ggffiacce A 

1200 K Street, N.W., Washington, D.C. 20005-4026 

Pension Benefit Guaranty Corporation 

JUL 2 8 2004 

Re: 1 Case 192633, The Singer Company - Sewing Salaried 

Employees Retirement Plan ("Plan") 

The Appeals Board has reviewed your appeal of PBGC's Septembers, 2003 determination 

that you are entitled to a monthly benefit of $813.28, which is less than the $1,722.26 estimated 

benefit you are receiving. For the reasons discussed below, the Appeals Board changed PBGC's 

determination by finding that your benefit should be based on your total Years of Credited Service 

under the Plan's Final Average Earnings ("FAE") benefit formula. 

PBGC's Insurance Operations Depamnent ("IOD"), the organization responsible for 

determining and paying PBGC benefits, will send you a new determination. 

Your September 9, 2003 letter of appeal said that you believe PBGC's determination is 

incorrect because PBGC did not use your total 33 years and 11 months of service with Singer to 

calculate your benefit. In accordance with established PBGC procedures, we forwarded a copy 

of your lener to the IOD Authorized Plan Representative to provide you with a more detailed 

explanation of how PBGC calculated your benefit. 

IOD responded on November 7, 2003, explaining that PBGC credited all 33 years and 

11 months of your service with Singer in determining your benefit and that your PBGC benefit 

was calculated in two parts: the first 24 years and 9 months of your service, Auyst 3, 1959 to 

June 1, 1984, were credited under the Plan's fiozen benefit formula, which was in effect until 

July 18, 1986, and the other 9 years and 2 months, July 15,1991 through August 24,2000, were 

credited under the FAE formula. PBGC also explained that Singer had incorrectly calculated 

your estimated accrued benefit by crediting all of your service under the FAE formula. IOD's 

letter also gave you 30 days to provide the Appeals Board with specific reasons if you still 

believed PBGC's determination was incorrect. 

On November 12, 2003, you supplemented your appeal filing, stating that you believe 

PBGC's determination is incorrect because Singer management had advised you on several 

occasions that your years of Credited Service would be bridged for purposes of calculating your 
! benefit under theFAE formula, and you provided several leners from the prior Plan Administrator 

$4 to support your claim. You also questioned the correctness of the $290.42 per month frozen 

; benefit amount shown on your PBGC benefit statement, noting that this would not be an issue if 

your benefit is calculated under the FAE formula using all of your Credited Service. z 

The Plan, as amended and restated effective January 1, 1989, was in effect when the Plan 

terminated on August 24, 2000, and is the governing Plan document. The following provisions 

of the Plan are relevant to your appeal: 

Section 2.5 - Recreditinn of Credited Service 

If a Participant who has no Nonforfeitable right to Retirement Income incurs a 

One-year Break in Service, Years of Credited Service earned prior to the One-Year 

Break in Service shall be disregarded after the consecutive number of One-Year 

Breaks in Service equals or exceeds five (5) years. In all other cases, the 

reemployed Participant shall be credited with his prior Years of Credited Service 

upon his reemployment with the Employer. [Emphasis added.] 

Section 4.1 - Noml Retirement Benefir 

(A) The amount of annual Retirement Income payable to a Member, computed 

with respect to his Normal Retirement Date, shall be: 

(i) For Participants who earn Years of Credited Service on or after 

January 1, 1991, equal to 1 118% of his Average Earnings multiplied by his 

total Years of Credited Service. 

(ii) For Participants who do not earn Years of Credited Service on or after 

January 1, 1991, the sum oE 

(1) 1 118% of his earnings for each Year of Credited Service performed 

after December 3 1, 1988, and 

(2) his benefit accrued pursuant to Section 4.1 of the Prior Plan as of 

December 31, 1988. 

PBGC records show that when your first period of employment with the Company ended 

on June 1, 1984, you were vested under the Prior Plan with 24 years and 9 months of Credited 

Service. Therefore, as provided under Section 2.5 of the Plan, when you were reemployed by 

the Company on July 15, 1991, you were credited with all your prior Years of Service. The 

records further show you earned an additional 9 years and 2 months of Credited Service after 
January 1, 1991. Thus, the Appeals Board found that based on section 4.1(A) (i) of the 1989 

Plan, your Retirement Income is to be calculated under the FAE formula using 33 years and 

1 i months of Credited Service, which covers both periods of your employment with the Company. 

We will forward a copy of this lener to PBGC's Insurance Operations Department, who 

will send you a new determination, with a new 45day appeal right. We appreciate your patience 

while PBGC completes the processing of your case. Meanwhile, if you need other information 

from PBGC, please call our Customer Contact Center at 1-800-400-7242. 

Sincerely, 

Sherline M. Brickus 

Member, Appeals Board