Protecting America's Pensions 

Pension Benefit Guaranty Corporation 

t 200 K Street, N.W., Washington, D.C. 20005-4026 

September 16, 2009 

Re: I ~owe International Retirement 

Plan for Lodge 475; Appeals decided in this decision: 

Dearl L--_~~' 

The Appeals Board of the Pension Benefit Guaranty Corporation ("PBGC") has 

reviewed your appeal on behalf of the D participants of the Rowe International 

Retirement Plan for Lodge 475 (the "Rowe Plan" or "Plan") listed above. For the reasons 

summarized immediately below and discussed in more detail later, we determined that 

we must deny your appeal. 

The Board determined that the plain language of the Plan, specifically the 

language in Article 6, is consistent with how PBGC calculated the appellants' benefits. 

The Plan's defined benefit insured by PBGC is the "Supplemental Plan" benefit, and 

Article 6 of the Plan defines how this Supplemental Benefit is calculated. The Board 

considered your contention that a prior early retirement calculation supported a different 

interpretation, but we were able to locate two other prior retirement calculati()ns, 

.;;, including one done for an appellant, that supported PBGC's interpretation of the Plan 

language. Both the Board's own actuary and an actuarial consultant provided further 

input into why your proposed interpretation is incorrect. Ultimately, the Board 

determined that PBGC's interpretation of the Plan's Article 6 language is correct and 

consistent with two of the three most relevant retirement calculations we were able to 

review. 

While we found that PBGC's methodology for calculating benefits was correct, 

we found an error that will result in a benefit increase for four of the six appellants. To 
calculate the normal retirement benefit, PBGC should have used the Basic Account value 

at the Normal Retirement Date ("NRD"); instead, PBGC erred by using the Basic 

Account value at the end of the NRD calendar year. This error is more fully explained in 

our decision. 

A summary of each appellant's correct benefit is at Appendix 1. New benefit 

statements for all six appellants are also included at Appendix 1, 

INTRODUCTION. 

PBGC is the United States government agency that provides pension insurance in 

accordance with the Employee Retirement Income Security Act of 1974, as amended 

("ERISA"). If a plan sponsor is unable to support its pension plan, PBGC becomes 

trustee of the plan and pays pension benefits as defined in the plan, subject to legal 

limitations set by Congress under ERISA. 

On November 12, 2003, the Plan terminated without sufficient assets to provide 

benefits guaranteed by PBGC under Title IV of ERISA, and PBGC became trustee of the 

Plan. 

The Plan had only six participants - all in the "separated vested" category, and 

you represent all 6 of these individuals. PBGC determined the total value of Title IV 

benefits payable by PBGC was $73,354, and Plan assets only covered $64,721 of this 

amount. I PBGC sent initial (formal) benefit determination letters to the six appellants in 

early April 2008.2 We note that none of the six appellants have yet retired. 

. After requesting and obtaining an extension of time to appeal, you filed a timely 

II-page Appeal Brief ("AB") with three tabbed enclosures on June 26, 2008. We 

docketed individual appeals on behalf of each appellant, pursuant to our standard 

policies. 

The Appeals Board exercised its discretion under section 4003.56 of PBGC's 

regulations and consolidated the appeal that you filed on behalf of these six individuals. 

I See page 1 of the full 6-page PBGC Actuarial Case Memo at Enclosure 1. 

2 Part 4003 of PBGC's regulations establishes the rules governing PBGC's issuance of 

v~ initial (formal) benefit determinations and the procedures for requesting and obtaining 

administrative review. 29 Code of Federal Regulations ("C.F.R.") § 4003 (titled "Rules 

for Administrative Review of Agency Decisions"). An initial (formal) benefit 

determination is the letter PBGC issues to communicate the Agency's determination of 

an individual's benefit. See 29 C.F.R. § 4003.21. If the individual desires Appeals Board 

review of his or her benefits, the individual or his or her representative must file an 

appeal of the Agency's determination, or a request for an extension of time, within 45 

days from the date of issuance of the benefit determination. See 29 C.F.R. § 4003.4, 

4003.52. 

2 
The Board concluded that the respective appeals arise out of the same or similar facts and 

that they seek the same or similar relief. 

