, Benefit/Plan Document Interpretations ofNote, subsection C. Length 

ofService Date) on or after January 1, 2001. This means salaried employees hired or rehired on or 

after January 1, 2001 or who were not full time employees before 200 l but became full time 

employees on or after January 1, 2001 are eligible for Part C benefits. For example, salaried 

employees who were college student interns before 2001 and became full time employees on or 

after January 1, 2001 were participants in Part Con their effective date of full time employment. 

These participants accrued only a Part A benefit for their service earned while they were student 

interns. 

Part C benefits are cash balance benefits. Participants' initial cash balances were $0. The Part C 

data we received from Fidelity included an "Implementation Balance" as of September 30, 2003 for 

most participants who were hired before 2003. We noted that there were no 2001 and 2002 cash 

balance credits for these participants in the data. We confirmed with John DeMarco, the former 

Delphi Director of Pension and Welfare Benefits, that the September 30, 2003 "Implementation 

Balance" included the 2001 and 2002 cash balance credits and accrued interest up to September 30, 

2003. 

The cash balance period for determining cash balance credits changed from calendar years to plan 

years (October 1 to September 30) effective October 1, 2003. There was a short cash balance 

transition period from January 1, 2003 through September 30, 2003. Cash balance credits were 

based on a percent of earnings credited at the end of each cash balance period as shown in the 

following table: 

Cash Balance Period Percent of Earnings 

01/01/2001 to 12/3 t/2001 4% 

0 l/O l/2002 to l 2/3 l /2002 4.7% (per the November 14, 2002, Minutes of Employee Benefit Plans Committee 

Meeting the change from 4% to 4.7% of earnings was effective 01/01/2002, Image 

Viewer Doc. #403762504) 

0 t/O l/2003 to 09/3012003 4.7% 

l 0/0 l/2003 to 09/30/2004 4.7% 

I 0/0 l/2004 to 09/30/2005 4.7% 

10/01/2005 to 09/30/2006 4.7% 

10/0112006 to 09/3012007 4.7% 

I 0/0112007 to 09/30/2008 4.7% 

Cash balance credits ceased on September 30, 2008, the plan freeze date. Interest on accumulated 

cash balance credits continued to accrue after the freeze date (see Section 11, Benefit/Plan 

Document Interpretations ofNote, subsection R. Reference Error Regarding Cash Balance 

Crediting ofInterest). 

Starting October 1, 2003, the plan credited interest to participants' accounts on the last day of every 

plan year, instead of calendar year, using the annual interest rates of 30-Year Treasury Securities 

"or such other rate, as specified by the Commissioner of the Internal Revenue Service" for the 

month of July prior to the first day of the plan year during which interest rates were being credited. 

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Case Number: 20637000 

According to plan documents, interest was credited on a calendar year basis through December 31, 

2002 and in the cash balance transition period before October 1, 2003 using the interest rates of 30­

Year Treasury Securities for the month of August prior to the calendar year during which interest 

rates were being credited. We found that plan administrators used 5.61%, the July, 2001 30-Year 

Treasury Rate, to credit interest from January 1, 2002 to December 31, 2002 instead of 5.48%, the 

August, 2001, 30-Year Treasury Rate. There is an e-mail, dated October 11, 2002, from James 

Petrie of Delphi to Watson Wyatt (Image Viewer Doc. #403732246) that acknowledges that the 

5.61 % rate was contrary to plan provisions but instructs Watson Wyatt to use the 5.61 % rate 

because Delphi felt compelled to honor the Delphi written statements sent to participants that stated 

that the interest rate for 2002 would be 5.61 %. The effect on cash balances as a result of this 

decision is not significant. For example, the difference in interest earned for the year 2002 on a 

$1,000 cash balance as of December 31, 2001, would be an increase of$ I .30. We did not change 

the plan administrator's calculation. The 30-Year Treasury Rates used to credit interest to cash 

balance accounts up to the benefit freeze date are shown below. 

30-Year Treasury Securities 

Rate 

Cash Balance Accumulation 

07/2001, 5.61% Interest Applied to Cash Balance on 12/31/2001, plus Pay Credits for the 2002 

Calendar Year (without interest), to detennine Cash Balance on 12/31/2002 

08/2002, 5.08% Interest Applied to Cash Balance on 12/31/2002, plus Pay Credits for the 

01/01/2003 to 09/30/2003 Partial Calendar Year (without interest), to determine 

Cash Balance on 09/30(2003 

07/2003, 4.93% Interest Applied to Cash Balance on 09/30/2003, plus Pay Credits for the 

10/01/2093 to 09/30/2004 Plan Year (without interest), to determine Cash Balance 

on 9/30/2004 

07/2004, 5.22% Interest Applied to Cash Balance on 09/30/2004, plus Pay Credits for the 

10/01/2004 to 09/30/2005 Plan Year (without interest), to determine Cash Balance 

on 09/30/2005 

07/2005, 4.4 l % Interest Applied to Cash Balance on 09/30/2005, plus Pay Credits for the 

10/0 l/2005 to 09/30/2006 Plan Year (without interest), to determine Cash Balance 

on 09/30/2006 

07/2006, 5.13% Interest Applied to Cash Balance on 09/30/2006, plus Pay Credits for the 

l 0/0 I /2006 to 09/30/2007 Plan Year (without interest), to determine Cash Balance 

on 09/30/2007 

07/2007, 5.l 1% Interest Applied to Cash Balance on 09/30/2007, plus Pay Credits for the 

10/01/2007 to 09/30/2008 Plan Year (without interest), to determine Cash Balance 

on 09/30/2008 

For the short 9-month cash balance period from January 1, 2003 through September 30, 2003, the 

plan administrator used simple interest to accumulate the December 31, 2002 cash balance to 

September 30, 2003. Likewise, we used the plan interest rate in effect for the last plan year that 

included DOPT ( 4.57%) and simple interest, for the accumulation of the cash balance at the benefit 

freeze date to DOPT (a partial plan year). 

According to the plan document effective October l, 2004, cash balance accounts are converted to a 

straight life annuity at the normal retirement date based on mortality described in Revenue Ruling 

2001-62 (Revenue Ruling 95-6 before October l, 2002) and "the annual interest rate on 30-year 

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Case Number: 2063 7000 

Treasury securities as specified by the Commissioner of the Internal Revenue Service for the third 

full month prior to the first day of the plan year preceding the determination date." The straight life 

annuity at the normal retirement date is converted to the annuity form at the date of retirement using 

plan actuarial equivalence (the same basis as stated above for conversion). 

Under the plan document effective January 1, 1999, the cash balance was accumulated to the date of 

retirement and converted to an annuity at the date ofretirement. Because the accumulation and 

conversion interest rates are the same, the immediate method under the plan document effective 

January 1, 1999 and the project method under the plan document effective October 1, 2004 are 

equivalent as long as pre-retirement mortality is not applied in the adjustment from the straight life 

annuity at the normal retirement date to the benefit at the date of retirement. The definition of 

actuarial value in the plan does not.reference pre-retirement mortality. We have two items in plan 

practice that support not using pre-retirement mortality for the cash balance early and late 

retirement factors: 1) we match within $5/5% tolerance the benefits in pay for all six Part C retirees 

using the immediate method (we are within $0.50 of the benefits in pay for five of the six Part C 

retirees) and 2) Delphi Salaried Programs Defined Benefit Plan Rules, page 132 (Image Viewer 

Doc. #400914215) describes the immediate method for the conversion ofthe cash balance to a 

monthly benefit. 

In the valuation, we used the project method to calculate cash balance benefits. We did not use preretirement mortality in calculating cash balance early and late retirement factors. 

Up until DOPT, Delphi used the 30-year Treasury securities rates and mortality described above in 

calculating Part C monthly benefits. 

We used the rates and mortality in the table below for the calculation of Part C benefits after DOPT. 

Part C Accumulation and Conversion Rates for Post-DOPT Benefit Calculations 

Part C Rate or Factor 

Description 

PBGC Rule Rate or Mortality Source Rate or Mortality 

Cash Balance 

Accumulation Interest Rate 

Arithmetic average of the 

interest crediting rates 

under the plan during an 

interest crediting period for 

which the interest crediting 

date was within 5 years of 

DOPT 

Average ofthe Annual 

Interest Rate on 30-Year 

Treasury Securities for 

07/2003, 07/2004, 07/2005, 

07/2006, 07/2007 

4.96% 

Plan Annuity Conversion 

Rates 

Interest: Arithmetic average 

of the interest rates that 

applied under the plan 

during periods for which 

the date of each rate change 

was within 5 years of 

DOPT 

Average of the Annual 

Interest Rate on 30-Year 

Treasury Securities for 

07/2004, 0712005, 07/2006, 

07 /2007. 07 /2008 

4.89% 

Mortality: Mortality in 

effect at DOPT 

Revenue Ruling 2001·62 1994 Group Annuity 

Reserving Table Mortality 

(50% male I 50% female, 

projected to 2002) 

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Case Number: 20637000 

Part C Accumulation and Conversion Rates for Post-DO PT Benefit Calculations 

Part C Rate or Factor 

Description 

PBGC Rule Rate or Mortality Source Rate or Mortality 

Plan Early/Late Retirement 

Factors 

Interest: Rate in effect at 

DOPT 

Annual Interest Rate on 30­

Year Treasury Securities 

for 07/01/2008 

4.57% 

Mortality: In Effect at 

DOPT 

Revenue Ruling 2001-62 1994 Group Annuity 

Reserving Table Mortality 

(50% male I 50% female, 

projected to 2002), no preretirement mortality 

Plan Benefit Form 

Conversion Factors 

Interest: Rate in effect at 

DOPT 

Annual Interest Rate on 30­

Year Treasury Securities 

for 07/0 l/2008 

4.57% 

Mortality: In Effect at 

DOPT 

Revenue Ruling 2001-62 1994 Group Annuity 

Reserving Table Mortality 

(50% male I 50% female, 

projected to 2002) 

Part A Plan Supplements 

There are three supplements associated with the Part A benefit provisions ofthe plan: Early 

Retirement, Interim, and Temporary. There are two general plan limitations applicable to the Early 

Retirement and Interim supplements. 

1. 	 The Part A basic benefit plus the Part B Supplementary benefit plus any Part A Early 

Retirement or Interim supplement cannot exceed 70% of the participant's final monthly base 

salary (highest monthly base salary rate during the last 60 months preceding the employee's 

last day of work) and 

2. 	The Part A Early Retirement or Interim supplement is reduced by the plan Part A Temporary 

supplement (even if the participant is not receiving a Temporary supplement) if the participant 

is eligible for Social Security Disability Insurance benefits. 

' 

Early Retirement Supplement 

The Early Retirement supplement is payable to participants with 30 years of eligibility service if the 

participant was hired before 1988 and has unbroken service (see Section 11, Benefit/Plan Document 

Interpretations ofNote, subsection C Length ofService Date). The Early Retirement supplement is 

payable until age 62 and one month (see Section 11, Benefit/Plan Document Interpretations ofNote, 

subsection B. Age 62 and One Month Date Calculation). The monthly amount of the Early 

Retirement supplement is an amount that, when added to the Part A Basic benefit and the Part B 

Supplementary benefit (prior to any reduction for spouse survivor coverage), raises the total of these 

benefits and the supplement to the Early Retirement Supplement Level. Ifthe participant is 

receiving Social Security Disability Insurance Benefits then the Early Retirement supplement is 

offset by the plan Temporary supplement (see Temporary Supplement below). 

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Case Number: 20637000 

Until October 1, 2002, Early Retirement Supplement Levels were determined using rolling rate 

periods similar to the rolling rate periods for benefit rates described above under Part A Benefits. 

The following two tables show the Early Retirement Supplement Levels for the two rolling rate 

periods associated with the plan after the GM spinoff: 

Table ofRolling Early Retirement Supplement Levels for Participants who Retired On and After 

October 1, 1996 and Prior to October 1, 1999 

Benefit Early Retirement Suoolernent Level ofTotal Payments for Benefit Payments Commencing 

Determination Date I 0/0 l I t 996 through 

09/01/1997 

l 0/01/1997 through 

09101/1998 

I0101I1998 through 

09/0\/1999 

I 010 II 1999 and after 

I010II1996 and prior 

to 10/0111999 

Unknown unknown unknown $2,385 (from prior Early 

Retirement Supplement 

Level of $2,295 + $90 

increase from 

Restatement effective 

January l, 1999) 

Table ofRolling Early Retirement Supplement Levels for Participants who Retired On and After 

October 1, 1999 and Prior to October l, 2003 

Benefit Early Retirement Supplement Level of Total Payments for Benefit Payments Commencing 

Detennination Date I010111999 through 

09101/2000 

I 0/0 t/2000 through 

0910112001 

I 0/0 l /200 l through 

09/01/2002 

10/01/2002 and after 

l 0/0 lll 999 and 

prior to l 0/0112003 

$2,380 $2,480 $2,600 $2,730 

After October l, 2003, the Salaried Retirement Program did not adopt any rolling rate periods for 

Early Retirement Supplement Levels. Early Retirement Supplement Levels for participants with a 

date of tennination of employment on or after October 1, 2003 are shovro in the following table: 

Table of Early Retirement Supplement Levels for participants who Retired on or after October 1, 

2003 

Benefit Determination Date Early Retirement Supplement Level ofTotal Payments for Benefit Payments 

Commencing 

I 0/0 i /2003 and prior to I 0/0 l/2004 $2,805 

I010 I /2004 and after $2,875 

Please see Section 11, Benefit/Plan Document Interpretations ofNote, subsection A. Benefit 

Changes Effective October 1, 2003, for more information regarding the adoption of the Early 

Retirement supplement level effective October 1, 2003. 

Interim Supplement 

The Interim supplement is payable only to participants who were hired before 1988 and did not 

break service after 1987 (see Section 11, Benefit/Plan Document Interpretations ofNote, subsection 

C. Length ofService Date). The participant must meet the following requirements: 

a. Attained age 55 while employed and age plus eligibility service total 85 or more, or 

b. Attained age 60 while employed with at least 10 years of eligibility service. 

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Case Number: 2063 7000 

The Interim supplement is payable until age 62 and one month (see Section 11, Benefit/Plan 

Document Interpretations ofNote, subsection B. Age 62 and One Month Date Calculation). The 

monthly amount of the Interim supplement is equal to Part A credited service multiplied by the 

benefit rate in the tables below, reduced by any Part B Supplementary benefit (prior to any 

reduction for spouse survivor coverage). Ifthe participant is receiving Social Security Disability 

Insurance Benefits then the Interim supplement is offset by the plan Temporary supplement (see 

Temporary Supplement below). 

Until October 1, 2002, Interim Supplement Benefit Rates were determined using rolling rate periods 

similar to the rolling rate periods for benefit rates described above under Part A Benefits. The 

following table shows the Interim Supplement Benefit Rates for the rolling rate period associated 

with the plan after the GM spinoff: 

Table of Rolling Interim Supplement Benefit Rates for Participants who Retired On and After 

October l, 1999 and Prior to October l, 2003 

Age at Retirement• Interim Supplement Benefit Rates for Benefit Payments Commencing 

1010 \/1999 through 

09/0l/2000 

I 0/0 l/2000 through 

09/01/2001 

I 0/0 I /200 I through 

09/01/2002 

I 0/0 I /2002 and 

after 

55 $17.10 $17.80 $18.65 $19.55 

56 $20.15 $2l.OO $22.00 $23.10 

57 $24.40 $25.40 $26.60 $27.90 

58 $28.55 $29.75 $31.15 $32.70 

59 $31.90 $33.20 $34.75 $36.50 

60 $36.90 $38.45 $40.25 $42.25 

•Prorated for intermediate ages computed on the basis of the number of complete calendar months by which the 

employee is under the age attained at the employee's next birthday 

After October l, 2003, the Salaried Retirement Program did not adopt any rolling rate periods for 

Interim Supplement Benefit Rates. Interim Supplement Benefit Rates for participants with a date of 

termination of employment on or after October l, 2003 are shown in the following table: 

Table of Interim Supplement Benefit Rates for Participants who Retired on or after October 1, 2003 

Age at Retirement* 

Benefits 

Payable 

Commencing 

55 56 57 58 59 60 

10/01/2003 

through 

09/01/2004 

$20.10 $23.75 $28.70 $33.65 $37.55 $43.45 

10/01/2004 

and after 

$20.70 $24.45 $29.50 $34.60 $38.60 $44.70 

*Prorated for intermediate ages computed on the basis of the number of complete calendar months by which the 

employee is under the age attained at the employee's next birthday 

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Case Number: 2063 7000 

Please see Section 11, Benefit/Plan Document Interpretations ofNote, subsection A. Benefit 

Changes Effective October I, 2003~ for more information regarding the adoption of the Interim 

supplement benefit rates effective October 1, 2003. 

Temporary Supplement 

The Temporary supplement is payable only to participants with 10 or more years of credited service 

who retire under the plan's total and permanent disability retirement provisions. The Temporary 

supplement is not payable to participants receiving Social Security Disability Insurance Benefits. 

The Temporary supplement is payable until age 62 and one month (see Section 11, Benefit/Plan 

Document Interpretations ofNote, subsection B. Age 62 and One Month Date Calculation). The 

monthly amount of the Temporary supplement is equal to Part A credited service (not greater than 

30 years) multiplied by the benefit rate in the following table: 

Retirement with Benefits Payable 

Commencing 

Benefit Rate Maximum Temporary Supplement 

10/011l998 and prior to 10/0I/1999 $38.65 $1,159.50 

10/01/1999 and prior to 10/01/2000 $38.85 $1,165.50 

I 0/0 I /2000 and prior to l 0/0 I /200 l $40.45 $1,213.50 

l 0/0 l/200 I and prior to l 0/0112002 $42.35 $1,270.50 

l 0/0 l /2002 and prior to l 0/0112003 $44.45 $1,333.50 

l 0/0 I /2003 and prior to I 010112004 $45.75 $1,372.50 

l 0/01/2004 or later $47.05 $1,4 l l.50 

Please see Section 11, Benefit/Plan Document Interpretations ofNote, subsection A. Benefit 

Changes Effective October I, 2003, for more information regarding the adoption of the Temporary 

supplement benefit rate effective October 1, 2003, 

Disability Benefits (Part A and Part B) 

Under the plan, a participant qualified for Total and Permanent Disability (T &PD) benefits if the 

participant was younger than age 65, earned 10 or more years of eligibility service, and was 

determined to be totally and permanently disabled by Delphi. The plan does not require that the 

participant be determined to be disabled by the Social Security Administration. The disability 

benefit payable was the participant's accrued benefit (adjusted for form of annuity but not for age). 

The plan paid an auxiliary disability benefit until the participant attained age 55. Upon reaching age 

55, the temporary disability benefit ends and the participant elects his retirement benefit. There are 

60 disabled participants who will each need to elect a benefit upon reaching age 55 (see Appendix E 

and Appendix F for lists of 49 pre-DO PT and 11 post-DO PT disabled retirees, respectively). Please 

see Section 10, Forms ofAnnuity, subsection, Part A and Part B Disability Auxiliary Benefit Form 

ofAnnuity and Section 11, Benefit/Plan Document Interpretations ofNote, subsection Q. Auxiliary 

Disability Benefit, for further discussion regarding disability benefits. 

John DeMarco, the former Delphi Director of Pension and Welfare Benefits, informed PBGC that 

T &PD participants with employee contributions were given the opportunity to withdraw employee 

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contributions at their initial benefit commencement date. Thereafter, T &PD participants are not 

allowed to withdraw employee contributions (see Image Viewer Doc. #403 778567). 

Disability Benefits (Part C) 

The plan has no disability provision for Part C participants. 

Benefit Provisions Pertaining to Divestitures 

Various GM/Delphi divestitures (spin-offs of company business units) affect employees' benefits. 