SUMMARY OF THE ISSUE RAISED IN YOUR APPEAL. 

The entire issue raised in your appeal is whether PBGC has used the proper 

method for calculating the Basic Retirement Benefit for a Participant who is eligible to 

retire early - before the age of 65.3 The Basic Retirement Benefit is the defined 

contribution portion of the Plan benefit - which is not insured by PBGC. The Basic 

Retirement Benefit must be calculated and is then offset (deducted) from the 

Supplementary Retirement Benefit. As with any offset type pension calculation, the 

lower the Basic Retirement Benefit deduction, the higher the Supplementary Retirement 

Benefit. You argue for a methodology that results in a lower Basic Retirement Benefit 

deduction and a higher Supplementary Retirement (PBGC) Benefit for your clients. 

The key claim of your appeal is at page 6 of the Appeal Brief. You state that 

when a participant " ... decides to take [the] "Supplementary Benefit" as an early 

retirement benefit, the amount is calculated using a two-step process, first applying 

Article 6.2 (a) and (b), and then applying Article 8, specifically Article 8.2 (a) or (b)." 

AB at 6. Your contention is that in cases of early retirement (whether under Article 8's 

definition of early retirement or for deferred vested participants with 10 years of service 

and eligible for early retirement under Article 11), the Article 6.2 (c) provision requiring 

use of the "Life Rate" at normal retirement age does not apply. AB at 1 and 6. We note 

that PBGC applied Article 6 in its entirety, including Article 6.2(c) to calculate the 

Supplementary Retirement Benefit. 

The term "Life Rate" is not defined by the Plan, yet you used this tenn frequently 

in your appeal. For example, you contend in your Appeal Brief, "the difference between 

the PBGC's and the participants' positions concerning the benefit determinations issued 

[for the Rowe Plan] is whether the offset of the Supplementary Benefit should be 

calculated using the Life Rate at the Nonnal Retirement Date (the first month after age 

65) or the Life Rate at the Early Retirement Date (the first month after qualifying for 

Early Retirement), which is different for each individual." AB at 1. 

We interpreted your use of the phrase "Life Rate at the Normal Retirement Date" 

to mean the actuarial factor used to calculate an annuity value with payment starting at 

age 65, We interpreted your use of the phrase "Life Rate at the Early Retirement Date" 

to mean the actuarial factor used to calculate an annuity value with payment starting at 

the early retirement date; this would result in an immediate annuity payable at the early 

retirement date. 

3 Under Plan Article 8.1, a Participant is eligible for an Early Retirement Benefit after 

attaining age 55 and having at least 10 years of vesting service. Likewise, a deferred 

vested participant with 10 years of vesting service is also eligible for early retirement, as 

early as age 55, under Plan Articles 11.2 and 11.3. 

3 
You state that "all of the known past applications of this Plan supports the 

participants' contention that the Life Rate at the Age of Retirement, and not at age 65 

(Normal Retirement Age) has been used by the Plan." AB at 2. To support you appeal, 

you provided information on past Plan calculations for two former Plan participants: 

I I Their calculations are at Tabs Band C of 

your Appeal Brief. Y ou stated that using the Life Rate at the Age of Retirement, in the 

case of one appellant, I for example, would result in him receiving 

"over $6,000 per year." AB at 2. 

Specifically, you contend that appellants should have their benefits calculated as 

follows: 

• "... I I benefit should be 

calculated using Article 6.2(a), then 6.2(b) and then S.2(b). Article 6.2(c) 

should not be used." AB at 9. You contend that to do otherwise would be 

inconsistent with the way the Plan calculated benefits for two former (and 

now retired) participants. 

• You contend that due to confusion in I Iwork history, "his 

Early Retirement Date should be November 11, 2003, the Life Rate for the 

reduction should be calculated using that date, and he should be paid 

retroactive benefits to that time." AB at 10. You believe the early 

retirement reduction of 1/4% per month would extend back to that date. 

~------------------------~ 

you have identified them as eligible 

for a deferred vested benefit as early as age 55 and you ask that ". . . their 

offsets should be similarly calculated. No other result is consistent with 

the past application of the confusing terms of this Plan." AB at 11. 

Based on our review and for the reasons stated below, we find that PBGC's 

interpretation of Article 6 is supported by the Plan's plain language and the relevant 

calculations we have reviewed. 

DISCUSSION. 

The Appeals Board has completed an extensive review of the Plan documents, 

PBGC records, and the claims you have made in the appeal. 4 We have also examined 

Plan practice in the case of 1 rentioned above and a third 

former participant, who we will not name in accordance with the Privacy Act. We were 

4 None of the 6 Plan participants were affected by any of the PBGC legal limits generally 

affecting participants. See Sections 6 - 9 of the Actuarial Case Memo, Enclosure 1. As 

noted above, the sole issue in your June 26, 200S appeal is whether PBGC's 

interpretation ofthe Rowe Plan, as explained above, is correct under the Plan's terms. 

4 
also able to obtain from a prior Plan actuary early retirement calculations in the case of 

I lone of the appellants. Finally, we also had an actuary from the Board's 

consultant actuarial firm, Bolton Partners, Inc., review this appeal, including the benefit 

calculations. Our analysis and findings are outlined next. 

PBGC's Interpretation of the Plan Document 

In its Actuarial Case Memorandum at Section 5, PBGC's "Interpretations of 

Note" contains the following explanation of the Rowe Plan and how PBGC interpreted it: 

This plan has two parts: Basic Plan and Supplementary Plan. The 

Basic Plan is of the defined contribution type and the account balances under 

it were distributed to participants in April 2005. 5 The account balance under 

the Basic Plan is converted to an annuity and this annuity serves as an offset 

in the Supplementary Plan formula. Based on plan provisions and with the 

guidance of ASD and OPSS [internal actuarial and policy divisions within 

PBGC], we developed the account balance as of NRD, converted it to an 

immediate annuity payable at Normal Retirement Date (NRD), and used the 

converted amount as the offset to develop an accrued benefit payable at age 

65 (see section 16 for more explanation). The accrued benefit was then 

adjusted for early retirement and form of payment. Following plan 

provisions, we used an immediate annuity conversion factor based on the 

plan's definition of actuarial equivalence (for other than lump sum 

determinations): 1971 GAM male mortality table projected with Scale E to 

1978 and 6% interest. This follows our reading of the plan document 

(particularly Sections 6.2 and 8.2 and how DISC [PBGC's Department of 

Insurance Supervision and Compliance] initially analyzed the plan. This 

results in a large offset and a very small benefit payable. No actual 

calculations were available. 

See Enclosure 1, Actuarial Case Memo, pages 2-3. 

Plan Provisions 

We started our independent analysis by reviewing the Plan language. The basis 

for the benefit calculation begins with Article 6 of the 2001 Restatement which outlines 

the calculation procedure for the Supplementary Retirement Benefit. The Supplementary 

Benefit, while somewhat of a misnomer, is the Plan's term for the defined benefit insured 

'" . and administered by the PBGC. You acknowledge this distinction in your appeal. 

5 We note that your appeal states: "The participants, I am advised, have already received 

the Basic Benefit under Article 5 (the defined contribution account), and they are now 

seeking the defined benefit part of the plan which has been confusingly mislabeled the 

'Supplementary Benefit. ,,, AB at 6. 

5 
Article 6 of the Rowe Plan is titled "Supplementary Retirement Benefits" and 

states in its entirety: 

6.1 This Article Generally. In addition to the benefits under the 

Basic Plan provided in Article 5, the Plan provides benefits under the 

Supplementary Plan contained in this Article. 

6.2 Amount of Benefits. Subject to the other provisions of the 

Plan, the amount of Supplementary Retirement Benefits payable to an 

eligible Member shall be equal to: 

(a) 2 Y2% of his Average Monthly Compensation multiplied by his 

Credited Service, up to a maximum of20 years of Credited Service; less 

(b) 4 116% of his Primary Social Security Benefit multiplied by his 

Credited Service, up to a maximum of20 years of Credited Service; less 

(c) The monthly retirement benefit which can be provided on an 

Actuarial Equivalent life annuity basis from the Account balance of the 

retiring Member as of his Normal Retirement Date under the Basic Plan; 

and less 

(d) The Actuarial Equivalent of any amounts previously distributed to 

the Member under the Supplementary Plan or the Basic Plan, due to the 

Member's prior withdrawal, termination, disability, or retirement. 6 

6.3 When Benefits are Paid. Supplementary Retirement Benefits 

shall be paid when a Member qualifies to receive benefits under the terms 

of Articles 7 through 11. 