The most important of these were divestitures from GM that occurred before 1999. The most 

common service rules for a divestiture are that credited service stops at the divestiture sale date but 

that eligibility service continues until the participant stops working for the divested unit. For most 

of the divestitures the participant never was employed at Delphi because the divested participant's 

employment was entirely with GM prior to the divestiture and in the divested unit after the 

divestiture date. 

Listed below are conditions that are applicable across most, but not all, divestitures. Delphi 

Divestitures Defined Benefit Plan Rules (Image Viewer Doc. #400913994) contains the provisions 

applicable to each divestiture. 

1. 	 Employees who are not vested at the time of sale become the total responsibility of the divested 

company. 

2. Before employees who are part of a divestiture are allowed to commence benefits, they must 

first terminate from the successor company. This requirement is documented in the 

"Coordination of Benefits" agreement between the divested unit and GM/Delphi. 

3. 	Ifthe employee has made Part B employee contributions under the Salaried Retirement 


Program and is non-vested at the date of sale, then those Part B contributions made by the 


employee remain at Delphi and are still available for an in-service withdrawal. 


4. 	For certain divestitures, retirement protection is provided in the form of a 3% annual increase 

(not compounded) in the 5-year average monthly base salary. In order for salaried participants 

to receive the 3% increase in their 5-year monthly average as of the sale date, the participants 

must not withdraw their Part B contributions. The 3% salary increase is discontinued after the 

plan freeze date, September 30, 2008. 

5. 	A salaried employee who is transferred as part of a divestiture does not accrue Part B credited 

service while working for the divested company. 

6. 	Employees who separate from the divested company as a terminated vested participant receive 

benefit rates in effect at the break-in-service from the divested company. 

7. 	To be eligible for the Early Retirement and Interim supplements, the employee must commence 

these benefits within 5 years of a break-in-service from the divested unit. These supplements 

are prorated based on Delphi service and total service. 

8. 	Delphi, not GM, has responsibility for the pension payments to salaried employees who 

remained at the sold unit if GM retained the pension assets and subsequently transferred said 

assets to Delphi effective January I, 1999, at the time of the spin-off. 

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Case Number: 20637000 

9. 	In all cases, except where explicitly mentioned, the term "Delphi credited service" refers to all 

credited service that was accrued while the Participant was an employee of GM prior to 

January I, 1999 and prior to the transition to the divested unit. Effective January 1, 1999, 

credited service and pension assets for salaried employees were transferred from GM to Delphi. 

At that moment, all prior GM credited service became Delphi credited service. 

Listed below are the main divestitures recognized by Delphi that affect salaried employees and the 

divestiture sale date. 

Name of Divested Unit Date of Coordination of Retirement Protection 

Sale Benefits 

Agreement with 

Delphi 

American Axle & 03/01/1994 Yes Yes ­ 3% average monthly base salary increase 

Manufacturing lnc. per year until age 60 

Chassis Components Inc. 09101/1998 Yes Yes ­ 3% average monthly base salary increase 

per year until termination from divested unit 

Dayton-Phoenix Group 10/31/1992 No No 

Delco Remy America Inc. 08101/1994 Yes Yes ­ 3% average monthly base salary increase 

per year until termination from divested unit 

Diesel Technology Corporation 01/01/1988 No No 

Electronic Data Systems 0110 l/1985 No No 

Guide Corporation I \/01/1998 Yes Yes- 3% average monthly base salary increase 

per year until termination from divested unit 

lnteva Products Solution 02/29/2008 Yes No 

ITT Automotive Electrical 0410 I /l 994 Yes Yes ­ 3% average monthly base salary increase 

Systems Inc. I Valeo per year until age 65 

Lear Seating 0910 l/1998 Yes Yes ­ 3% average monthly base salary increase 

per year until termination from divested unit 

Magnequench International 10/01/1995 Yes Yes ­ 3% average monthly base salary increase 

per year until termination from divested unit 

New Venture Gear 04/01/1990 No No 

Peregrine U.S. 01101/1997 Yes Yes ­ 3% average monthly base salary increase 

per year until termination from divested unit 

Pinkerton 08101/1993 No No 

Tau Laboratories 12/3111984 No No 

Thomson Industries 04/30/1987 No No 

Benefits ofEmployees ofHughes Electronics Corporation 

There are 118 participants who are former employees of Hughes Electronics Corporation (Hughes). 

See Appendix G for a list of these participants. Although Delphi coded former employees of 

Hughes in the plan data as divested participants, Hughes was not a divested company by GM or 

Delphi. GM bought Hughes in 1985. Hughes employees were covered under an existing Hughes 

retirement plan. GM and Hughes established transfer procedures that covered benefits of employees 

who transferred from Hughes to GM after 1985 (Image Viewer Docs. #401772724 and 

#401772726). An example of the letter participants received from Del hi re ardin their Hughes 

and Delphi benefits is Image Viewer Doc. #220060229 for These 

transfer procedures remained in place for former Hughes employees who became Delphi employees 

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as a result of the GM/Delphi spinoff on January 1, 1999 (see the April 22, 2008 e-mail of Brian 

Studer, Delphi Manager of Employee Benefits, Image Viewer Doc. #403938459). These procedures 

are as follows: 

1. 	 Combined Hughes and GM/Delphi service is used to determine retirement eligibility under the 

Delphi and Hughes plans. 

2. Under the Delphi plan, eligibility for Early Retirement or Interim Supplements is based solely 

on GM/Delphi service. 

3. 	Delphi credited service for the calculation of Delphi benefits is calculated from date of transfer 

to GM to date of termination from Delphi and, for Hughes benefits, from the date of hire at 

Hughes to the date of transfer to GM. 

4. 	The last 5 years of compensation at the final employing company is used to calculate retirement 

benefits under both plans. 

6. Normal, Early, and Late Retirement Dates 

Normal Retirement (Part A, Part B, and Part C) 

The Normal Retirement Date defined in the plan documents (General Provisions, Section 1 (t)) is 

the later of age 65 and 5'11 anniversary of participation. However, numerous sections in the plan 

describe normal retirement benefits beginning "at age 65." For example, see the following sections 

of the plan: Eligibility for Retirement Section 2; Part A, Section l(a); and Part B, Section 2(a). Page 

2 7 of Delphi Salaried Programs Defined Benefit Plan Rules (Image Viewer Doc. #400914215) 

states the following: ''The fifth anniversary of participation requirement is ignored administratively 

by Delphi because of conflicts with other sections of the Delphi Plan Document. Therefore, the 

administrative practice will be that Normal Retirement Age is age 65." 

We accepted the plan practice described above and made the Normal Retirement Date the first day 

of the month coincident with or next following the participant's 651

h birthday. 

Early Unreduced Retirement (Part A and Part B) 

The plan offered early unreduced retirement under any of the following conditions for Part A and B 

benefits: 

a. 	 85-Point Retirement Type: The early unreduced date is on the first day of the month 

coincident with or next following the participant's age 62 birthday ifthe participant attained 

age 55 while employed, was hired before 1988 with unbroken service (see Section 11, 

Benefit/Plan Document Interpretations ofNote, subsection C. Length ofService Date), and 

the sum ofthe participant's age and years of eligibility service equal at least 85. Subsidized 

early retirement factors are applied to Part A and Part B benefits for retirement on or after 

age 55 and before age 62. The reduction to the Part A benefit for early retirement that occurs 

before age 62 is removed starting with the payment at age 62 and one month (see Section 

11, Benefit/Plan Document Interpretations ofNote, subsection B. Age 62 and One Month 

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Date Calculation). The reduction to Part B benefits for early retirement that occurs before 

age 62 is never removed. 

b. 	 30-Year Retirement Type: The early unreduced date is on the first day of the month 

coincident with or next following the participant's age 62 birthday if the participant accrued 

30 years of eligibility service and was hired before 1988 with unbroken service (see Section 

11, Benefit/Plan Document Interpretations ofNote, subsection C. Length ofService Date). 

Subsidized early retirement factors are applied to Part A and Part B benefits for retirement 

before age 62. The reduction to the Part A benefit for early retirement that occurs before age 

62 is removed starting with the payment at age 62 and one month (see Section 11, 

Benefit/Plan Document Interpretations ofNote, subsection B. Age 62 and One Month Date 

Calculation). The reduction to Part B benefits for early retirement that occurs before age 62 

is never removed. 

c. 	 60/10 Retirement Type: The early unreduced date is on the first day of the month coincident 

with or next following the participant's age 62 birthday if the participant attained age 60 

while employed with I 0 years of eligibility service. Subsidized early retirement factors are 

applied for retirement on or after 60 and before age 62. The reduction to Part A and Part B 

benefits for early retirement that occurs before age 62 is never removed. 

d. 	 Career Transition Program: The early unreduced date is on the first day of the month 

coincident with or next following the participant's age 60 birthday if the participant accrued 

20 years of eligibility service. Deferred vested early retirement factors are applied from age 

65 for retirement before age 60 (retirement before age 55 under this retirement type is only 

applicable to retired participants as of DOPT, who retired under a Career Transition 

Program). 

Early Retirement (Part A and Part BJ 

In addition to the early unreduced retirement described above, the plan offered early retirement for 

Part A and Part B benefits to participants who attained age 55 while employed with 10 years of 

eligibility service (55/10 Retirement Type). Deferred vested participants with at least 5 years of 

eligibility service could retire at any age. The plan provided different early retirement factors for 

55110 versus deferred vested retirement. Because the plan also provided a consensual lump sum 

option upon separation ofservice for vested participants at any age, the Earliest PBGC Retirement 

Date (EPRD) for this plan is the date at which the participant is age 55. As a result, a participant 

who is vested in a benefit may be placed in pay status as early as the first of the month coincident 

with or next following the participant's 55th birthday. For participants eligible for the 30-Year 

Retirement Type, the EPRD is immediate (see Image Viewer Doc. #403732254 for ASD's approval 

of this EPRD). 

Early Retirement (Part CJ 

Participants were allowed to begin Part C benefits at any age after termination of employment. 

Because the plan provided a consensual lump sum option upon separation of service for vested 

participants at any age, the EPRD for Part C benefits in this plan is age 55. Therefore, a participant 

otherwise entitled to a benefit may be placed in pay status as early as the first of the month 

coincident with or next following the participant's 55th birthday. 

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Late Retirement (Part A and Part B) 

The monthly benefit for a participant who terminated employment prior to Normal Retirement Date 

and retired after Normal Retirement Date is equal to the accrued benefit at DOTE, increased from 

Normal Retirement Date to the actual retirement date using the plan's actuarial equivalence (1994 

Group Annuity Reserving Table Mortality, 50% Male I 50% Female, Projected to 2002, and 4.57% 

interest). 

Benefits were suspended for employees who worked beyond normal retirement. The monthly 

benefit for a participant who terminated employment and retired after Normal Retirement Date is 

equal to the accrued benefit at DOTE, increased from DOTE to the actual retirement date using the 

plan's actuarial equivalence (1994 Group Arumity Reserving Table Mortality, 50% Male I 50% 

Female, Projected to 2002, and 4.57% interest). 

Late Retirement (Part C) 

Benefits were suspended for employees who worked beyond normal retirement. Because Part C 

benefits are cash balance benefits, the monthly benefit for a participant who terminated employment 

and retired after Normal Retirement Date is equal to the larger of (a) the benefit attributed to the 

participant's account balance at the late retirement date with all applicable credits and (b) the 

benefit attributed to the cash balance at the later of the normal retirement date and the date of 

termination of employment, actuarially increased to the late retirement date. The actuarial 

equivalence for the late retirement increase is based on 1994 Group Annuity Reserving Table 

Mortality, 50% Male I 50% Female, Projected to 2002 (no pre-retirement mortality), and 4.57% 

interest. 

7. Vesting 

The plan provides a 5-year cliff vesting schedule for Part A and Part B benefits. The plan provides a 

3-year cliff vesting schedule for Part C benefits. Prior to October 1, 2008, a 5-year cliff schedule 

was in effect for participants in Part C. 

The 3-year cliff vesting schedule also applies to Part A and Part B benefits of participants who 

earned benefits under Part A and/or Part B and Part C. 

Service for the cliff requirement could be satisfied using plan defined Credited Service or the plan 

defined "ERISA" Service. Credited Service was computed based on completed months of service. 

A year of ERISA Service was earned in each 12-month period, beginning with the employee's date 

of hire or rehire, and, thereafter, each succeeding anniversary of the date of hire or rehire in which 

the employee completes 750 hours of service. 

Participants are 100% vested upon reaching normal retirement age while employed. 

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Participants are I 00% vested in the benefit attributable to employee contributions that have not been 

withdrawn. 

Benefit Freeze Immediate Vesting Provision 

Active employees on September 30, 2008 were made 100% vested. Effective September 30, 2008, 

employees who separated from service with less than 5 years of service as part of any divestiture 

that occurred between August 1, 2006 and September 30, 2008 were made l 00% vested. See 

Section 15, Phase-In Limitation, regarding the adoption of this provision while the plan was in 

bankruptcy and the phase-in of this provision. The only divestiture that meets the above criteria and 

affects salaried employees is the Inteva Products Solution divestiture that took place on February 

29, 2008. The immediate vesting provisions effective September 30, 2008 applied to all Part A, Part 

B, and Part C benefits. 

8. QPSA and other Pre-Retirement Death Benefits 

The plan provided a qualified pre-retirement survivor annuity (QPSA). The plan did not charge for 

QPSA coverage. The plan QPSA provisions are described below. 

Part A 

Part A Plan QPSA for Employees Age 55 with l 0 Years of Eligibility Service or Any Age with 30 


Years of Eligibility Service and Date of Hire Prior to January l, 1988 


The QPSA is the survivor portion of the plan normal married form of annuity, Joint & 65% 


Survivor annuity with a pop-up, payable on the first of the month following the participant's date of 


death. The surviving spouse is eligible for "'rolling rate" increases. 


Part A Plan Pre-Retirement Death Benefit for All Other Vested Participants 


The death benefit payable to the surviving spouse is 50% of the participant's unreduced Part A 


accrued benefit payable at the participant's age 65. The surviving spouse can begin payments, 


reduced for age, on the first of the month following the participant's date of death (prior to October 


1, 2004, the benefit is payable when the "employee would have become eligible to retire."). 


A QPSA must provide a survivor annuity at least as great as the survivor amount payable under the 


plan qualified Joint and Survivor annuity had the participant retired on the participant's earliest 


retirement age (ERISA Act Sec 205. (e)). The plan allowed participants to retire before age 55 and 


provided participants with 50% spouse coverage before age 55 (see Section I 0. Form ofAnnuity, 


subsection Part A and Part B Post-Retirement 50% Spouse Coverage for Retirement Payments 


before Age 55). Thus, in some cases (death and payment of pre-retirement surviving spouse benefit 


before age 55) this benefit meets the QPSA requirements of ERISA. However, in other cases this 


pre-retirement death benefit does not meet the QPSA requirements of ERISA. For example, the 


normal married form of annuity of a participant who attained age 55 with less than 10 years of 


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eligibility service is a Joint & 65% Survivor annuity with a pop-up. Ifthe participant were to die, 

the 50% pre-retirement survivor benefit would not meet the QPSA requirements of ERISA because 

the 65% survivor benefit from the normal married form of annuity at the date of death would be 

greater. PBGC asked the IRS for their opinion regarding the Delphi 50% pre-retirement death 

benefit. In a November 30, 2009 e-mail (Image Viewer Doc. #403732247) the IRS replied 

" ... we've looked at the issue you raise and agree with the analysis that, since the QJSA is a joint 

and 65% survivor annuity, the QPSA under the plan should be based on the 65% survivor annuity 

portion of the QJSA.'' For deferred vested participants, we provided a QPSA for all Part A 

participants equal to the survivor portion of the plan normal married form of annuity payable on the 

later of the participant's earliest retirement date and the first of the month following the 

participant's date of death. We changed the benefits of the nine beneficiaries in pay at DOPT in the 

table below who we determined were given a Part A pre-retirement death survivor annuity less than 

the survivor amount payable under the plan qualified Joint and survivor annuity had the participant 

retired at the participant's earliest retirement age of 55. 

No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Part B 

Part B Plan QPSA for Active Employees Participating in Part B at the Date of Death 

The QPSA is 65% of the participant's unreduced Part B accrued benefits payable on the first ofthe 

month following the participant's date of death. The 65% is increased by~% for each 12 months in 

excess of 5 years that the spouse's age exceeds the employee's age or decreased by ~%for each 12 

months in excess of 5 years that the spouse's age is younger than the employee's age. 

Part B Plan QPSA for Active Vested Participant not Participating in Part Band Age 55 with 10 

Years of Eligibility Service or Any Age with 30 Years of Eligibility Service and Date of Hire Prior 

to January 1. 1988 

The QPSA is the survivor portion of the plan normal married form of annuity, Joint & 65% survivor 

annuity, payable on the later of the participant's earliest retirement date and the first of the month 

following the participant's date of death. 

Part B Plan Pre-Retirement Death Benefit for All Other Vested Participants 

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The death benefit payable to the surviving spouse is 50% of the participant's unreduced Part B 

accrued benefits payable at the participant's age 65. The surviving spouse can begin payments 

reduced for age on the first of the month following the participant's date of death. 

For the same reasons as provided in this Section 8 under subsection Part A Plan Pre-Retirement 

Death Benefit for All Other Vested Participants, for deferred vested participants, we provided a 

QPSA for all Part B participants equal to the survivor portion of the plan normal married form of 

annuity, Joint & 65% survivor annuity, payable on the later of the participant's earliest retirement 

date and the first of the month following the participant's date of death. There were no beneficiaries 

receiving the Part B 50% pre-retirement death benefit. Therefore, no beneficiaries' Part B benefits 

were changed as a result of this decision. 

PartC 

Part C Plan QPSA for Vested Participant 

The surviving spouse has the option to l) receive a monthly benefit commencing on the first of the 

month following the participant's date of death equal to the actuarial value of the participant's 

account balance or 2) receive a lump sum equal to the participant's vested account balance. We 

valued the Part C lump sum death benefit in excess of the Part C QPSA monthly annuity benefit in 

PC6. 

Part C Death Benefit for Unmarried Vested Participant or Vested Participants Married Less than 

One Year at the Date of Death 

The pre-retirement death benefit is a lump sum equal to the participant's vested account balance 

payable to the participant's designated beneficiary or estate. We valued this Part C death benefit in 

PC6 for all deferred participants whose marital status was single at DOPT. We valued the plan 

QPSA benefit for all deferred participants whose marital status was unknown or married. 

9. Offsets to Plan Benefits 

The auditor did not identify any offsets for loans. 

The auditor determiped there were 2,375 participants who received lump sum distributions before 

DOPT. They are no longer considered participants in the plan and are not entitled to any benefit 

from PBGC. These participants are listed in the auditor's Participant Review Summary on PBGC's 

Archive Access System (PBGC file name 206370A8. zip). 

Pre-1999 Purchased Annuities by GM 

Prior to 1999, GM entered into group annuity contracts with three insurers: Prudential, Aetna, and 

MetLife (see Section 4, Plan Documents, subsection Insurance Company Purchased Annuity 

Contracts, for more information). The contracts covered purchased annuities for Part B Primary 

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Case Number: 20637000 

benefits for employee contributions made before 1985 for 6,552 participants and beneficiaries. 

Before DOPT, the Delphi pension plan continued to administer and make full pension payments to 

retirees and beneficiaries. The insurance companies reimbursed the Delphi pension plan monthly for 

the purchased annuity portion of the benefits paid by the pension plan. This practice continued after 

DOPT until June, 2013 when an agreement was reached between PBGC and the insurance 

companies for the insurance companies to make purchased annuity payments directly to participants 

(see Cmage Viewer Docs. #403779435 and #403779436). OGC and AED detennined that the 

purchased annuities are not assets of the pension plan and the liabilities covered by the purchased 

annuities are not plan liabilities at DOPT (see the OGC Memorandum dated January 26, 2015, 

Image Viewer Doc. #404497000). The plan benefits of any participant or beneficiary with a 

purchased annuity are offset by the purchased annuity benefit. Purchased annuities are offset from 

the guaranteed plan benefit. See the archive folder Purchased Annuities Va~ 

related to purchased annuities. See the benefit determination statement for ____... 

- as an example of a participant with a purchased annuity. 

Hughes Benefit Offset for Former Hughes Employees with Hughes Benefit Paid by Raytheon 

An unknown number of former Hughes employees who became Delphi employees had their 

Hughes retirement plan assets transferred to Raytheon as part of the asset sale of Hughes' defense 

business to Raytheon in 1997. Because these employees were no longer considered GM employees 

by Raytheon, when GM spun-off Delphi, Raytheon did not agree to continue the procedures 

described in Section 5. Plan Benefit Formula Summary, subsection BenefiJ ofEmployees ofHughes 

Electronics Corporation, for fonner Hughes employees as of May 28, 1999 (the date Delphi 

became independent from GM). As a result, Hughes plan benefits payable by Raytheon would not 

increase because of participant eligibility service and salary increases earned at Delphi after May 

28, 1999. 

Delphi agreed to an alternative benefit calculation for some participants for whom Hughes or a 

successor company ''does not provide a retirement benefit based on time worked at Hughes in 

accordance with the provisions of the GM-Hughes Transfer procedure." The alternative benefit 

calculation provided some replacement value for the Hughes benefits possibly lost due to 

Raytheon's decision not to follow the GM /Hughes transfer procedures (Image Viewer Docs. 

#401772724 and #401772726). The alternative benefit is calculated using combined Hughes and 

GM/Delphi service as credited service for calculating the Delphi benefit. This benefit is then offset 

by the Hughes benefit payable by Raytheon (not to include any Hughes benefits attributable to 

Hughes employee contributions). A Delphi participant eligible for the alternative calculation 

receives the larger ofthe benefit detennined under the alternative calculation and the benefit 

determined under the former method. The plan document restricts the alternative calculation to "an 

employee eligible to retire.'' We interpreted this to mean that only active employees who reach 

immediate retirement at the employee's date of termination of employment are eligible for the 

alternative benefit calculation. This interpretation was confirmed by Brian Studer, the Delphi 

Manager of Employee Benefits (see the December 21, 2010 e-mail from Brian Studer, Image 

Viewer Doc. #403938458). 

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We do not have a list of eligible participants with Hughes benefits payable from Raytheon. 

Therefore, we could not calculate the alternative benefit in the valuation. On the benefit 

determination statements of former Hughes employees, we inform eligible participants that the 

alternative benefit calculation is available if the participant can provide PBGC with benefit 

statements from Ra)1.heon showing the participant's employer-provided Hughes benefit at the 

chosen retirement date. See the benefit determination statement for for an 

example of a participant possibly eligible for the alternative calculation. The 20 deferred 

participants eligible for the alternative calculation, if their Hughes benefit is payable from 

Raytheon, are listed in Appendix J. 

and are the only two retirees in pay on 

DOPT known to have a benefit calculated using the alternative method. 

Foreign Benefit Offset 

The plan contained a benefit offset to Part A and Part B Supplementary benefits for any benefit 

payable to the participant by a foreign subsidiary. According to the plan, pension benefits are 

"reduced by an amount equivalent to the total of any monthly benefits (or lump sum payment) that 

could be payable to such employee under any other retirement plan to which the foreign subsidiary 

has contributed, excluding, however, any retirement benefits or portion purchased by employee 

contributions." John DeMarco, the former Delphi Director ofPension and Welfare Benefits, stated 

that foreign exchange rates published by Wall Street Journal were used for the conversion of foreign 

benefits into United States dollars (see Image Viewer Doc. #403779434). For deferred vested 

participants with foreign benefit offsets, we used the foreign currency rates from the Wall Street 

Journal as of July 31, 2009 (DOPT). For retirees with foreign benefit offsets, we used the currency 

rates from the Wall Street Journal as of the date of retirement. 

There are 47 participants with foreign accrued benefits that are not from GM Canada (see Appendix 

K). We used the foreign pension data Delphi provided to PBGC to calculate the foreign pension 

offset. We did not have any foreign pension plan provisions in regard to these benefits. Ifwe had no 

information regarding the retirement age associated with the foreign accrued benefit, we assumed it 

was age 65. See the benefit determination statement for as an 

example of a participant with a foreign service offset. 

Canadian Foreign Benefit Offset 

There are 22 participants who also were participants in the GM Canada Salaried plan (see Appendix 

L). The plan document does not contain specific provisions regarding participants who earned a 

benefit from GM Canada. We found letters from GM to participants stating that when these 

participants retired, GM Canada would forward to GM the participant's Canadian benefit amount 

for the purposes of offsetting the participant's United States benefit. There is also a January 29, 

1998 GM memorandum describing the above offset procedure that states that transfers before 

January 1, 1992 would receive a benefit as though the participant's entire career had been in the 

United States. Both the letter and the memorandum are found in Image Viewer Doc. #401844711. 

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Of the 22 participants in the GM Canada Salaried plan, GM Canada provided PBGC with data for 

18 participants. According to this data, five of these participants were not eligible for a benefit from 

GM Canada and 13 were due a benefit from the GM Canada Salaried plan. The data GM Canada 

provided for these participants is in each participant's Image Viewer file and contained in the Leo 

database. We obtained the Canada salaried benefits for the remaining four participants from the GM 

Canada benefit statements we found on Image Viewer. 

The GM Canada pension includes the following benefits: 

a. 1 % Basic Benefit, 

b. 1 % Excess Benefit, 

c. 0. 75% Benefit, 

d. Supplementary Benefit, and 

e. Special Allowance Benefit 

GM US confirmed that because the 0. 75% benefit is based on employee contributions, it should not 

be included when offsetting Delphi benefits by GM Canada benefits. The Supplementary Benefit 

and Special Allowance Benefit are GM Canada supplements payable to age 65. The plan document 

does not describe how to offset temporary GM Canada supplements from Delphi benefits. In the 

valuation we offset Delphi supplements by any supplement payable from GM Canada. GM US 

confirmed that this was the correct application of the foreign offset for the supplements. See Image 

Viewer Doc. #404544337 for the e-mail documenting the discussions with GM US. 

GM Canada participants could retire with an unreduced benefit as early as age 60. According to 

information from GM Canada the age 60 unreduced benefit was provided to GM Canada 

participants with 30-Year or 85-Point Retirement Types as of the participant's date of termination 

from Delphi. GM Canada provided PBGC with early retirement reduction factors associated with 

GM Canada benefits (see Image Viewer Doc. #404258413). We used this information to calculate 

the offset to Delphi benefits from the 1 % Basic Benefit and 1 % Excess Benefit at the participant's 

retirement date from Delphi. 

There were three Delphi retirees with GM Canadian service whose Delphi benefits had not been 

, and 

. These retirees transferred to the United States after January 1, 1992. 

We match these participants' benefits exactly if we do not offset their benefits by their GM Canada 

benefits. received a lump sum of $351,991.77 (Canadian Dollars) and 

offset by their GM Canada benefit: 

received a lump sum of $433, 168.35 (Canadian Dollars) from GM Canada. Although we do not 

have the Delphi plan administrator's benefit calculation for these retirees, we changed the benefits 

of these three retirees because it is clear their benefits had not been offset by their GM Canada 

benefits (see Section 19. Pre-DOPT Retiree Benefit Changes I Pre-Termination Plan Liability). 

was the only other Delphi retiree with GM Canada service. He retired 

on February 1, 2000, over 9 years before DOPT. We offset his benefit for the GM Canada benefit 

we found on his GM Canada benefit statement (Image Viewer Doc. #403185167). We were unable 

to match his benefit in pay. Our calculated benefits were larger than his benefits in pay. Unlike the 

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three retirees described in the prior paragraph we do not match his benefit when we do not offset his 

benefit by his GM Canada benefits. Delphi plan administrators were unable to completely explain 

how his benefit was calculated but there is evidence they were aware of his GM Canada benefit and 

attempted to apply the foreign offset (Image Viewer Docs. #221118573, #221118574, and 

#222610245). We accepted his benefit in pay because we could not demonstrate that his benefit had 

not been offset for his GM Canada benefit. 

Monthly Workers' Compensation Offset 

Workers' compensation benefits are offset from Delphi Part A, Part B Supplementary, and Part C 

benefits but not Part B Primary benefits. The four participants listed below were being paid 

workers' compensation benefits by the State of Michigan. 

No. 

2 

3 

4 

Month! Workers' Com ensation Offset 

$1,536.08 

$1,436.59 

$2,783.73 

$2,647.67 

State of Michigan Delphi workers' compensation benefits were discontinued sometime after DOPT. 

The March 19, 2010 memorandum from OCC (Image Viewer Doc. #403732248) recommends that 

PBGC not offset State of Michigan workers' compensation benefits unless the worker's 

compensation benefit is actually being paid to the participant. Delphi workers' compensation 

benefits have since been reinstated by the State of Michigan, and we assume participants have been 

paid for any missed payments. In the valuation, these participants' Delphi benefits were offset by 

their reported workers' compensation benefits. 

10. Forms of Annui!}'. 

Valuation Forms ofAnnuity 

Part A Benefits 

The automatic form of annuity for Part A benefits for an unmarried participant is a Straight Life 

Annuity (SLA); the automatic form of annuity for a married participant is a Joint & 65% Survivor 

annuity (J&65%S) with a pop-up ifthe spouse predeceases the participant. If a participant is 

married less than one year at the benefit commencement date, the surviving spouse coverage begins 

on the one-year anniversary of marriage date. When data were unavailable, we assumed that 

participants were married with females ( 1) 4 years younger than their male spouses for valuation 

purposes and (2) the same age for lump sum benefit payment purposes. Please see Section 13, 

Accrued-at-Normal Limitation, regarding the effect of the accrued-at-normal limitation on the Part 

A normal married form of annuity benefit pop-up upon the death of a spouse. Please see Section 11, 

Benefit /Plan Document Interpretations ofNote, subsection L. Change ofForm ofAnnuity Elections 

by Participants after Retirement, regarding the plan provisions allowing participants to change 

annuity form elections after the benefit commencement date. 

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Part B Benefits 

The automatic form of annuity for Part B benefits for an unmarried participant is a SLA; the 

automatic form of annuity for a married participant is a Joint & 65% Survivor Annuity (J&65%S). 

If a participant is married less than one year at the benefit commencement date, the surviving 

spouse coverage begins on the one-year anniversary of marriage date. When data were unavailable, 

we assumed that participants were married with females (1) 4 years younger than their male spouses 

for valuation purposes and (2) the same age for lump sum benefit payment purposes. Please see 

Section 11, Benefit /Plan Document Interpretations ofNote, subsection K. Joint and Survivor Form 

ofAnnuity without Pop-Up for Part B Benefits, regarding not providing a pop-up benefit to the Part 

B J&65%S form of annuity. Please see Section 11, Benefit /Plan Document Interpretations ofNote. 

subsection L. Change ofForm ofAnnuity Elections by Participants after Retirement, regarding the 

plan provisions allowing participants to change annuity form elections after the benefit 

commencement date. 

The Part B Primary forms of annuity for participants who do not withdraw their employee 

contributions contain a modified cash refund. 

The cash refund is the greater of (1) and (2), where 

1. The total of (a) 125% of employee contributions without interest made prior to July 1, 1971 (or, 

if greater, 30 times the monthly Part B Primary benefit accrued prior to July 1, 1971), plus (b) 

125% of employee contributions without interest made on or after July l, 1971 (or, if greater, 

employee contributions made on or after July l, 1971 with interest to the date of retirement), 

and 

2. the employee contributions with interest to the date of retirement, 

less the sum of all benefit payments made to the participant and beneficiary before the payments 

ceased as a result of death. 

For most participants with a Part B modified cash refund the modified cash refund is based on the 

employee contributions with interest to the date ofretirement. There were 53 retirees and two 

beneficiaries with a modified cash refund at DOPT for whom their modified cash refund is based on 

the 125% of employee contributions without interest amount. There were two deferred participants 

for whom their modified cash refund is based on the 125% of employee contributions without 

interest amount at their expected retirement date. For these deferred participants at later dates of 

retirement after the expected retirement date the modified cash refund may be based on the 

employee contributions with interest to the date of retirement, if it is greater than the t25% of 

employee contributions without interest amount. Please see Appendix AR for a list of these 57 

participants. 

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Part A and Part B Post-Retirement 50% Spouse Coverage for Retirement Payments before Age 55 

If a participant under age 55 retired with less than 30 years of eligibility service, the plan provided 

post-retirement surviving spouse coverage up to age 55. Under this coverage, if the participant died 

before age 55, the surviving spouse received 50% of the participant's benefit in pay for life. There 

was no cost for this coverage. In plan practice (see page 223 of Delphi Salaried Programs Defined 

Benefit Plan Rules, Image Viewer Doc. #400914215), at age 55, the participant's benefit was 

converted to the plan normal form of annuity. This coverage should not be confused with the plan 

Part A disability benefit coverage before age 55 (see the subsection Part A and Part B Disability 

Auxiliary Benefit Form ofAnnuity below). This form is not available to participants who retire after 

DOPT because of PBGC's EPRD rules (see Section 6, Normal, Early and Late Retirement). There 

were seven non-disabled retirees under age 55 at DOPT and two retirees on August l, 2009, before 

DOTR, with this form of annuity (see the subsection Future Benefit Changes below). 

Part A and Part B Disability Auxiliary Benefit Form ofAnnuity 

Under the plan, if a married participant qualified for Part AT&PD benefits and was younger than 

age 55, then the plan automatically assigned Joint and Survivor Coverage for Disability up to age 55 

unless the participant and spouse waived the coverage. Under the coverage, upon the death of the 

participant prior to the attainment of age 55, the surviving spouse would receive a benefit for life 

equal to 50% of the Part A amount in pay beginning at the participant's age 55. Benefits were 

reduced for this coverage. Part B T &PD benefits before age 55 were covered by the plan preretirement survivor coverage. 

At age 55, Part AT&PD benefits were automatically changed to the normal married 65% surviving 

spouse coverage annuity benefits unless the participant and spouse waived the coverage. At age 55, 

Part B T &PD benefits were converted to the form of annuity elected by the participant. There were 

49 T &PD retirees (see Appendix E) who were younger than age 55 at DOPT. We noted that one of 

these retirees had a Part A benefit in the J &65%S form of annuity and 11 of these retirees had Part 

B benefits in a Joint and Survivor annuity form of annuity, contrary to the pre-age 55 T&PD 

provisions ofthe plan described above. We do not know the reason why the plan administrator 

allowed these participants to choose a Joint and Survivor form of annuity before age 55. In the 

valuation we did not change these retirees' forms of annuity. 

Part C Benefits 

The automatic form of annuity for Part C benefits for an unmarried participant is a SLA; the 

automatic form of annuity for a married participant is a Joint & 100% Survivor Annuity 

(J&l00%S). When data were unavailable, we assumed that participants were married with females 

(a) 4 years younger than their male spouses for valuation purposes and (b) the same age for lump 

sum benefit payment purposes. 

The Part C forms of annuity contain a modified cash refund for participants who die and the total of 

the benefit payments before death is not greater than the cash balance account at the date of 

retirement. In plan practice the actuarial equivalent annuity conversion factor calculation ignored 

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the modified cash refund period (see page 132 of Delphi Salaried Programs Defined Benefit Plan 

Rules, Image Viewer Doc. #400914215). We did the same in the valuation. 

Plan Optional Forms ofAnnuity 

There are no participants who elected a plan optional form of annuity after DOPT but prior to 

DOTR. 

There were two participants, and 

who retired on August 1, 2009 who were younger than age 55 and did not have 30 years of 

eligibility service. They received the coverage described above under subsection Part A and Part B 

Post-Retirement 50% Spouse Coverage for Retirement Payments before Age 55. 

Future Benefit Changes 

A. Regular Benefits 

There are 3,897 participants (3,278 pre-DOPT retirees, 619 post-DOPT retirees) in pay who are 

receiving an Early Retirement or Interim supplement and/or who are entitled to the Part A benefit 

adjustment at age 62 and one month and will require a future benefit change. Please see Appendix 

M (pre-DOPT retirees) and Appendix N (post-DO PT retirees) for lists of these participants. 

B. Disability Benefits 

Under the plan provisions, participants who retired before age 55 with an auxiliary disability benefit 

are required to select a final form of annuity at age 55. See Section 5, Plan Benefit Formula 

Summary, for a description of the plan disability benefit. There are 60 participants (49 pre-DO PT 

retirees, 11 post-DOPT retirees) in pay who are required to select a form of annuity at age 55. See 

Appendix E (pre-DOPT disabled retirees) and Appendix F (post-DOPT disabled retirees) for lists of 

these participants. 

There are 17 T &PD participants (11 pre-DO PT retirees, 6 post-DOPT retirees) who are receiving a 

Temporary supplement and will require a future benefit change at age 62 and one month when the 

supplement ends. Please see Appendix 0 (pre-DOPT retirees) and Appendix P (post-DOPT retirees) 

for lists of these participants. 

C. 50% Spouse Coverage for Non-Disability Retirement before Age 55 

There were nine non-disabled participants under age 55 at their date of retirement who received the 

50% Spouse Coverage for Payments before Age 55 described above. These participants are required 

to select a final form of annuity at age 55, if they have not already done so. These nine retirees are 

listed in the table below. 

No. Participant Name Date of 

Retirement 

03/01/2009 

Age 55 Comment 

Retirement Date 

04/01/2016 Not et a e 55 

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Case Number: 20637000 

No. Participant Name Date of Age 55 Comment 

Retirement Retirement Date 

2 0 I /O t/2009 0510[/2012 Chose PBGC J&l00%S 

form at a e 55 

3 04/01/2009 05/01/2009 Chose Plan SLA form at 

4 03/01/2009 0710112019 

5 02/01/2009 03/01/2020 

6 03/01/2009 12/0112009 

form at a e 55 

7 08/01/2009 12/01/2009 Chose PBGC J&50%S 

8 08/01/2009 11/01/2011 

05/01/2009 04/01/2012 Participant has not elected 

his a e 55 form ofannui 

attained age 55 prior to DOPT but did not elect a final form of annuity at age 55 until after DOPT. 

11. Benefit I Plan Document Interpretations of Note 

A. Benefit Changes Effective October 1, 2003 

Delphi Salaried Programs Defined Benefit Plan Rules (Image Viewer Doc. #400914215) describe 

benefit changes effective October I, 2003 for Part A benefit rates, Early Retirement supplements, 

Interim supplements, Temporary supplements, and the Part B Supplementary compensation level. 

These changes are not mentioned in the two plan document restatements. They are mentioned as 

proposed changes for committee approval in the November 10, 2003 Delphi Employee Benefit 

Plans Committee memorandum Benefit Modifications Covering US. Salaried Employees (Image 

Viewer Doc. #403778532). In the May 21, 2004 Delphi Employee Benefit Plans Committee 

memorandum Benefit Modifications Covering US. Salaried Employees (Image Viewer Doc. 

#403778533), the October 1, 2003 changes are again listed (in conjunction with proposed October 

I, 2004 changes) and it is stated "In November 2003, the EBPC approved salaried pension increases 

effective October 1, 2003." We accepted the October 1, 2003 benefit increases as validly adopted 

by Delphi based on these documents. 

B. Age 62 and One Month Date Calculation 

The plan age 62 and one month date is the date at which plan benefit supplements (Temporary, 

Interim, or Early Retirement) cease and the Part A benefit is adjusted (for those eligible for the 85­

Point or 30-Year retirement types). The plan document does not define how this date is determined. 

Plan practice (see page 21 of Delphi Salaried Programs Defined Benefit Plan Rules, Image Viewer 

Doc. #400914215) calculated this date as the first of the month coincident with or next following 

the date the participant turns age 62 and one month, except that a participant born on the 2nd day of 

the month will be treated as if they were born on the 1

51 day of the month. We followed this plan 

practice in the valuation. 

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Note that a participant can receive a supplement payment after age 62. For example, a participant 

with 30 years of eligibility service who was born on January 15, 1960 has an age 62 and one month 

date of March 1, 2022. Ifthe participant retires before age 62, then the last early retirement 

supplement payment is on February 1, 2022. This participant's Part A benefit is adjusted to an 

unreduced (for age) amount beginning with the payment on March 1, 2022. 

Note also that a participant can retire on the age 62 early unreduced date and have a supplement 

payable on that date. For example, consider a participant with 30 years of eligibility service who 

was born on January 15, 1960 and who retires on February 1, 2022. The participant's age 62 and 

one month date is March 1, 2022. This participant receives a single early retirement supplement 

payment on February 1, 2022. This participant's Part A benefit would not be adjusted to an 

unreduced (for age) amount beginning with the payment on March I, 2022 because the benefit in 

pay would already be unreduced. 

C. Length ofService Date 

The plan defines Length of Service Date as "the date recognized under Delphi policy utilizing date 

of hire and periods of employment with the Corporation or its subsidiaries which are considered 

unbroken under Delphi Policies." 

Plan practice (see page 26 ofDelphi Salaried Programs Defined Benefit Plan Rules, Image Viewer 

Doc. #400914215) considered the Length of Service Date to be a participant's most recent date of 

hire (ignoring a service break with a date of rehire within 3 months of a date of termination of 

employment). Plan practice used this date in conjunction with the plan requirement that a 

participant be "hired before January 1, 1988" for 30-Year and 85-Point retirement type eligibility 

and Early and Interim supplement eligibility. Plan administrators interpreted this provision to refer 

to the most recent date of hire. Thus, a participant with an initial date of hire before 1988 who 

earned 30 years of service but quit and more than 3 months later was reemployed on a date after 

1987 would have a Length of Service Date at the rehire date after 1987. This participant would not 

be eligible for the 30-Year retirement type or Early Retirement supplement because the most recent 

date of hire was not before 1988. We followed this interpretation in the valuation. 

D. Age at Retirement Calculation for Early Retirement Adjustment Factor Determination 

Plan early retirement adjustment factors are based on age at date of retirement. Plan practice (see 

page 20 of Delphi Salaried Programs Defined Benefit Plan Rules, Image Viewer Doc. #400914215) 

calculated the age for determining the factors by subtracting the participant's date of birth from the 

date of retirement. 

The subtraction is done as follows: 

Date ofretirement expressed as MM DD YYYY, less 


Date of birth expressed as MM DD YYYY 


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Case Number: 20637000 

Days are made subtractable by borrowing from the months. Ifa month is borrowed, 30 days are 

added to the number of days, regardless of the actual calendar days within the given month. Once 

days are subtractable, months are made subtractable by borrowing from the years if needed. If a 

year is borrowed, 12 is added to the number of months. The resulting years are subtracted from one 

another and the months are subtracted from one another. Any remaining days are rounded up a 

month. Age, expressed as completed years and months, is rounded to four decimal places. 

We followed this plan practice in the valuation. As a result of this practice, a participant may 

receive an adjustment factor of 1.0000 on the date one month before the participant's early 

unreduced retirement date. 

For example, if a deferred vested participant born on January 15, 1960 has an early unreduced 

retirement date at normal retirement of February 1, 2025, then on January 1, 2025, one month 

before the normal retirement date, the participant's age is 64 years, 11 months, 16 days. The 

remaining days are rounded up a month and the age used for early retirement factor determination is 

65. Therefore, the early retirement factor one month before normal retirement on January 1, 2025, is 

1.0000. 

E. 	Post-DOPT Disability Benefit Eligibility 

As of DOPT, a group of 45 participants had not applied or re-applied for plan T&PD benefits. Many 

of these participants were receiving benefits from other Delphi plans (Sickness and Accident or 

Extended Disability Benefit plans). Under the plan, a participant qualified for T &PD benefits if the 

participant was younger than age 65 with 10 or more years of service and was determined to be 

totally and permanently disabled by Delphi. The plan does not require that the participant be 

determined to be disabled by the Social Security Administration. After DOPT, with OPSS's 

concurrence, PBGC sent letters to these participants informing them that in order to receive T &PD 

benefits, they would need to obtain approval from Delphi. PBGC advised Delphi to follow Delphi's 

usual disability application process. PBGC did not require these participants to commence T &PD 

benefits immediately if approved. In August of 2010, Delphi notified PBGC that they would cease 

making disability determinations as of September 30, 2010. After September 30, 2010, TPD 7 and 

OPSS agreed that the following criteria would be used by PBGC in determining if a participant was 

eligible for a post-DO PTT&PD disability retirement date. Please see the PBGC File Memorandum 

dated November 1, 20 I 0, [mage Viewer Doc. #225929828. The Memorandum includes an 

attachment that lists the 45 participants. Also please see the OCC e-mail regarding how PBGC 

should handle applications for T &PD benefits, Image Viewer Doc. #40452 I 930. 

a. 	 If a participant was determined by Social Security to be disabled before DOPT but never 


applied for T &PD benefits, then PBGC will allow the participant to receive T &PD benefits. 


b. 	If a participant was determined by Social Security to be disabled before DOPT but was denied 

T &PD benefits by Delphi and exhausted all company appeals, then PBGC will not allow the 

participant to receive T &PD benefits. 

c. 	If a participant was determined by Social Security to be disabled before DOPT and was denied 

T &PD benefits by Delphi but did not complete all stages of the Delphi appeal process as of 

DOPT, then PBGC will allow the participant to receive T&PD benefits. 

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In the valuation, there are 26 participants who were granted T &PD benefits by PBGC after DOPT. 

At the time the November 1, 2010 memorandum was Mitten, 19 participants had been approved for 

T &PD benefits. Seven additional participants were approved for T &PD benefits after November I, 

20 I 0. These participants are listed in the following table: 

No. 

2 


3 


4 


5 


6 


7 


8 


9 


10 


11 


12 


13 


14 


15 


16 


17 


18 


19 


20 


21 


22 


23 


24 


25 


26 


Date of Retirement 


10/01/2009 


12/01/2009 


04/0!/2012 


08/01/2010 


08/01/2009 


01/01/2012 


04/01/2012 


09/0 J/2009 


11/0 l /2009 


08/0112009 


09/0112009 


10/01/2009 


09101/2010 


03/01/2011 


02/0 l/2010 


l 0/0l/2010 

06/01/2013 

11/01/2009 

0610 l/20 l 0 

04/01/2012 

06/01/2011 

0410112012 

10/01/2009 

06101/2010 

T &PD participants who retired after DOPT but before age 55 were put into pay with their accrued 

benefits. PBGC did not provide these participants with the Part A 50% spouse coverage before age 

55 (see Image Viewer Doc. #403778566). Instead, PBGC decided that the Part A and Part B 

benefits were covered by the plan QPSA up until age 55 (see Section 8. QPSA and other Pre~ 

Retirement Death Benefits). At age 55, these participants are required to choose their retirement 

form of annuity. 

PBGC allowed post-DO PT T &PD participants with employee contributions to withdraw employee 

contributions up to their initial benefit commencement date. Thereafter, T &PD participants were 

not allowed to withdraw employee contributions (see Image Viewer Doc. #403778567). 

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F. Freeze ofCareer Transition 3%Average Salary Increase 

Under the plan freeze provisions, average base salary was frozen as ofthe freeze date, September 

30, 2008. The freeze provisions also state that the 3% annual increase (not compounded) to average 

base salary provided in many divestitures is also frozen as ofthe freeze date. The freeze provisions 

do not mention the effect ofthe freeze on the 3% increase to average base salary in Career 

Transition programs. Delphi did send a notification to participants, dated September 15, 2008, 

informing them that the 3% increase to average base salary in Career Transition programs would be 

frozen on September 30, 2008 (Image Viewer Doc. #401772732). In the valuation, we applied the 

freeze to the 3% average base salary increase of Career Transition program participants. 

G. Joint and Survivor Form ofAnnuity Change {J&650/oS to J&60%S) 

Effective October 1, 1999, the plan changed the normal married form of annuity for Part A and Part 

B benefits from a Joint and 60% Survivor (J&60%S) to a J&65%S form of annuity. The plan 

language did not contain reference to retirees in pay before October 1, 1999 with J&60%S 

annuities. The Delphi Hourly Plan (PBGC case number 20637100) provisions similarly changed the 

normal married form effective October 1, 1999 but also provided that hourly participants with Joint 

and survivor annuities, who retired between November I, 1976 and October 1, 1999, would receive 

a form of annuity "uplift" to the J&65%S annuity form. Although the salary plan provisions did not 

contain the language for this uplift, we found in the Delphi data some retirees who retired before 

October 1, 1999 and were listed with J&65%S annuities. There is a Delphi memorandum dated 

December 2, 1999 (Image Viewer Doc. #401844 713) noting Salaried Plan changes "consistent" 

with Hourly Plan changes. The memorandum does not list the form of annuity uplift. John 

DeMarco, the former Delphi Director of Pension and Welfare Benefits, informed us that the Delphi 

salary plan did not have the same retroactive uplift as the Hourly plan. He stated that he was not 

certain why retirees who retired before October l, 1999 had J&65%S annuities. We interpret the 

plan to provide the J&60%S form to participants who terminated employment before October 1, 

1999. We examined retirees who terminated employment before October 1, 1999 but were in pay 

with the J&65%S form of annuity. We changed the form of annuity for any retiree whose Image 

Viewer file contained a Delphi SRP 117 form of annuity election document that showed a J&60%S 

form of annuity from J&65%S to J&60%S. No monthly benefit amounts to participants were 

changed as a result of this decision because the plan annuity form conversion factors for J&65%S 

and J &60%S annuities are the same. The 28 retirees whose forms of annuity we changed are listed 

below. 

No. Participant Name Participant SSN Date of Termination of Employment Date of Retirement 

09/30/1999 I 0/01/1999 

2 0913011999 I 0/01/1999 

3 0913011999 10/01/1999 

4 09/30/1999 10/01/1999 

5 05/31/1999 06/01/1999 

6 08/3111999 09/01/l999 

7 04/30/1999 05101/1999 

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No. Participant Name Participant SSN Date of Termination of Employment Date of Retirement 

8 

9 

10 

II 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

06/30/1999 07/01/1999 

09/30/] 999 10/01/1999 

03/31/1999 04/01/1999 

0913011999 10/01/1999 

09/30/1999 10/01/1999 

09/30/1999 10/01/1999 

07/31/1999 08/01/1999 

05/31/1999 06/0\/1999 

09/30/1999 I 0/01/1999 

03/3 l/1999 04/01/1999 

09/30/1999 10/0\/1999 

09/30/1999 I 0/01/1999 

06/30/1999 07/01/1999 

12/23/1998 02/01/\999 

03/31/1999 04/01/1999 

07/31/1999 08/01/1999 

09/30/1999 10/01/1999 

12/31/1998 04/01/1999 

09/28/1999 10/01/1999 

09/30/1999 10/01/1999 

04/30/1999 0510111999 

H Withdrawal ofEmployee Contributions while Working 

The plan allowed employee contribution withdrawals while a participant was working and making 

contributions. Future Part B benefits calculated after the in-service withdrawal date were based on 

the employee contributions made and service earned after the withdrawal date. At the in-service 

withdrawal date, an "ERISA Minimum Benefit" was calculated equal to the participant's Part A and 

Part B accrued benefits as ofthe withdrawal date offset by the benefit attributabl~ee 

contributions withdravm. For example, see the GM withdrawal forms for retiree-­

(lmage Viewer Doc. #228574382, pages 19 and 20). He withdrew on two dates 

before his date of termination of employment. The GM forms show how the minimum benefit 

calculated on the first withdrawal date is incorporated in the minimum benefit calculated on the 

second withdrawal date. 

Printed at the bottom ofthe GM withdrawal forms is the following statement in regard to the 

calculated minimum benefit: "Payable only if your retirement benefit is not equal to or greater than 

this minimum benefit." PBGC asked GM if a participant could lose the Part B accrued benefits 

earned prior to the withdrawal date ifthe minimum benefit was less than the accrued benefits 

earned after the withdrawal date. In a memorandum to Jim Armbruster of OCC from GM (Image 

Viewer Doc. #403732249), dated September 13, 2012, GM stated that in-service withdrawal 

employees retain a benefit attributable to employer contributions. In reference to a calculation 

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example, GM stated the participant would receive the Part B benefits earned after the withdrawal 

date and "an ERISA minimum benefit attributable to employer contributions determined at the date 

of withdrawal." We interpreted this to mean that the accrued Part B benefits at the date of an inservice withdrawal less the benefit attributable to the employee contributions as of the withdrawal 

date (the employer provided Part B benefit) are always added to the employee's post withdrawal 

accruals when determining a participant's total accrued benefit. We believe this interpretation does 

not violate the anti-cutback rules of ERISA. 

We examined retirees who made in-service withdrawals and found that the plan administrators did 

not provide the minimum benefit as described above to 326 participants who made in-service 

withdrawals. For example, in the calculation for retiree , we matched 

the benefit in pay using only his post withdrawal Part B accrued benefits. His net Part B benefits 

prior to his second withdrawal date were not included in his retirement benefits. For 326 payees 

with in-service withdrawals in the valuation, we determined the net Part B benefits at the date(s) of 

withdrawal and added these benefits (adjusted for early/late retirement and form of annuity as 

applicable) to the retirees' benefits in pay. Please see Image Viewer Doc. #403829823 in regard to 

the discussion with ASD to increase retirees' benefits for their missing ERISA minimum benefits 

from in-service withdrawals. These retirees are included in the pre-termination liabilities described 

in Section 19. Pre-DOPT Retiree Benefit Changes I Pre-Termination Plan Liability. In the table 

below we show the breakdown of these payees according to those with and without GM withdrawal 

forms. 

Retirees and Beneficiaries with In-service Withdrawals Number 

Number without GM withdrawal forms. Valuation calculated benefits at the in-service withdrawal dates 

based on service and employee contributions at the in-service withdrawal dates. 

162 

Number with GM withdrawal forms. Valuation used Part B benefits printed on the GM forms as the Part 

B benefits as of the in-service withdrawal dates. 

164 

Total 326 

For the 125 non-retirees with in-service withdrawals in the valuation, we determined the net Part B 

benefits at the dates(s) of withdrawal and added these benefits (adjusted for early/late retirement 

and form of annuity as applicable) to the participants' benefits at the expected retirement date. In 

the table below we show the breakdown of these participants according to those with and without 

GM withdrawal forms. 

Non-Retirees with In-service Withdrawals Number 

Number without GM withdrawal forms. Valuation calculated benefits at the in-service withdrawal dates 

based on service and employee contributions at the in-service withdrawal dates. 

100 

Number with GM withdrawal forms. Valuation used Part 8 benefits printed on the GM forms as the Part 

B benefits as of the in-service withdrawal dates. 

25 

Total 125 

I. Incorrect Interest Rate for Post Withdrawal ofEmployee Contributions Accumulation 

We found that the GM in-service withdrawal forms used an incorrect interest rate to accumulate 

employee contributions after the withdrawal date to the normal retirement date for the purposes of 

determining the benefit attributable to employee contributions. After October l, 1988, GM used 

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interest equal to 120% of the Federal mid-term rates and a 10% annuity conversion factor to 

accumulate and convert employee contributions to an annuity at age 65. IRC section 

411 ( c )(2)(C)(iii) states that the interest rates for accumulating employee contributions before a 

withdrawal are 120% of the Federal mid-term rates and, after a withdrawal, are IRS section 

4 l 7(e)(3) rates. For example, withdrew his employee contributions 

on July 17, 1996. His GM withdrawal form (Image Viewer Doc. #229109715, page 11) shows that 

7 .59% interest was used to accumulate his employee contributions after his withdrawal date to his 

normal retirement date. However, 7.59% is not the IRS section 417(e)(3) rate as of the withdrawal 

date but is the 120% Federal mid-term rate in effect on October 1, 1995. Note that the GM forms 

agree with OBRA '87 legislation but not with the retroactive OBRA '89 legislation. Apparently, 

GM never updated their employee contribution withdrawal procedures for OBRA '89. Because of 

this error on the GM withdrawal forms, we did not use the benefit attributable to employee 

contributions at normal retirement date shown on line 20 ofthe GM withdrawal forms for 

employees who made in-service withdrawals after October 1, 1988. Instead, we calculated the 

amount using the interest rates and mortality required by law. 

J. Treatment ofWithdrawal ofEmployee Contributions after Benefit Freeze Date or Divestiture 

Date 

There are 15 deferred vested participants who withdrew their employee contributions after the 

benefit fre,eze date and before their dates of termination of employment (see Appendix Q). There 

are 13 participants (five retirees and eight deferred vesteds) who withdrew their employee 

contributions after the dates their Delphi units were divested and before their dates of termination of 

employment (see Appendix R). Although these participants withdrew their employee contributions 

before their DOTE, they withdrew after a date they could no longer make employee contributions or 

earn Part B credited service. We treated these withdrawals as out of service withdrawals, i.e., we 

calculated the total monthly benefit and offset the monthly benefit attributable to employee 

contributions as defined in ERISA. 

K. Joint and Survivor Form ofAnnuity without Pop-Up for Part B Benefits 

According to the plan, the Part B normal married form of annuity provides "surviving spouse 

coverage in accordance with the provisions of Part A, Article I, Section 5(a) through (g)." The Part 

A normal married form of annuity described in Section 5(a) through (g) is a J&65%S with pop-up. 

Plan practice shows that Delphi did not provide the pop-up feature to the Part B married form of 

annuity. Delphi participant annuity election forms explicitly state that the Part B form does not 

contain a pop-up (see Image Viewer Doc. #403776165, Page 11, for ••••••••• 

-). We accepted this interpretation of the plan because the pop-up feature ofthe Part A form of 

annuity provides a benefit to the participant, not the surviving spouse, i.e., it is not considered 

"surviving spouse coverage." See Section 14. Maximum Guaranteeable Benefit I Aggregate 

Maximum Benefit, subsection MGB for Participants wilh Part A and Part B Benefits, for the 

discussion regarding how the Maximum Guaranteeable Benefit was calculated for a participant's 

combined Part A and Part B benefits in Delphi. 

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L. 	Change ofForm ofAnnuity Elections by Participants after Retirement 

The plan contains provisions for retired participants to change their elected fonn of annuity after 

benefits commence under certain conditions. A retired participant who elected surviving spouse 

coverage for part A and Part B benefits may rescind the surviving spouse coverage after 

commencement of benefits under the following conditions: 

a. 	 if the designated spouse predeceases the participant, 

b. 	if the designated spouse signs a waiver of coverage and proof of the spouse's good health is 


provided, or 


c. 	if the participant and designated spouse are divorced and a QDRO provides that the spouse is 

not entitled to the survivor benefit from surviving spouse coverage. 

A retired participant who was single at retirement and later marries or who is married at retirement 

and later remarries (and rescinds any prior surviving spouse coverage) can elect surviving spouse 

benefit coverage for the new spouse within 18 months of marriage. This provision is only applicable 

to Part A benefits. The coverage is only available if the coverage had not been rejected for a 

previous spouse. 

We discussed with ASD, OCC, and OPSS the extent to which PBGC would allow a retired 

participant to make these form of annuity changes. It was decided that retirees in pay as of DOPT 

would not be allowed to make changes to the form of annuity in effect as of DOPT and that a postDOPT retiree may not change the fonn of annuity elected at the date of retirement. PBGC will 

honor any documented fonn of annuity change made before DOTR (see Image Viewer Doc. 

#403 778568). 

A number of pre-DOTR retirees notified PBGC that they changed their benefit annuity form based 

on Delphi's marriage/remarriage rules but that the benefit in pay as of DOTR did not reflect their 

decision. In some cases, PBGC was able to verify this through the participant's Delphi Retirement 

Annuity Election Fonn documents. In other cases, the retiree's annuity election documents were not 

available. PBGC decided to accept documentation that the retiree added the new spouse to Delphi 

health and life insurance plan coverage as evidence that the participant elected surviving spouse 

benefit coverage for their pension benefit (see Image Viewer Doc. #403 778568). 

M Salaried Retirement Incentive Window Treatment ofEarly Retirement Supplement 

The available documentation of the various Salaried Retirement Incentive retirement window 

programs comes from Delphi Employee Benefit Plans Committee memorandums. These 

memorandums do not describe the provisions in detail. In general the memorandums provide that 

factors from a special reduction table are applied to plan benefits. We determined from actual 

retiree calculations that the factors were also applied to Part A Temporary and Early Retirement 

supplements for a Salaried Retirement Incentive retiree with 30 years of service. For example, the 

Part A supplements of 	 were determined by Delphi as follows: 

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Window Temporary Supplement = Plan Temporary Supplement x Window Reduction Factor = 

$1,270.50 x 0.816 = $1,036.73 

Window Early Retirement Supplement = (Plan Early Retirement Supplement - Window 

Temporary Supplement) x Window Reduction Factor= ($1,353.08 - $1,036.73) x 0.816 = 

$258.14 

We asked Delphi plan administrators, John DeMarco, the former Delphi Director of Pension and 

Welfare Benefits, and Brian Studer, the Delphi Manager of Employee Benefits, in an e-mail dated 

December 11, 2009, if this was the method plan administrators used to calculate Early Retirement 

Supplements for Salaried Retirement Incentive Window benefits. John DeMarco confirmed that the 

above method was used by plan administrators (see Image Viewer Doc. #403732244). We followed 

this method in the valuation. 

N Average Monthly Base Salary 

Average Monthly Base Salary (AMBS) is defined in the plan as the monthly average of the 

employee's base salary for the highest 60 months ofthe 120 months immediately preceding the 

employee's date of termination of employment. The plan does not describe how to calculate AMBS 

in the case when the employee has less than 60 months of employment. 

In the valuation, there were 11 deferred participants with less than 60 months of employment. For 

these employees, we calculated AMBS by dividing the total monthly compensation received by the 

participant by the number of months of compensation. 

0. Post 1999 GM Service and Eligibility Service for Peregrine Divestiture 

and 

- were Peregrine divested employees. All three left employment at Peregrine to work for GM 

in 1999 and continued working for GM up to DOPT. The plan does not state that GM service after 

1998 should count as eligibility service for a divestiture employee who is hired by GM after 1998. 

In 's Image Viewer file, there is an e-mail stream (Image Viewer Doc. 

#224233116) between Brian Studer, the Delphi Manager of Employee Benefits, and Lisa 

McCulloch of GM. The e-mails are dated April 23, 2008. In the e-mails, Brian Studer states that 

Delphi and GM determined that "If a former Peregrine employee rehires at GM on or before 12-31­

2000 and GM grants the employee an adjusted service date (that precedes the divestiture to 

Peregrine), then Delphi will use combined credited service from their former period of GM 

employment, which Delphi has, and their C.S. at Peregrine and their GM C.S. to determine 

eligibility." 

PBGC has no other documentation ofthis decision between Delphi and GM. We accepted this 

decision and credited and with eligibility 

service for their GM service after 1998. 

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P. Medicare Supplements are not a Plan Benefit 

Some participants have asked PBGC about their Delphi Medicare Supplement. The plan document 

contains no reference to Medicare Supplements. Medicare Supplements were part of the Delphi 

Health Care Plan. The confusion may have arisen because the Delphi Medicare Supplement was 

listed on the pension benefit statements provided to participants by Delphi and was paid to 

participants as part oftheir pension check. PBGC is not responsible for the payment of any Delphi 

Medicare Supplements. 

Q. Auxiliary Disability Benefit 

ace pointed out that the plan has provisions that require disabled participants to submit to medical 

examinations to prove continued disability up to age 65, and that, at normal retirement the 

participant's benefit is "reclassified" as a normal retirement benefit. According to OCC, these 

provisions could be interpreted to mean that the disability benefit was an auxiliary benefit up to age 

65 and, therefore, there was a potential conflict with the plan's age 55 final form of annuity 

election. ASD sought guidance from OCC regarding at what age the auxiliary disability benefit 

should be converted to a retirement benefit. 

An auxiliary benefit is a disability benefit that is payable before early or normal retirement that does 

not result in an actuarial decrease for the early receipt of benefits (Treas. Reg. l.40l(a)-20 Q&A 

lO(c)). The plan disability benefits meet these criteria. Treasury Regulations also indicate that a 

participant receiving an auxiliary benefit begins retirement at early or normal retirement and spousal 

rights are determined at that date. In a memorandum dated June 19,, 2014 (Image Viewer Doc. 

#403732255), OCC agreed that PBGC should convert the Delphi auxiliary disability benefit to a 

regular retirement benefit at age 55. 

R. Reference Error Regarding Cash Balance Crediting ofInterest 

The plan changed the cash balance interest crediting period in Part C from calendar years to plan 

years in Part C, Article II, Section 3(a) ofthe October 1, 2004 plan document. This change was also 

discussed in the August 15, 2003 Cash Balance Plan Memorandum of the Delphi Employee Benefit 

Plans Committee (Image Viewer Doc. #215128907). In plan practice the change was effective 

October 1, 2003. However, Part C, Article II, Section 3(b) of the October 1, 2004 plan document, 

still refers to calendar years for determining the cash balance. We considered the reference to 

calendar year in Article II, Section 3(b) to be an unintentional error. 

S. Validity ofBenefit Freeze 

Benefit freeze notices were given to participants through a company letter dated September 15, 

2008 (Image Viewer Doc. #401772732) and a plan brochure titled Important News for Delphi US 

Salaried Employees (Image Viewer Doc. #215129081). We also have the Delphi Employee Benefit 

Plans Committee proposal to freeze the plan and approval of the freeze report (Image Viewer Docs. 

#401772730 and #403733134). PBGC accepted the benefit freeze as valid (see the March 17, 2015 

e-mail from OCC, Image Viewer Doc. #403829824). 

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12. Expected Retirement Age 

The company was reorganized under the Bankruptcy Code in an asset sale in October of 2009. We 

obtained a list of company facilities that were closed, sold, or remained open after DOPT (see 

Appendix A). We used the most recent Delphi employee work location code (Delphi called this the 

CISCO code) assigned to each participant to determine the participant's employment location. Ifwe 

could not determine a participant's employment location or we did not know the facility status 

(open, closed, or sold) at a participant's employment location, then we assumed the participant 

worked at a facility that was open as of DOPT. In some cases, a participant's date of tennination of 

employment fell after the date of sale or date a facility closed. In these cases, we assumed that the 

participant had been transferred to an open facility. We determined the expected retirement age for 

participants as follows: 

Employment Facility Closed 

Ifthe participant's employment Location was at a facility that was closed on or before DOPT, we 

followed ERISA §4044.56 and applied Table 2C to determine the expected retirement age for 

participants who terminated employment one year or more before DOPT. When using Table 2C, we 

used the age at the EPRD as the participant's earliest retirement age at DOPT. Following ERISA 

§4044.57, the expected retirement age for participants who terminated employment within one year 

of DOPT and who worked at a closed facility was their age at their EPRD. 

Employment Facility Open as ofDOPT 

Because plan provisions required that a participant retire from employment to begin receiving a 

benefit, we followed ERISA §4044.55 to determine the expected retirement age for a participant at 

an open facility as of DOPT. We applied Table 2A, 2B, or 2C according to the size of the 

participant's guaranteed monthly benefit at earliest unreduced retirement age to detennine the 

expected retirement age for each active participant. We followed ERISA §4044.56 and applied 

Table 2C to determine the expected retirement age for each separated participant as of DOPT. 

When using Table 2A, 2B, or 2C, we used the age at the EPRD as the participant's earliest 

retirement age at DOPT. 

Employment Facility Sold before DOPT 

We assumed that any facility sold before DOPT was still open as of DOPT. 

We received a list ofdivested units with coordination of benefits agreements between Delphi and 

the new owners of facilities sold before DOPT. For these divested units, we followed the expected 

retirement procedures described above under Employment Facility Open as ofDOPT. 

Ifthere was not a coordination of benefits agreement between Delphi and the new owner of a 

facility sold before DOPT, then it was not required that a participant employed at such a facility 

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retire from employment after the sale date to begin receiving a benefit. Following ERISA §4044.56, 

we applied Table 2C to determine the expected retirement age for each participant employed at a 

sold facility without a coordination of benefits agreement. When using Table 2C, we used the age at 

the EPRD as the participant's earliest retirement age at DOPT. 

13. Accrued-at-Normal Limitation 

Please see Section 5, Plan Benefit Formula Summary, for a description of the plan Early 

Retirement, Interim, and Temporary supplement benefits. 

If a participant's benefits are limited by PBOC's Accrued-at-Normal (AAN) limitation, then the 

Part A pop-up upon the death of the spouse must not occur until the age 62 and one month date (the 

date the Part A supplement ends); otherwise, the addition of the pop-up benefit would result in 

benefits above the AAN limit. 

There are a total of 3,091 retirees and deferred vested participants whose benefits are affected by the 

AAN limitation. Please see Appendix S for the list of 1,949 retirees and deferred vesteds affected 

only by the AAN limitation. Please see Appendix T for the list of 1, 142 retirees and deferred 

vesteds affected by both the AAN and Maximum Guaranteeable Benefit limitations. 

14. Maximum Guaranteeable Benefit I Aggregate Maximum Benefit 

Maximum Guaranteeable Benefit 

There are a total of 3,386 retirees, deferred vested, beneficiaries, and alternate payees whose plan 

benefit exceeds the Maximum Guaranteeable Benefit (MOB). Some of these retirees, deferred 

vesteds, beneficiaries, and alternate payees will receive an increase due to the allocation of plan 

assets in PC3 and/or the 4022(c) allocation in PC3 (see Sections 17 thru 20 and Section 24 of this 

memo for more information). Please see Appendix U for the list of the 2,242 retirees, deferred 

vesteds, beneficiaries, and alternate payees affected only by the MOB limitation. Please see 

Appendix T for the list of 1, 142 retirees and deferred vesteds affected by both the AAN and MOB 

limitations. 

MGBfor Participants with Part A and Part B Benefits 

Because a participant could be in pay with any combination of the normal forms of annuity for their 

Part A and Part B benefits, we calculated a participant's MOB using the following steps: 

1. 	 Levelize the participant's unlevel benefits (Part A benefits if there is an adjustment at age 62 

and one month and/or Supplements) and add the levelized benefits to any ofthe participant's 

level benefits. 

2. 	Determine what percent survivor benefit applies to the total levelized benefit determined in (1) 

by dividing the total survivor benefit from all benefits by (1). Call this survivor percent ''p%." 

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3. Determine the participant's Part A pop-up amount. 

4. 	 Determine the theoretical pop-up amount assuming all of the participant's benefit parts 


included a pop-up. 


The MGB equals $4,500 x MGB Age Factor x MGB Joint and p% Survivor Factor x [ 1 - 0.04 x 

0.65 x MGB Pop-up Age Factor x (3) I (4)] 

See the e-mail dated October 14, 2009 for ASD's concurrence for this method (Image Viewer Doc. 

#403732250). 

MGB to Retirees with Partial Benefits in Pay at DOPT 

There were eight retirees (see Appendix V) who were in pay at DOPT with Part A benefits but who 

had not started their Part B benefits. There were 52 beneficiaries (see Appendix W) in pay with Part 

B benefits but who had not started their Part A benefits. We applied the MGB first to the benefit in 

pay at DOPT based on the form of annuity in pay. Ifthe benefit in pay at DOPT did not exceed the 

MGB, then the percentage of the MGB above the benefit in pay at DOPT was used to adjust the 

MGB determined at the future retirement date of the benefit not in pay. Ifthe benefit in pay at 

DOPT exceeded the MGB, then the benefit not in pay was considered above the MGB and was not 

guaranteed. See the e-mail dated October 14, 2009 for AS D's concurrence for this method (Image 

Viewer Doc. #403732250). 

MGB for Disability Benefits to Retirees Under Age 55 at DOPT 

As described in Section 10. Forms ofAnnuity, subsection Par! A and Part B Disability Auxiliary 

Benefit Form ofAnnuity, participants under age 55 receiving a disability benefit were required to 

choose a final form of annuity at age 55. We applied the MGB first to the benefit in pay at DOPT 

based on the form of benefit in pay and the age of the participant at DOPT. At age 55, we applied 

the MGB based on the form of annuity chosen at age 55 and the age of the participant at DOPT. 

MGB for Non-Disability Benefits to Retirees Under Age 55 with 50% Survivor Coverage 

As described in Section 10. Forms ofAnnuity, subsection Part A and Part B PosJ-ReJirement 50% 

Spouse Coverage for Retirement Payments before Age 55, participants under age 55 receiving a 

benefit with 50% spouse coverage were required to choose a final form of annuity at age 55. We 

applied the MGB first to the benefit in pay at DOPT based on the form of benefit in pay and the age 

of the participant at DOPT. At age 55, we applied the MGB based on the form of annuity chosen at 

age 55 and the age of the participant at DOPT. None ofthese participants' benefits were reduced by 

the MGB limitation. 

MGB Application for Participants with Foreign BenejiJ Offset 

As described in Section 9. Offsets to Plan Benefits, subsection Foreign Service Offset, a 

participant's benefit is offset by any benefit payable to the participant by a foreign subsidiary. 

Because foreign offset benefits are not plan benefits, the foreign benefit offset is applied to the plan 

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Case Number: 20637000 

benefit before applying PBGC MOB limitations. See Image Viewer Doc. #403762512 for ASD's 

concurrence to this decision. 

Aggregate Maximum Benefit 

There are 2,516 records listed in the Aggregate Maximum report provided by OASD. 

There were 845 records for Delphi Salaried plan employees who were also employees in the Delphi 

Hourly-Rate Employees Pension Plan (PBGC Case Number 20637100), which has the same DOPT, 

trusteeship date, and termination initiation date as this plan. Because this plan is the smaller plan, it 

is considered the prior plan and these participants are not affected by the Aggregate Limit on 

Benefits Payable from PBGC funds in this plan. Note that the 845 employee number in both plans 

in the Aggregate Maximum report is different from the 73 participants with benefits from both plans 

in Appendix I because the Aggregate Maximum report includes 772 employees not included in the 

hourly and salaried valuations for various reasons. 

There were 143 Delphi Salaried plan participants who were also in the ASEC Manufacturing 

Retirement Program (PBGC Case Number 21102100), Delphi Mechatronic Systems Retirement 

Program (PBGC Case Number 20700700), or PHI Non-Bargaining Retirement Plan (PBGC Case 

Number 21102700). These plans have the same DOPT, trusteeship date, and termination initiation 

date as this plan. Because this plan is the larger plan, it is considered the current plan. We found the 

benefits of these participants are not affected by the Aggregate Limit on Benefits Payable from 

PBGC funds. 

We analyzed the remaining 1,528 employees of other plans in the Aggregate Maximum report and 

found that none are affected by the Aggregate Limit on Benefits Payable from PBGC funds. 

Please see Appendix X for a list of 1,270 participants in this plan who are also participants in other 

PBGC trusteed plans. 

15. Phase-In Limitation 

Benefit Freeze Immediate Vesting 

As part ofthe plan benefit freeze, effective September 30, 2008, active employees and employees 

who separated from employment with less than 5 years of service as part of any divestiture that 

occurred between August 1, 2006 and September 30, 2008 were made 100% vested. According to 

John DeMarco, the former Delphi Director ofPension and Welfare Benefits, the Internal Revenue 

Service (IRS) ruled that this benefit increase was de minimis and that IRC Section 40l(a)(33) and 

Section 412(f)( 1) (pertaining to nonqualification of a plan if a plan adopts a benefit increase while 

the employer is a debtor under title 11) could be waived. We do not have documentation of this IRS 

waiver. The immediate vesting provisions are described in appendices B3, 84, BS, and B6 of the 

April 30, 2009 Watson Wyatt Financial Accounting Standards 35 Opinion (Image Viewer Doc. 

#403778572) and in the benefit freeze notices given to participants (Image Viewer Docs. 

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l(b)(6) Applied to All Redactions on This Page Case Number: 20637000 I 

#401772732 and #215129081). We accepted the assertion by John DeMarco that Delphi obtained a 

waiver for the immediate vesting provision. We applied a 0% phase-in to this benefit increase (see 

Image Viewer Doc. #403778569). Because the 4022(c) allocation did not increase the benefits of 

participants with unfunded non-guaranteed PCS benefits, participants affected by this phase-in will 

not receive a benefit from PBGC unless they receive a benefit attributable to their employee 

contributions. 

The 0% immediate vesting phase-in affected the benefits of one retiree and 3 73 deferred 

participants. The one retiree affected by the 0% immediate vesting phase-in of Part C benefits is ········••I The 0% immediate vestin hase-in affected the Part A benefits of 

. All other benefits affected by the 0% immediate vesting phase-in are 

and 

Part C benefits. The 373 deferred participants affected by the 0% immediate vesting phase-in are 

listed in Appendix Y. 

Benefit Rate, Supplement, and Compensation Limit Increases 

The increase to Part A benefit rates from $48.50 to $49.55, effective October 1, 2004, is $80/80% 

phased-in. The increases to Part A Early Retirement and Interim supplements, effective October l, 

2004, are $80/80% phased-in. The increases in 401(a)(17) compensation limits are phased-in as 

shown in the following table: 

Effective Date 401(a)(17) Compensation Limit Phase-in Limitation 

10/01/2004 $205,000 $80/80% 

10/01/2005 $210,000 $60160% 

10/01/2006 $220,000 $40/40% 

10/01/2007 $225,000 $20/20% 

10/01/2008 $230,000 0% 

At the valuation expected retirement date, there are no participants with benefit increases from the 

Part A benefit rate change, Part A supplement changes, and/or the changes to compensation limits 

that are affected by phase-in limitations. 

One participant, , had a benefit increase at his normal retirement date 

from the Part A benefit rate change and the changes to compensation limits that is affected by the 

$60160% phase-in limitation. He earned compensation over the 401(a)(l 7) compensation limits. He 

also had benefits reduced by the benefit he earned from GM Canada. 

One participant, had benefit increases at his early unreduced 

retirement date and normal retirement date from the Part A benefit rate change and the changes to 

compensation limits that are affected by the $80/80%, $60/60%, and $40/40% phase-in limitations. 

He earned compensation over the 40I(a)(17) compensation limits. He also had benefits reduced qy 

the benefit he earned from GM Canada. 

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Mutually Salisfaclory Retirement Benefit Increase 

The Delphi Hourly plan provided hourly participants Mutually Satisfactory Retirement (MSR) 

benefits "as a result of a plant closing or discontinuance of operations." MSR provisions provide an 

hourly participant with unreduced benefits at the participant's date of retirement. 

There are four retirees in the Delphi Salaried plan with ''Mutually Satisfactory Release" as the last 

event of their employment history in the deconversion file. All four transferred from the Delphi 

Salaried plan to the Delphi Hourly plan. These retirees are:•••••••••••• 

, and 

The Part A benefit of these four retirees is paid by the Delphi Hourly plan. The Part B Primary 

benefit of these four retirees is paid by the Delphi Salaried plan. None of these retirees has a Part B 

Supplementary benefit. 

The Delphi Salaried plan does not contain MSR provisions or indicate that transfers to the Delphi 

Hourly plan could receive MSR unreduced Part B benefits. Two of the retirees, 

and -·have a Delphi benefit calculation document that shows the Part B Primary benefit 

did receive MSR unreduced treatment (see Image Viewer Docs. #219822430, page 3, and 

#219898765, page 2). All four of the retirees' Part B benefits in pay are matched when calculated 

with no early retirement reduction. John DeMarco, the fonner Delphi Director of Pension and 

Welfare Benefits, stated that "when an employee retired under an Hourly MSR, they received all of 

their benefits, including any salary program benefits, under the provisions of the MSR." We 

accepted the plan practice that provided these retirees with MSR unreduced Part B benefits (see 

Image Viewer Doc. #403778907). 

, and-retired before 2004. Because they were given the 

MSR for their Part B benefits more than 5 years before DOPT, their Part B benefits in pay are 100% 

phased-in. 

worked at the Delphi facility in Athens, Alabama. This facility closed within one year 

of DOPT. His tennination of employment is December 31, 2008. The MSR he received is 

considered an Unpredictable Contingent Event Benefit (UCEB). Under PPA 2006, because the 

Unpredictable Contingent Event (UCE) occurred after July 26, 2005 and within one year of DOPT, 

his Part B benefit increase from the MSR benefit provisions is 0% phased-in. Note that the PBGC is 

also applying the same 0% phase-in to Delphi Hourly plan benefits under the MSR given to hourly 

employees at the Athens facility. The UCEB is not prohibited under IRC 436(b). See Section 26. 

Addilional Comments, A. !RC 436, for additional information on !RC Section 436 prohibitions. 

Career Transition Program and Salaried Retirement lncenlive Program Benefit Increases 

The last Career Transition Program or Salaried Retirement Incentive Program that provided 

retirement incentives to Delphi employees was more than 5 years before DOPT. Therefore, no 

Career Transition Program or Salaried Retirement Incentive Program benefits were subject to 

phase-in limitations. 

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16. Majority Owner Limitation 

The auditor did not identify any majority owners. 

17. Asset Allocation 

Employee contributions were required to participate in Part B of the plan; therefore, there were PC2 

liabilities. 

A participant's PC3 benefit could exceed the participant's guaranteed benefit. The plan changed the 

Part A benefit rate from $48.50 to $49.55 and the Part B Supplementary compensation level from 

$4,850 to $4,955 effective October l, 2004. Under this change, a participant's Part A benefit 

increases and Part B Supplementary benefit decreases. The total accrued benefit of any participant 

could never decrease because the increase to a participant's Part A benefit is always greater than or 

equal to the decrease in the participant's Part B Supplementary benefit. For the purposes of 

calculating PC3 benefits, we used the Part A benefit rate of $48.50 and the Part B Supplementary 

compensation level of $4,850 from the benefit provisions of the 5-year-old plan (see Image Viewer 

Doc. #403778570). 

We calculated PCS liabilities as a result of vested benefits in excess of Accrued-at-Normal 

limitations, MOB limitations, and phase-in limitations. 

We calculated PC6 liabilities as a result of non-vested liabilities and the Part Clump sum death 

benefit in excess of the Part C QPSA. 

Assets covered priority category liabilities in the following percentages: 

Priority Category Liabilities Assets Percent Covered by Assets 

PC2 $129,488,190 $129,488, 190 100% 

PC3 $2,865,947 ,654 $2,383,546,358 83.1678% 

PC4 $ l, 177,313,357 $0 0% 

PCS $357,565,885 $0 0% 

PC6 $63,759 $0 0% 

Total $4,530,378,845 $2,513,034,548 -­

A total of l, 122 retirees and deferred vested participants received PC3 allocated benefits greater 

than their guaranteed benefits. See Appendix Z for a list of these participants. All of these 

participants also received benefits from the 4022(c) allocation (see below). 

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18. 4022(c) Allocation 

The total Unfunded Non-Guaranteed Benefits (UNGB) were $521,525,998. Of this amount, we 

valued $163,896,354 in PC3 as a result of AAN and MOB limitations, $357,565,885 in PCS as a 

result of the AAN, MOB, and phase-in limitations, and $63,759 in PC6 as a result of non-vested 

liabilities and the Part Clump sum death benefit in excess of the Part C QPSA. 

PBGC issued the Notice of Determination (NOD) on July 20, 2009. Because this occurred after 

December 17, 1990, and UNGB exceeded $20 million, we consider this a NON-SP ARR Plan for 

4022( c) benefit amounts. The PBGC recovered $155,298,056 for employer liability in this plan (see 

Recovery Valuation and Allocation Memorandum for Delphi Corp, Dated November 6, 2014, 

[mage Viewer Doc. #403671629 and the CMS Recovery Valuation screen). The total UBL for this 

plan is $2,017,344,297. The Actual Recovery Ratio, which is equal to the value of PBGC's 

recovery divided by the total UBL, is 7.70% (see the e-mail dated September 25, 2015 from OCC, 

Image Viewer Doc. #404771252). 

The 4022(c) amount is $40,157,548. We used the entire amount to increase the benefits of 

participants with UNGB in PC3. The 4022(c) amount funds 24.5018% of the PC3 UNGB. 

There were 1, 122 participants who received benefits from both the PC3 asset allocation and the 

4022(c) allocation (see Appendix Z). There were 2,229 participants who received benefits from 

only the 4022(c) allocation (see Appendix AA). 

19. Pre·DOPT Retiree Benefit Changes I Pre-Termination Plan Liability 

Pre-DOPT Retiree Benefit Changes 

Application of the $5/5% Tolerance Range 

We tested the benefits of the 7,606 retirees and 318 beneficiaries in pay on DOPT. 

There are 6,971 retirees and 272 beneficiaries (7,243 payees in total) for whom the difference 

between our calculated benefit and the benefit in pay status is within the $5/5% tolerance range and 

for whom there were no systematic or administrative errors-in the plan administrator's calculation 

oftheir benefits. We accepted the benefit in pay for these 7,243 payees. 

There are 140 retirees and 11 beneficiaries ( 151 payees in total) for whom the difference between 

our calculated benefit and the benefit in pay status is outside the $5/5% tolerance range and for 

whom we did not have the plan administrator benefit calculation and cannot determine the reason 

for the difference. We accepted the benefit in pay for these 151 payees. 

There are 116 alternate payees in pay. Please see Section 24. Qualified Domestic Relations Orders 

(QDROs) for the discussion of how we valued the benefits of alternate payees in pay. 

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Systematic Errors 

During our analysis of the benefits in pay at DOPT, we identified 326 payees with a systematic plan 

administrator error due to the failure of the plan administrator to credit participants with the ERISA 

minimum benefit attributable to employee contributions determined at the date of an in-service 

withdrawal described in Section 11, Benefit/Plan Document Interpretations ofNole, subsection H 

Withdrawal ofEmployee Conlributions. We changed the benefits of these payees. 

Non-systematic and Administrative Errors 

We identified 53 non-systematic plan administrator errors during our analysis of the benefits in pay 

at DOPT. These errors affect the benefits of 233 payees in pay on DOPT. We changed the benefits 

of these retirees, beneficiaries, and alternate payees. The table below shows a general description of 

the different errors and the number of occurrences of each error. Twenty four payees in the table 

below are also affected by the systematic error described in the previous paragraph. These payees 

are identified with "ERISA minimum benefit applies at in-service employee contributions 

withdrawal" as the last portion of the error description comment. 

Error Description Number of 

Occurrences 

Not eligible for Part A increase at age 62 and one month 45 

Part A benefit did not pop-up upon spouse's death 46 

Benefit did not increase at age 62 and one month 28 

Part A Benefit not reduced for survivor coverage 22 

Part B credited service calculated as if no withdrawal; ERfSA minimum benefit applies at in-service 

employee contributions withdrawal 12 

Employee contribution withdrawn after divested date should be treated as out-of-service withdrawals 5 

Benefit did not increase at age 62 and one month; pre-62 Part A benefit calculated as if no increase at age 

62 and one month 5 

Participant benefit at retirement date not reduced by amount payable to A ltemate Payee 4 

Benefit in pay not reduced for Joint and Survivor coverage 4 

Canada Foreign Offset not applied 3 

Not eligible for supplement because participant is receiving Social Security Disability 4 

Part B survivor benefit calculated using incorrect QPSA survivor percentage (65.5% rather than 65.3%) 

for active employee (see Section 8., Part B, Part B Plan QPSA for Active Emgloxees Particigating in Part 

B at the Date of Death 2

Fidelity offset weekly workers compensation rather than monthly workers compensation 2 

Alternate Payee died before DOPT; Participant's benefit was not restored to full amount and Part A was 

not popped up 2 

Benefit did not reduce to Joint and Survivor amount at age 55 1 

Not eligible for 30-Year retirement 2 

Alternate Payee's share of supplement not subtracted from Participant's supplement 2 

Part B benefits in pay not reduced for Joint and Survivor coverage 2 

Part A survivor benefit should have started first of the month following participant's 55111 birthday; Part A 

in pay uses incorrect benefit rate 1 

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Case Number: 20637000 

Error Description Number of 

Occurrences 

Part B Supplementary benefit is being paid twice - in both Part B Supplementary field and early 

retirement supplement field I 

Transfer from PHI - Delphi benefit should be calculated using only Delphi credited service I 

Part A survivor benefit calculated using incorrect Joint and survivor percentage (50% rather than 65%) 8 

Part A survivor benefit calculated using Part B credited service; employee contributions withdrawn after 

divested date should be treated as out-of-service withdrawals; ERISA minimum benefit applies at inservice employee contributions withdrawal 1 

Employee contribution withdrawn after DOTE should be treated as out-of-service withdrawal 1 

Plan Administrator initiated recovery should have ended before DOPT; Part B benefits in pay calculated 

using JO-Year rather than Window early retirement factor I 

T&PD Age 55 re-election before DOPT I 

Employee contribution withdrawn after divested date should be treated as out-of-service withdrawal; 

ERISA minimum benefit applies at in-service employee contributions withdrawal I 

Part A benefit did not pop-up upon spouse's death; ERISA minimum benefit applies at in-service 

employee contributions withdrawal 1 

IRS levy does not apply to Early Retirement Supplement after DOPT; ERISA minimum benefit applies at 

in-service employee contributions withdrawal I 

Part B CS calculated as if no withdrawal; Part A Benefit did not increase at age 62 and one month; pre-62 

Part A benefit calculated as if no increase at age 62 and one month; ERISA minimum benefit applies at 

in-service employee contributions withdrawal I 

Benefit did not increase at age 62 and one month; pre-62 Part A benefit calculated as if no increase at age 

62 and one month; ERISA minimum benefit applies at in-service employee contributions withdrawal I 

Plan Administrator form conversion factor= 0.945, calculated fonn conversion factor= 0.950; ERISA 

minimum benefit applies at in-service employee contributions withdrawal I 

Plan Administrator did not apply 70% Final Base Pay limit; ERISA minimum benefit applies at in-service 

employee contributions withdrawal 1 

Plan Administrator early retirement factor= 0.618, calculated ERF = 0.622; ERISA minimum benefit 

applies at in-service employee contributions withdrawal l 

Fidelity's estimated withholding for Alternate Payee benefit while Domestic Relations Order was being 

qualified was incorrect I 

Participant and Alternate Payee benefits in pay are greater than the total benefit for post-retirement shared 

payment I 

Participant's Part A and Early Retirement Supplement not reduced for Qualified Domestic Relations 

Order I 

Alternate Payee's share of Part A 62& 1 increase not paid to either P or Alternate Payee I 

Part A Benefit did not increase at age 62 and one month; Part B Primary benefit not offset for portion 

payable to Alternate Payee I 

Alternate Payee's survivor benefit not in pay on DOPT 1 

Incorrect marital fraction used to put Alternate Payee into pay (used marital fraction from an estimate for 

a 2012 retirement date) 1 

Fidelity stopped paying Part B Supplementary when Part A started at Participant's age 55 I 

Fidelity did not pay Part B Supplementary benefit 1 

Interim supplement incorrect per Fidelity I 

Plan Administrator used deferred vested early retirement factor rather than 30-Year early retirement I 

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Case Number: 20637000 

Error Description Number of 

Occurrences 

factor 

Plan Administrator early retirement factor"" 0.771, calculated early retirement factor"" 0.580; ERJSA 

minimum benefit applies at in-service employee contributions withdrawal I 

Part A benefit did not increase a:fter spouse waived survivor coverage upon divorce I 

QDRO and ERISA minimum benefit applies at in-service employee contributions withdrawal I 

Part A benefit did not increase at age 62 and one month; Part B Primary benefit not reduced for early 

retirement I 

Part A benefit did not increase at age 62 and one month; Part B Primary benefit not reduced for survivor 

cost I 

Part A Benefit not reduced for survivor coverage; ERISA minimum benefit applies at in-service 

employee contributions withdrawal I 

Part B benefit should not have popped-up at spouse's death I 

ERF Part B benefits and Early Retirement Supplement incorrect per Fidelity I 

Please see Appendix AB for a list of the 535 payees whose benefits were changed for the systematic 

and non-systematic errors noted above. 

Reconciliation of Current Monthly Benefits 

There are 1 ,934 retirees and beneficiaries whose current monthly benefit will increase. Please see 

Appendix AC for more information. 

There are 149 retirees and beneficiaries whose current monthly benefit will decrease. Please see 

Appendix AD for more information. 

Only participants who are receiving a benefit determination statement from the BSRS program are 

included in the counts above. Participants with a manual statement are not included. 

Pre-Termination Plan Liability 

The pre-termination plan liabilities for 401 retirees, 31 beneficiaries and three alternate payees are 

shown in Appendix AE. Because assets cover these amounts, the participants will receive their full 

pre-termination plan liability. 

The total pre-termination plan liability is $2,295,675.59. 

Plan Administrator Recoupments that Continue after DOPT 

There are 18 retirees and one beneficiary with plan administrator initiated recoupments in place at 

DOPT for benefit overpayments that occurred before DOPT. See Appendix AF for a list of these 

participants. 

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Many of the recoupments were for participants who received an Early Retirement or Interim 

supplement when they were put into pay by Delphi but began receiving Social Security Disability 

Insurance Benefits after retirement. Delphi did not immediately offset the Early Retirement or 

Interim supplement by the plan Temporary supplement, as required by the plan (see Section 5. Plan 

Benefit Formula Summary, Subsection Part A Supplements) resulting in an overpayment. Delphi 

notified the participant before DOPT by letter that overpayments as a result of this error were 

subject to recoupment and started the recoupment of the overpayment before DOPT. However, in 

some cases Delphi notified the participant after DOPT by letter that overpayments as a result of this 

error were subject to recoupment (see Image Viewer Doc# 219663860 for 

- as an example). For some participants there is no information that Delphi notified the 

participant at all about any overpayment. For example there is no information on Image Viewer that 

was notified by Delphi about overpayments. Delphi retirement 

application forms explicitly state that overpayments as a result of the receipt of Social Security 

Disability Insurance Benefits are subject to recoupment (for example see Image Viewer Doc# 

220336533 for . OPSS determined that the Delphi retirement application form 

served as a recoupment notice to participants. PBGC will recoup the pre-DOPT overpayments to 

participants due to the receipt of Social Security Disability Insurance Benefits after retirement 

according to the plan administrator's recoupment schedule (see Image Viewer Doc #404497027). 

20. Post-DOPT Retirees 

As of March I, 2015, there are 1,157 participants and deferred beneficiaries who retired after 

DOTR2

• 

The current monthly benefits for 540 post-DOTR retirees and beneficiaries will not change because 

each is exactly correct. See Appendix AG for a list of these payees. 

The current monthly benefits for 104 post-DOTR retirees and beneficiaries will not change because 

each is not exactly correct but within administrative tolerance. See Appendix AH for a list of these 

payees. 

The current monthly benefit for 443 post-DOTR retirees and beneficiaries will increase. See 

Appendix AI for a list of these payees and the reason for the benefit increase. 

The current monthly benefit for 70 post-DOTR retirees and beneficiaries will decrease. See 

Appendix AJ for a list of these payees and the reason for the benefit decrease. 

2 We are only including participants who are receiving a benefit determination statement from the BSRS program. 

Participants with a manual statement are not included at this time. 

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l(b)(6) Applied to All Redactions on This Page I Case Number: 2063 7000 

21. Estimated Lump Sums paid Post-DOPT 

Estimated Lump Sums Paid Post-DOPT but Pre-DOTR 

No lump sum payments were paid by the prior plan administrator prior to DOTR. 

Estimated Lump Sums Paid Post-DOTR 

As ofJune 1, 2015, no estimated lump sum payments have been paid after DOTR by PBGC. 

22. Estimated Benefit Adjustments 

Estimated benefit adjustments were made on the benefits of3,725 participants, 13 beneficiaries, and 

107 alternate payees. The benefits were adjusted due to the MGB limitation, the Accrued-at-Normal 

limitation, or both. The PC3 4044 allocation ratio used for estimated benefit adjustments was 70%. 

The Estimated Benefit Adjustment Memos and accompanying attachments are located in Section 

9C oflmage Viewer (Image Viewer Doc, #221737080). See also Section 19, Pre-DOPT Retiree 

Benefit Changes I Pre-Termination Plan Liability, and Section 20, Post-DOPT Retirees, for more 

information. 

23. Post-Normal Retirement Date Benefits 

The following 37 participants reached their Normal Retirement Date before DOPT and had not 

retired as of DOPT, July 31, 2009: 

No. Participant Name Participant SSN Nonnal Retirement Required Actual Retirement 

Date Be innin Date Date 

11/01/2007 04/01/2014 I 0/01/2009 

2 12/01/2008 04/01/2015 02/01/2015 

3 12/01/2008 04/01/2015 01/01/2011 

4 12/01/2000 08/01/2009 08/01/2009 

5 11/01/2006 04/01/2013 04/0112013 

6 05/01/2005 04/01/2011 12/01/2010 

7 10/01/2007 04/01/2014 Not in Pa 

8 01/01/2009 04/01/2015 09/01/2009 

9 11/01/2006 04/01/2013 l l/O 1/2009 

10 08/01/1998 04/01/2010 04/01120 I 0 

11 08/01/2008 04/01/2015 l 0/01/2012 

12 07/01/2009 04/01/2015 l l/01/2009 

13 01/01/2008 04/01/2014 10/01/2009 

14 07/01/2009 04/01/2015 08/0 l/2009 

15 03/01/2009 04/01/2015 09/01/2009 

16 07/01/2008 0410l/2014 12/01/2009 

17 I 0/01/1999 08/01/2009 08101/2009 

18 12/01/2008 04/01/2015 Not in Pa 

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l(b)(6) Applied to All Redactions on This Page I Case Number: 20637000 

No. Participant Name Participant SSN Nonna! Retirement Required Actual Retirement 

Date Be innin Date Date 

19 09101/2006 04/01/2013 l l/O 1/2009 

20 06/01/2007 04/01/2013 11101/2009 

21 10/01/2008 04/01/2015 01/0 l/20 I2 

22 12/01/2006 04/01/2013 Not in Pa 

23 05/01/2007 04/01/2013 1110i/2012 

24 01/01/2008 04/01/2014 11/01/2009 

25 06/01/2001 08/01/2009 08/01/2009 

26 07/01/2009 04101/2015 08/01/2009 

27 09/01/2008 04101/2015 l 0/0 l/2009 

28 11/01/2008 04/01/2015 07/01/2012 

29 04/01/2005 04/01/2011 0810112009 

30 09/01/2007 04/01/2014 03/01/2012 

31 12/01/2004 04/01/201 l 10/01/2009 

32 12/01/2007 04/01/2014 12/01/2009 

33 01/01/2007 04/01/2013 09101120 I0 

34 11/01/2008 04/01/2015 08/01/2009 

35 02101/2007 04/01/2013 10/0J/2009 

36 10/01/2008 04/01/2015 08/01/2009 

37 0610112008 04/01/2014 I l/O 1/2009 

24. Qualified Domestic Relations Orders (QDROs) 

QDRO population as ofMarch 1, 2015 

There are 637 participants and beneficiaries with QDROs. The following table shows a breakdown 

of the participant QDRO population: 

Description Count 

Participants in Pay on DOPT 352 

Participants Not in Pay on DOPT 279 

Beneficiaries in Pay on DOPT 6 

Total Participants and Beneficiaries with QDROs 637 

There are 652 alternate payees with QDROs. Of these 652, there are 120 alternate payees included 

in the valuation with separate benefit liabilities, and 532 alternate payees associated with 

participants such that they do not have separate alternate payee records in the valuation database. 

The 532 includes 305 alternate payees whose data is not included in the valuation database, because 

they were not in pay at DOPT and we did not have the data to include them in the database when it 

was constructed. The following table shows a breakdown of the alternate payee population: 

Description Count 

Alternate Payees in Pay on DOPT valued 

Separately on DOPT 116 

Deferred Alternate Payees valued Separately on 

DOPT 4 

Alternate Payees in Pay at DOPT and Valued with 227 

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Description Count 

Participant Liability• 

Alternate Payees not in Valuation Database 305 

Total Alternate Payees Subject to a QDRO 652 

*See Valuation Assumptions for liabilities section below 

Please see Appendix AK for a list of the 651 participants and beneficiaries with the associated 

alternate payees. 

artici ant count (637) and the alternate payee count (652) is because 

one participant, is identified as havin two QDROs associated with his 

benefit. One of the alternate payees, is included in the database 

while the other alternate payee, is not included in the database. 

Additionally there are 14 participants with a QDRO associated with their benefits who are not 

included in the valuation database because they died before DOPT (12 participants), received a 

lump sum for their entire benefit before DOPT ( 1 participant), or their entire benefit is paid through 

a purchased annuity ( 1 participant). 

Valuation Assumptions for Liabilities 

Due to the large number of QDROs as well as the complexities associated with each QDRO, we 

used several assumptions to calculate liabilities for participants and alternate payees in the 

valuation. ASD agreed with the outline below for valuing QDROs in the valuation (see e-mail dated 

December23, 2013, Image Viewer Doc. #403732251). 

For purposes of this Section 24, "P" indicates "participant" and "AP" indicates "alternate payee." 

Our assumptions are detailed as follows: 

• 	 If the P and/or the AP were in pay on DOPT, then: 

1. 	We accepted the plan benefits in pay on DOPT; 

2. 	We used the benefits in pay on DOPT and our calculated plan early retirement factors 

(ERF), late retirement factors (LRF), benefit form conversion factors (BFCF), and age 

adjustment factors to derive an associated AP%; 

3. We assigned the resulting AP% to the AP's MOB and to the AP's PC3 benefit; and 

4. 	Ifthe P was married at date of retirement (DOR), we assumed the spouse is entitled to all 

of the survivor benefit. Otherwise, ifthe AP is entitled to a survivor benefit and there is no 

current spouse, then we assumed the AP is entitled to all of the survivor benefit. 

• 	 Ifneither the P nor the AP was in pay on DOPT, we valued the entire benefit on the P's life 

and ignored the QDRO. 

• 	 We included the AP in the load calculation only if the QDRO was a separate interest and 

either the P or the AP or both were in pay on DOPT, or ifthe QDRO was a shared payment 

and the P was deceased as of DOPT. 

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Details of the Valuation Calculations 

The following outline shows how the valuation assumptions noted above were applied for purposes 

of the valuation: 

1) Separate Interest QDROs 

A. Neither P nor AP in pay on DOPT -we valued only the P's benefit and as if there was no 

QDRO 

B. Either P or AP but not both in pay on DOPT -	 we accepted the benefit in pay on DOPT. We 

calculated the plan ERF, BFCF, and/or age adjustment factor and used them to derive the 

associated accrued monthly benefit (AMB) assigned to the person in pay. Since the total 

AMB equals sum of the P's AMB and the AP's AMB, the portion of the benefit assigned to 

the AP was AP AMB I total AMB =AP%. We assumed the AP was entitled to AP% of the 

PC3 benefit. Ifthe P was married at DOR I XRD, we assumed the spouse receives all of the 

survivor benefit. Ifthe AP is entitled to a survivor benefit and there is no current spouse, then 

we assumed the AP receives all of the survivor benefit. 

C. Both P and AP in pay on DOPT- we accepted the benefits in pay on DOPT. We calculated 

the plan ERF, BFCF, and/or age adjustment factor applied to the AP's benefit and derived the 

associated AMB assigned to the AP. The portion of the total AMB assigned to the AP was 

AP AMB I total AMB =AP%. We assumed the AP is entitled to AP% of the PC3 benefit. If 

the P was married at DOR, we assumed the spouse receives all of the survivor benefit. Ifthe 

AP is entitled to a survivor benefit and there is no current spouse, then we assumed the AP 

receives all of the survivor benefit. 

2) Shared Payment QDROs 

A. Pre-DOPT QDROs 

a) Both P and AP in pay on DOPT: 

L Pre-retirement QDRO- we accepted and summed the benefits in pay on DOPT and 

valued the sum in the form elected at the P's DOR. If the P was married at DOR, we 

assumed the spouse receives all ofthe survivor benefit. Ifthe AP is entitled to a survivor 

benefit and there is no current spouse, then we assumed the AP receives all of the survivor 

benefit. 

IL Post-retirement QDRO -we accepted and summed the benefits in pay on DOPT and 

valued the sum in the form elected at the P's DOR. Ifthe AP is entitled to a survivor 

benefit, then we assumed the AP receives all of the survivor benefit. Note that the plan 

allowed for post-retirement form changes that we ignored post-DO PT for valuation 

purposes. 

b) Either P or AP but not both in pay on DOPT: 

1. 	 Ifthe AP died before DOPT, then we assigned the entire benefit to the P. 

IL 	 Ifthe AP is in pay on DOPT and the Pis alive and not in pay, then we valued the benefits 

like a separate interest QDRO payable over the P's lifetime. 

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Case Number: 20637000 

ni. Ifthe AP is in pay on DOPT and the P died before DOPT, then: 

1. 	If both an AP and a beneficiary were in pay on DOPT, we calculated the plan ERF and 

BFCF, applied them to the AP's benefit, and derived an associated AMB assigned to the 

AP. The portion of the benefit assigned to the AP is AP AMB IAMB= AP%. We 

assumed the AP is entitled to AP% of the PC3 benefit. 

2. 	Ifthere is only an AP in pay on DOPT, then we valued the AP as a beneficiary. 

c) Neither P nor AP in pay on DO PT-we valued only the Pas if there was no QDRO. 

B. Post-DO PT QDROs - we valued the benefit in pay on DOPT as if there was no QDRO. 

In summary, for all QDROs where either the Participant or the Alternate Payee was in pay status on 

DOPT, we used the benefit amounts as provided by the prior plan administrator and adjusted for 

PBGC limitations for purposes of the valuation. If neither the Participant nor the Alternate Payee 

was in pay on DOPT, we valued only the Participant's benefit as ifthere was no QDRO. We did not 

attempt to recalculate the Participant and Alternate Payee benefits in pay on DOPT. After the 

valuation is completed, each record with a QDRO associated to the benefit will be reviewed 

individually for application of the $515% tolerance, systematic errors, and plan administrator errors. 

25. Benefit Statement and Recalculation System (BSRS) 

Current Date for BSRS 

The valuation database was last updated on March 1, 2015. The "current date" for BSRS purposes 

is December 1, 2015. 

Number ofBenefit Determination Statements Produced - Non QDRO 

Group Number of BSRS 

Statements 

Number of Manual 

Statements 

Number without 

Statements 

Total 

Retirees and Beneficiaries 4,015 50 3,501 7.566 

Separated V esteds 3,678 31 0 3,709 

Active Vesteds 7,359 542 0 7,901 

Non-Vesteds 0 0 0 0 

Total 15,052 623 3,501 19,176 

Retirees and beneficiaries receive benefit determination statements because of changes to their 

current benefits in pay due to the 4044 and 4022(c) allocations and/or the correction of plan 

administrator errors described in Section 19. Pre-DOPT Reliree Benefit Changes I Pre-Termination 

Plan Liability. 

The benefit determination statements for 623 participants not affected by a QDRO are manual 

statements. Of these 623 participants, 524 have manual statements because they are entitled to 

retroactive retirement dates (see Section 26. Additional Comments, subsection D. Retroactive 

Annuity Starting Dates) and 34 have manual statements because of working retirement issues (see 

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Case Number: 2063 7000 

Section 26. Additional Comments, subsection J Working Retirement Violations). The remaining 65 

have manual statements for various reasons shown on Appendix AL. Please see Appendix AL for a 

list of the 623 participants with manual statements. 

Former Hughes Employees with Hughes Benefit Paid by Raytheon 

If a participant listed in Appendix J provides PBGC with a Hughes benefit statement from Raytheon 

showing the Hughes employer provided benefit at the participant's date of retirement then the 

alternate calculation described in Section 9. Offsets to Plan Benefits, subsection Hughes Benefit 

Offset for Former Hughes Employees with Hughes Benefit Paid by Raytheon will be done manually 

by ASD. Please send requests for these calculations to the actuary. 

QDRO Benefit Statements 

The benefit statements for 63 7 participants and beneficiaries and 652 alternate payees who are 

affected by a QDRO are manual statements. After the valuation is completed, each record with a 

QDRO associated to the benefit will be reviewed individually and, if necessary, a benefit 

determination statement will be produced. Please see Appendix AK for a list of these participants. 

Description Count 

QDRO possible Participants and 

Beneficiaries Manual Statements 

637 

QDRO possible Alternate Payee Manual 

Statements 

652 

Total possible QDRO Statements l,289j 

Additional Guidance Needed/or the BSRS 

Benefit calculations are not sholMl on benefit determination statements, except for Part C benefits. 

If a participant requests to see the calculation for a benefit sholMl on the participant's benefit 

determination statement, a worksheet can be obtained through the BSRS recalculation program. 

Description ofRetirement Types on Benefit Determination Statements 

The retirement types sholMl on PBGC benefit determination statements are the same as those used 

by Delphi plan administrators. Below is a table that lists the different retirement types. 

date 


Death Of An Em lo ee - Svr Benefit 


Mutually Satisfactory Retirement 
 Participant met the requirements for Mutually Satisfactory Retirement, See 

Section 15. Phase-in Limitation, Subsection Mutually Satisfactory 

Retirement Bene 11 /ncrease 

3 The difference between the total count from the two tables above of20,465 ( 19, l 76 + 1,289) and the valuation 

database count of 20, 160 is the 305 alternate payees not included in the valuation database. 

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Delphi Retirement Type Description 

Non Vested Participant is not vested 

Nonna! - Age 65 and Older Participant is Age 65 or older at retirement but not Age 70 Y2 Minimum 

Distribution Type 

Separation With Vested Benefit Vested oarticioant not eligible to retire under any other retirement type 

Special Retirement Special retirement provided to participant by Delphi 

Total And Pennanent Disability Participant met the requirements for plan disability benefits, See Section 5 

Plan Benefit Formula Summary, Subsection Disability Benefits (Part A and 

Part B) and Section 11. Benefit I Plan Document Interpretations ofNote, 

Subsection E. Post-Disability Benefit Elif.!ibi/ity 

Vest Comm Serv Lost I 0 - 76 & Latr Vested participant not eligible to retire under any other retirement type 

Voluntary - 30 Years Or More Participant met the requirements for 30-Year Retirement, See Section 6. 

Normal, Early, and late Retirement Dates, Subsection Early Unreduced 

Retirement (Part A and Part 8) 

Voluntary - Age 55 to 60 Not 85 Pt Participant met the requirements for 55/10 Retirement, See Section 6. 

Normal, Early, and late Retirement Dates, Subsection Early Retirement 

(Part A and Part B) 

Voluntary - Age 55 to 62 - 85 Points Participant met the requirements for 85-Point Retirement, See Section 6. 

Normal, Early, and late Retirement Dares, Subsection Early Unreduced 

Retirement (Part A and Part B) 

Voluntary - Age 60 to 65 Participant met the requirements for 60110 Retirement, See Section 6. 

Normal, Early, and late Retirement Dates, Subsection Early Unreduced 

Retirement (Part A and Part B) 

Window Retirement Age 53 to 62 Pre-DO PT retiree who retired under Plan Age 53 to 62 Window Retirement 

Window Retirement with 85 Points Pre-DO PT retiree who retired under Plan 85 Points Window Retirement 

Part A, Part B. and Part C Separate Retirement Dates and Forms of Annuity 

The plan does not require that participants choose the same date of retirement for Part A, Part B, 

and Part C benefits. The BSRS will only calculate Part A, Part B, and Part C benefits on the same 

retirement date and in the single or married form of annuity. If any participant asks to receive Part 

A, Part B, and Part C benefits on separate dates of retirement or with different annuity forms, the 

calculation will have to be done manually by ASD. Ifthe participant's benefits are affected by 

PBGC's limitations, the benefit calculation could have unusual complexities. 

Retirees in Pay with Auxiliary Disability Benefits 

The 49 retirees listed in Appendix E must elect a form of annuity for their retirement date on the 

first of the month coincident with or next following their 55th birthday. The BSRS will produce a 

benefit recalculation and a PBGC optional form of annuity worksheet for these participants. The 

FBA must enter the first of the month coincident with or next following the participant's 55th 

birthday in the field labeled "Age 55 Retirement Date'' on the data entry screen. The BSRS will not 

produce a benefit worksheet for these participants. Any participant requests for a benefit worksheet 

must be sent to the actuary. 

To produce a benefit recalculation for the Age 55 retirement benefit: 

1. 	Enter the Age 55 date of retirement in the "Age 55 Disability Retirement Date" field on the 


Participant Data Entry screen 


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Case Number: 20637000 

2. Select "Change Data" on the "Actual ARD Data in Database" screen 

3. 	Enter the Age 55 date of retirement in the "Actual Retirement Date" field on the "'Additional 

Data Needed for Recalculation at ARD" screen 

4. 	Enter the spouse and/or non-spouse beneficiary information on the "Additional Data Needed 

for Recalculation at ARD" screen 

The surviving spouse of a retiree who dies before retirement benefits commence (age 55) is entitled 

to a QPSA. The BSRS is not programmed to calculate the QPSA benefits for retirees who were 

receiving an auxiliary disability benefit on DOPT. Please send requests for these calculations to the 

actuary. 

Retirees in Pay with Deferred Part B Benefits 

The eight retirees in pay listed in Appendix V are in pay for their Part A benefits (and in some cases 

supplements) and have deferred Part B benefits. The benefit determination statement shows the Part 

A benefits payable until the Part B retirement date and the Part B benefit payable at normal 

retirement date, earliest unreduced retirement date, and earliest retirement date. 

To produce a benefit recalculation for the Part B benefit: 

1. 	Enter the Part B date of retirement in the "Part A DOR for Benes I Part B DOR for Rets" field 

on the Participant Data Entry screen 

2. 	Select "Change Data" on the ''Actual ARD Data in Database" screen 

3. Enter the Part B date ofretirement in the "Actual Retirement Date" field on the "Additional 


Data Needed for Recalculation at ARD" screen 


4. Enter the spouse and/or non-spouse beneficiary information on the "Additional Data Needed 

for Recalculation at ARD" screen 

The surviving spouse of a retiree who dies before Part B benefits commence is entitled to a Part B 

QPSA. The BSRS is not programmed to calculate Part B QPSA benefits for retirees who deferred 

payment ofthe Part B benefit. Please send requests for these calculations to the actuary. 

Beneficiaries in Pay with Deferred Part A Benefits 

The 52 beneficiaries in pay listed in Appendix Ware in pay for their Part B benefit(s) and have 

deferred Part A benefits. The earliest retirement date for the Part A benefit is the later of August 1, 

2009, and the first of the month coincident with or next following the date the participant would 

have attained age 55. The benefit determination statement shows the Part B monthly benefit as of 

DOPT and the Part A monthly benefit payable at the earliest retirement date. 

To produce a benefit recalculation for the Part A benefit: 

1. 	Enter the Part A date of retirement in the ''Part A DOR for Benes I Part B DOR for Rets" field 

on the Participant Data Entry screen 

2. 	Select "Change Data" on the "Actual ARD Data in Database" screen 

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l(b)(6) Applied to All Redactions on This Page I Case Number: 20637000 

3. Enter the Part A date of retirement in the "Actual Retirement Date" field on the "Additional 


Data Needed for Recalculation at ARD" screen 


Non-Retirees Eligible for Total and Permanent Disability Retirement 

Of the 26 non-retirees that PBGC determined were eligible for T &PD benefits discussed in Section 

11. Benefit I Plan Document Interpretations ofNote, subsection E. Post-DO PT Disability Benefit 

Eligibility, 11 were younger than age 55 at DOPT. Their benefit determination statements show the 

auxiliary benefit payable until age 55 then the retirement benefit payable at age 55 as a straight life 

annuity. Four of these non-retirees receive a benefit determination statement through the BSRS. 

Seven of these non-retirees receive manual benefit determination statements. 

These non-retirees are required to elect a retirement benefit on the first of the month coincident with 

or next following their 55th birthday. The BSRS is not able to recalculate the benefit of these 

participants at their age 55 retirement date. Please send requests for these age 55 calculations to the 

actuary. 

The following table lists the 11 non-retirees younger than age 55 at DOPT who are eligible to begin 

receiving an auxiliary disability benefit on DOPT: 

No. Participant Name Benefit Determination Age 5 5 Benefit 

Statement Recale u lation 

Manual Manual 

2 BSRS Manual 

3 Manual Manual 

4 BSRS Manual 

5 BSRS Manual 

6 Manual Manual 

7 Manual Manual 

8 Manual Manual 

9 BSRS Manual 

10 Manual Manual 

II Manual Manual 

Non-Disability Retirees with Form of Annuity Election at Age 55 

Section 10. Forms ofAnnuity, subsection Future Benefit Changes, C. 50% Spouse Coverage for 

Non-Disability retirement before Age 55, lists the 9 non-disabled retirees who are required to elect a 

form of annuity at their age 55 retirement date. All of these retirees receive manual benefit 

determination statements. The BSRS is not able to recalculate the benefit of these participants at age 

55. Please send requests for these age 55 calculations to the actuary. 

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26. Additional Comments 

A. !RC 436 

There are no IRC 436 limitations impacting benefits in this plan. See Image Viewer Docs. 

#22173 7080 and #403 732245 in Section 9C on Image Viewer for the preliminary 436 Evaluation 

and the OPSS Section 436 Evaluation. 

B. 	Bankruptcy Petition Date (BPD) 

There are no BPD issues in this plan since the most recent BPD occurred prior to September 16, 

2006. 

C. 	Grow-In Liabilities 

DISC determined that the probability ofDelphi surviving until 5 years after DOPT is 0% (Image 

Viewer Doc. #403732252). Therefore, there are no grow-in liabilities for active Delphi participants 

atDOPT. 

GM/Delphi made a number ofdivestitures and asset sales prior to DOPT. See Section 4 Divestiture, 

Sale and Asset Purchase Agreements and Section 5 Benefit Provisions Pertaining to Divestitures for 

more information about these events. A participant's service with the acquiring company after the 

divestiture or sale date sometimes counted under the Delphi plan for purposes of vesting and benefit 

eligibility, and Delphi assumed the grow-in benefit liability for this post-acquisition service. Some 

of the participants involved were actively employed with acquiring companies that were still 

ongoing as of DOPT. Consequently, some minimal PC6 grow-in liability exists for these 

participants with respect to their post-DOPT service. 

We ignored this grow-in liability in the valuation ofthe Delphi Retirement Program for Salaried 

Employees plan. We believe that no participant's benefit is materially affected by this approach for 

the following reasons: 

1. 	Assets are exhausted in PC3; therefore, they do not extend into PC6. 

2. 	This is a Non-SPARR plan. While any increase in benefit liabilities would increase the plan's 

UBLs, it would also decrease the actual recovery ratio to which UBL is applied in calculating 

the plan 4022(c) amount. 

D. 	Retroactive Annuity Starting Dares 

PBGC Policy 5.2-4, Annuity Starting Dates, Section D. 4., requires PBGC to offer participants a 

retroactive annuity starting date before the BSRS current date or the participant's actual retirement 

date if the participant is eligible for a plan-provided, unreduced early retirement benefit that is not 

reduced by the Title IV limitations. We identified 170 participants eligible for a retroactive annuity 

starting date because their Delphi early unreduced benefits are not reduced by Title IV limitations. 

These participants are listed in Appendix AM. 

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PBGC Policy 5.2-4, Annuity Starting Dates, Section D. 5., requires PBGC to offer participants a 

retroactive annuity starting date before the BSRS current date or the participant's actual retirement 

date if the participant is eligible for level or substantially level benefits as a result of Title IV 

limitations and/or asset/4022(c) allocations. We identified 389 participants eligible for a retroactive 

annuity starting date because of the level Title IV benefits they receive from the PC3 4044 

allocation. These participants are listed in Appendix AN. 

Participants eligible for a retroactive retirement date under sections D. 4. and/or D. 5. of the Annuity 

Starting Dates policy may elect to receive a retroactive retirement benefit at any time prior to 

receiving a benefit determination informing the participant of the eligibility for the retroactive 

benefits. The benefit determination will provide a 90-day window that will be the participant's final 

opportunity to request an application for the retroactive annuity starting date. 

PBGC Policy 5.2-4, Annuity Starting Dates, Section D. 7., allows PBGC to offer a QPSA 

beneficiary a retroactive annuity starting date to the later of the first ofthe month following a 

participant's death and the participant's EPRD. The policy notes that retroactive annuity starting 

dates will not be given if beneficiaries were previously offered the opportunity to commence QPSA 

benefits. We have evidence that the Delphi plan administrators routinely notified QPSA 

beneficiaries of their eligibility to receive QPSA benefits (see Image Viewer Doc. #404227811 ). 

Therefore, a QPSA beneficiary will not be eligible for retroactive annuity starting dates, unless it is 

shown that the beneficiary did not receive QPSA benefit eligibility information from the plan 

administrator. 

E. Participants with Employee Contributions whose Valuation Lump Sum is Less than or Equal to 

$5,000 

PBGC Policy 5 .11-2, Payment ofPriority Category 2 Benefits, provides that a participant with 

employee contributions at DOPT whose valuation lump sum is less than or equal to $5,000 may not 

withdraw employee contributions. The participant may either take the valuation lump sum or the 

plan annuity (without the withdrawal of employee contributions). There are seven non-retired 

participants with employee contributions at DOPT whose valuation lump sums are less than or 

equal to $5,000. The benefit determination statements for these participants do not show plan 

benefits for the withdrawal of employee contributions because it is not allowed. These participants 

are listed in the table below. 

No. 

l 

2 


3 


4 


5 


6 


7 


Valuation Lum Sum 

$844 

$4,913 

$952 

$2,924 

$2,470 

$1 508 

$1,151 

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F. Payment ofResidual Lump Sums for Participants who Withdraw Employee Contributions 

PBGC Policies 5.4-9, Lump-Sum Benefit Payments and 5.11-2, Payment ofPriority Category 2 

Benefits, provide that if a participant, not otherwise eligible for a valuation lump sum, withdraws 

employee contributions and the participant's residual lump sum is less than or equal to $5,000, then 

the participant may receive the residual lump sum in lieu of an annuity benefit. We calculated the 

residual lump sum as the value of the employer provided benefit at the participant's expected 

retirement age using PBGC lump sum rates. There are no participants in the valuation with residual 

lump sums less than or equal to $5,000. 

G. Single Participants who Died before DOPT with Employee Contributions 

There were three participants who died before DOPT, were vested, were not married, had not 

retired, and had not withdrawn their employee contributions. We discussed two participants in this 

situation with ASD. ASD decided to include records for these participants in the valuation (Image 

Viewer Doc. #403778571). Based on this decision we added a record to the valuation for a third 

deceased participant who we discovered at a later date. Their estates are entitled to receive interest 

on their employee contributions from the date of death to DOPT. The participants are shown below. 

No. 

l 

2 

3 

• • 

I I 

I I 

L_______J 

Date of Death RETST AT ID Dumm CUSNUM 

08/12/2004 2 2 900- 11-005 l 

0 [ /22/2009 2 2 266-86-5888 

07/07/2003 2 2 900-11-0052 

H Difference Between Cash Balance Bene.fit Estimation Tool (BET) and Valuation 

When the BET was created in 2010, ASD decided to calculate the cash balance benefits using the 

greater of the benefit calculated using the plan's (pre-PP A) interest and mortality assumptions in 

effect on DOPT and the post-PP A interest and mortality as described in PBGC Policy 5.12-2, 

Statutory Hybrid Plans - Valuing and Paying Benefits. 

Upon further review, ASD decided that the "greater of' calculation as described above is not 

appropriate for this plan (see e-mail dated November 14, 2014, Image Viewer Doc. #403733135). 

We calculated cash balance benefits as described in Section 5, Plan Benefit Formula Summary. 

I. Deemed Cash-Out 

Because the plan contains a deemed cash-out provision, plan liabilities do not include benefit 

accruals for non-vested participants who terminated employment before the plan's DOPT. 

J Working Retirement Violations 

OCC determined that Delphi employees at DOPT who became employees of "New Delphi" or 

"New GM" as a result of the October 2009 Delphi asset sales should not be considered employed 

with a successor employer and, thus, should not be precluded from receiving Delphi benefits from 

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PBGC, effective November 1, 2009 (see e-mail dated January 15, 2010 from Karen Morris, Image 

Viewer Doc. #403732253). 

We found 38 participants who had not terminated employment from Delphi, were put into pay in 

the 3 month period after DOPT and before November I, 2009. These participants were not entitled 

to retire until November 1, 2009. PBGC decided to recalculate these participants' retirement 

benefits using a retirement date ofNovember 1, 2009 (see Image Viewer Doc. #404260169). These 

participants are listed in Appendix AO. 

Employees of divestitures with Coordination of Benefits Agreements (see Section 5. Plan Benefit 

Formula Summary, subsection Benefit Provisions Perlaining to Divestitures) must terminate 

employment with the divested unit before receiving an early retirement benefit from PBGC. We 

found eight participants who had not terminated employment from the divested unit at which they 

were employed and who were put into pay after DOPT. PBGC decided to take these participants out 

of pay and inform the participants they may elect retirement only after they either reach Nonnal 

Retirement Age or cease employment with the divested unit at which they work (see Image Viewer 

Doc. #404260169). These participants are listed in Appendix AP. 

K. Withdrawal ofAccumulated Employee Contributions with Interest After DOPT 

The number of participants, beneficiaries, or alternate payees who have withdrawn accumulated 

employee contributions with interest after DOPT as ofMarch 1, 2015 is 1,411 (see Appendix AQ). 

We compared the amounts withdrawn (user defined field N240 for beneficiaries and alternate 

payees and N350 for participants) found in the valuation database to the amounts calculated using 

the final valuation employee contributions with interest at DOPT, net of any employee contributions 

held by the insurance companies or withdrawn before DOPT, accumulated to the withdrawal date 

using the interest factor generated by the PACSIIRL add-in function. The PACSIIRL add-in 

function computes the interest factor for a PBGC lump sum payment made after DOPT. We 

investigated the difference between the amount paid and our calculated amount that was greater 

than our administrative tolerance. 

The following 28 participants were overpaid by PBGC: 

No. 

2 

3 

4 

5 

6 

7 

Participant Name Participant Employee Withdrawal Employee Employee Overpayment 

SSN Contributions Date Contributions Contributions 

with Interest at Amount Amount Paid 

DOPT Owed at at 

Withdrawal Withdrawal 

Date Date 

$25,629.46 0410112010 $26,087.03 $26,487.60 $400.57 

$11,633.37 09101/20 IO $11,966.62 $19,620.61 $7,653.99 

$16,546.42 09101/2009 $16,584.54 $16,598.06 $13.52 

$5,644.31 04/01/2010 $5,745.08 $10,698.67 $4,953.59 

$11,486.76 08/01/2009 $11,486.76 $13,815.06 $2,328.30 

$44,402.04 06101/2013 $47,493.63 $48, 177.38 $683.75 

$8,736.45 09/01/2010 $8,986.71 $9,042.90 $56.19 

Reason 

3 

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Case Number: 20637000 

No. Participant Name Participant Employee Withdrawal Employee Employee Overpayment Reason 

SSN Contributions Date Contributions Contributions 

with Interest at Amount Amount Paid 

DOPT Owed at at 

Withdrawal Withdrawal 

Date Date 

8 $944.54 08/0 l/2012 $1,002.34 $3,108.24 $2, 105.90 2 

9 $14,741.13 12/01/2010 $ l 5,229.43 $20,852.91 $5,623.48 4 

10 $72,289.41 0410112010 $73,580.02 $89,119.18 $l5,539.16 

I l $9,237.20 07/01/2010 $9,466.40 $9,525.57 $59.17 

12 $25,916.50 09/01/2009 $25,976.21 $25,997.38 $21.17 

13 $8,429.16 08/0112009 $8,429.16 $11,567.94 $3,138.78 

14 $9,758.25 08/01/2010 $10,019.76 $10,051.03 $3 l.27 

IS $6.410.00 09101/2009 $6,424.77 $6,430.00 $5.23 

16 $36,368.66 04/01/2010 $37,017.96 $37,133.33 $115.37 I 

17 $797.92 12/01/2010 $824.35 $12,974.08 $12,149.73 4 

18 $9,845.63 08/0 l/2010 $10,109.48 $24,052.96 $13,943.48 I 

19 $28,692.91 09/01/2009 $28,759.02 $28,782.45 $23.43 

20 $4,378.66 04/01/2010 $4,456.83 $8,037.99 $3,581.16 

21 $8,104.87 02/0112011 $8,397.45 $8,420.75 $23.30 

22 $5,382.66 04101/2010 $5,478.76 $16, 179.80 $10,701.04 

23 $26 916.24 09101/2010 $27,687.28 $33,259.86 $5,572.58 l 

24 $16,730.39 09101/2009 $16,768.94 $16,782.61 $13.67 1 

25 $162.64 08/01/2012 $172.59 $729.02 $556.43 2 

26 $10,772.47 09/01/2009 $10,797.29 $10,806.08 $8.79 1 

27 $0.00 09/01/2011 $0.00 $10,666.04 $10,666.04 5 

28 $13,772.08 09/01/2009 $13,803.81 $13,815.06 $1 1.25 

• In addition to the overpayment of the employee contribution lump sum, these participants' current monthly benefits in 

pay change. 

Reason 1 - Employee contributions with interest at DOPT were incorrectly calculated by Fidelity 

Reason 2 -Amount paid is the lump sum value of the Part B benefit at DOPT plus interest to the 

payment date rather than the employee contributions with interest 

Reason 3 - Employee contributions with interest at DOPT used to process lump sum payment 

included employee contributions held by Insurance Companies as part of purchased 

annuity 

Reason 4 - Employee contributions with interest at DOPT used to process lump sum payment 

included employee contributions withdrawn before DOPT 

Reason 5 - All employee contributions wi.th interest were withdrawn before DOPT and paid again 

in error by PBGC after DOPT 

The following seven participants were underpaid by PBGC: 

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l(b)(6) Applied to All Redactions on This Page I Case Number: 20637000 

No. Participant Name Participant Employee Withdrawal Employee Employee Underpayment Reason 

SSN Contributions Date Contributions Contributions 

with Interest Amount Amount Paid 

at DOPT Owed at at 

Withdrawal Withdrawal 

Date Date 

$25,961.89 04/01/20I0 $26,425.40 $26,414.32 $I 1.08 


2 
 $41,488.16 04/0112010 $42,228.86 $42,187.98 $40.88 

3 $4,044.67 01/01/2015 $4,445.92 $4,075.59 $370.33

$110)12.93 04/01/2010 $112,282.38 $111,831.54 $450.84 


5 


4 

$17,562.34 08/01/2010 $18,032.99 $18,022.04 $10.95 


6 
 $8,948.61 09/01/2011 $9,393.68 $9,337.76 $55.92 


7 
 $23,203.91 12/01/2011 $24,439.17 $24,365.72 $73.45 2 

"' In addition to the underpayment ofthe employee contribution lump sum, these participants' current monthly benefits 

in pay change. 

Reason 1 - Employee contributions with interest at DOPT were incorrectly calculated by Fidelity 

Reason 2 - Employee contributions with interest at DOPT were incorrectly calculated by PBGC 

L. Methodfor Determining Termination Monthly Benefits 

The termination monthly benefit for a participant in pay status on DOPT is equal to the plan 

monthly benefit multiplied by the present value of termination benefits divided by the present value 

of plan benefits. This method preserves the "shape" of the annuity in pay status on DOPT. 

The termination monthly benefit for a participant not in pay status on DOPT is equal to the Title IV 

monthly benefit multiplied by the present value oftermination benefits divided by the present value 

of Title IV benefits. This method results in a stable PC3 benefit regardless of the participant's 

elected retirement date. 

OCC approved the methods described above. Please see the memorandum found in Image Viewer 

document #404107519. 

M. Present Value used to Calculate the Taxable/Non Taxable Portion ofthe Plan Benefit 

In order to determine the taxable and nontaxable portion of a refund of mandatory employee 

contributions, the present value of the associated benefit is needed by PBGC plan administrators. 

OCC provided guidance that, for the purpose of determining the taxable/nontaxable portion of the 

plan benefits in the Delphi Salaried plan, the present value of only the participant's Part B Primary 

and Part B Supplementary termination benefits using PBGC annuity rates are to be used in the 

denominator of the exclusion ratio (see Image Viewer Doc. #403762513). This present value is 

sho'-"11 on the last page of a participant's benefit statement worksheet. 

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N. 	Separate Databases for ADTIIP VFB and BSRS!Benefit Administration 

Due to the complexity of the Delphi Salaried plan benefits, the Delphi Salaried plan valuation was 

developed by assigning ACT data fields to benefits in a manner that best facilitated the ACT BSRS 

system and ongoing benefit administration. PBGC's ADT and IPVFB systems require particular 

assignment of benefit data to ACT data fields that differ from the field assignment used for the 

BSRS and ongoing benefit administration. We created an additional database that meets the field 

requirements of ADT and IPVFB. Both databases will be submitted for the case software closeout. 

For more information regarding the specifics regarding the two databases see Image Viewer Doc. 

#404258414. 

0. ASEC Manufacturing, Delphi Mechatronic Sys/ems, and PHI Non-Bargaining Transfers 

Participants who transferred to or from Delphi and three Delphi subsidiary companies [ASEC 

Manufacturing (PBGC Case Number 21102100), Delphi Mechatronic Systems (PBGC Case 

Number 20700700), and PHI Non-Bargaining Retirement Plan (PBGC Case Number 21102700)1 

were governed by the transfer agreements between Delphi and each subsidiary. The 135 Packard 

Hughes Interconnect employees are listed in Appendix H. The five ASEC Manufacturing 

employees and three Delphi Mechatronic Systems employees are listed below. 

No. 

2 

3 

4 

5 

6 

7 

8 

ASEC Manufacturin 

ASEC Manufacturin 

In general, the transfer agreements provided the following: 

1. 	Combined service is used to determine retirement eligibility and vesting under the Delphi and 

subsidiary pension plans. 

2. 	Retirement benefits from each company are based on credited service earned while working for 

the company. 

3. 	 Earnings at the final employing company are used to calculate retirement benefits under both 

plans. 

P. 	Transfers between Delphi Salaried and Delphi Hourly Plans 

Participants who transfer from hourly employment to salaried employment have both Part A and 

Part B benefits paid from the Delphi Salaried plan based on service using combined hourly and 

salaried service. The Delphi Hourly-Rate Employees Pension Plan (PBGC Case Number 20637100) 

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l(b)(6) Applied to All Redactions on This Page I Case Number: 2063 7000 

would not pay these participants a benefit because the entire Part A benefit accrued under both 

plans is paid by the Delphi Salaried plan. 

Participants who transfer from salaried employment to hourly employment retain Part B benefits in 

the Delphi Salaried plan (ifthe participant made employee contributions). The entire Part A benefit 

accrued under both plans is payable from the Delphi Hourly-Rate Employees Pension Plan. 

The basic principle applied is that a participant's Part A benefit moves with the participant 


throughout his employment history and is paid by the plan the participant is active in at the 


participant's final termination of employment date. 


Note the same rules above for transfers between the two plans are also applied to participants who 

break service in one plan and are rehired in the other plan. Thus, if a salaried participant terminates 

salaried employment and 4 years later is rehired into hourly employment, the participant's entire 

Part A benefit accrued under both plans will be paid by the Delphi Hourly-Rate Employees Pension 

Plan. 

The plan no longer required the transfer of Part A benefits between plans with the introduction of 

Part C (Cash Balance) benefits for rehires on or after Janu 1 2001. There is one participant in 

the salaried plan affected by this rule. terminated salaried employment 

on December 31, 2002. He was rehired as an hourly employee on December 11, 2006. Because he 

was rehired after January 1, 2001, the Part A benefits he accrued as a salaried employee did not 

transfer to the Delphi Hourly-Rate Employees Pension Plan. His Part A benefits are retained by the 

Delphi Salaried plan. The Cash Balance benefit he earned as an hourly employee after December 

11, 2006 is paid by the Delphi Hourly-Rate Employees Pension Plan. 

Appendix I lists the 73 participants and beneficiaries who have a benefit in both the Delphi Salaried 

plan and the Delphi Hourly-Rate Employees Pension Plan. 

27. Expense Loading 

(1) Number of Participants= 19,933 

(2) PVPBL Without Load = $4,491,304,497 

(3) Initial Annuity Interest Rate= 0.0531 

(4) p = 1% + [(3)- 7.5%] I IO= .781% = 0.00781 

(5) Amount of Load= $10,000 + [(2) - $200,000] x (4) + [$200 x (1)] = $39,072,126 

(6) Expense percentage= (5) I (2) =0.0087 = 0.87% 

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Case Number: 20637000 

28. LiabilitywWeighted Average Age I Liabilities Excluding Expense Loading 

Average W.e1ghted A T J!.e a bl e:

(l) 

Number 

(2) 

Group 

(3) 

Average ANB at DOPT 

Weighted by 

PY of Termination 

Benefits 

(4) 

Average XRA 

Weighted by 

PV of Termination Benefits 

8,040 

Retirees, Beneficiaries, and Alternate 

Payees 62.I -----­

3,795 

Separated Vesteds and Deferred 

Beneficiaries 50.5 58.6 

8,098 Active V esteds 51.5 57.8 

0 Non-V esteds .......... -----­

. '[" . L1ab1 1t1es Exe I u ct· mg Expense Loact·mg:

(l) 

No. 

(2) 

Group 

(3) 

Present Value 

ofTitle IV 

Benefits 

(4) 

Present Value of 

Unfunded NonGuaranteed 

Benefits 

(5) 

Present Value of 

Total Benefit 

Liabilities 

(3) + (4) 

(6) 

Present Value 

of 4022(c) 

Benefits 

(7) 

Present Value of 

Termination 

Benefits 

(3) + (6) 

8,040 

Retirees and 

Beneficiaries $2,674,822, 734 $293,650, 789 $2,968,473 523 $31,667,4 l 0 $2,706,490, 144 

3,795 

Separated 

Vesteds and 

Deferred 

Beneficiaries $216,991,33 l $4,047, 160 $221,038,491 $138,771 $217' 130, 102 

8,098 Active Vesteds $1,082,462,574 $219,329,909 $1,301,792,483 $8,005,009 $1,090,467,583 

0 Non-Vesteds $0 $0 $0 $0 $0 

19,933 TOTAL $3,974,276,639 $517,027,858 $4,491,304,497 $39 811,190 $4,014,087,829 

LS TERM Total: 

LS_ TERM Total for all Participants 


TOTAL: I $4,069,697,195 


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