Our interpretation of the Plan's Language in Article 6 

To determine the amount of the Supplementary Benefit payable, Plan Article 6.2 

states that the gross benefit provided by the Supplementary Plan under 6.2(a) will be 

reduced by both a calculation related to the participant's Primary Social Security Benefit 

(6.2(b» and by "[t]he monthly retirement benefit which can be provided on an Actuarial 

Equivalent life annuity basis from the Account Balance of the retiring Member as of his 

Normal Retirement Date under the Basic Plan ... " (Article 6.2(c». The actuarial 

equivalent of the Basic Plan Account Balance is determined as of the Normal Retirement 

Date. Thus, the Plan language itself identifies the Normal Retirement Date as the date at 

which the monthly retirement benefit derived from the Basic Plan Account Balance is 

determined. 

PBGC's decision, as noted in the Actuarial Case Memorandum at Section 5 

(discussed above), to calculate the Basic Account Balance as of the Normal Retirement 

Date is clearly supported by the plain language in Plan Article 6.2(c). 

6 We are not aware of any prior distributions involved in this case; thus, this provision is 

generally not relevant to our review. 

6 
Your Key Contention is that Article 6.2(c) does Not Apply 

Your contention, however, is that " ... the Supplementary Benefit is calculated 

differently, depending on whether the retirement is early, normal, late, or deferred." AB 

at 4. As discussed earlier, you contend that Article 6.2 (specifically 6.2(c)) is only 

applicable when calculating the Normal Retirement Benefit under Article 7. You assert 

that the Supplementary Benefit for early retirement is calculated using Article 8.2. AB at 

4. 

We note that all six appellants are eligible for an early retirement benefit either 

directly under Article 8 or as a deferred vested beneficiary under Article 11.7 Thus, we 

also looked at the Plan language in Article 8 in examining your appeal. 

Article 8 Plan Language 

Article 8 of the Rowe Plan is titled "Early Retirement Benefit" and states in part: 

8.1 Eligibility for Benefit. 

A Participant or an Inactive Participant shall have a nonforfeitable 

right to an Early Retirement Benefit if his Termination of Employment 

occurs after attaining Early Retirement Age, but before attaining Normal 

Retirement Age. 

"Early Retirement Age" means the age at which a Participant has 

attained age 55 and completed at least ten years of Vesting Service." 

8.2 Amount of Benefit. 

The monthly pension benefit payable to a Participant who is 

entitled to an Early Retirement Benefit shall be an amount equal to: 

(a) His Supplementary Retirement Benefit determined as of 

his Early Retirement Date if payment of his pension commences as of his 

Normal Retirement Date; or 

(b) His Supplementary Retirement Benefit determined as of 

his Early Retirement Date, reduced for each month his pension starts 

before his Normal Retirement Date. The reduction shall be 'l4 of 1 % for 

each month before age 65 the pension is to be paid. Payment of this 

amount shall continue during the life of the Participant without change at 

the Participant's Normal Retirement Date. (emphasis added) 

7 Under Article 11.3 a deferred vested participant " ... with at least ten years of Vesting 

Service may elect to have his pension benefits commence at any time between age 55 and 

his Normal Retirement Date." Under Article 11.2, " ... if the Participant elects under 

Section 11.3 to have his pension benefits commence before his Normal Retirement Date, 

the Participant's benefits shall be reduced in the same manner as an Early Retirement 

Benefit, as described in Section 8.2(b)." 

7 
Our Interpretation of the Key Article 8 Language 

The key language you rely on is highlighted in italicized text above. Both Article 

8.2(a) and 8.2(b) use the phrase: "His Supplementary Retirement Benefit determined as 

of his Early Retirement Date ... " regardless of whether the pension starts at age 65 

(NRD) under 8.2(a) or whether the pension starts before NRD under Article 8.2(b). 

This phrase is subject to varying interpretations. The Board's interpretation is 

that the phrase means that the Supplementary Retirement Benefit is determined (under 

Article 6 provisions) using the Basic Plan Account Balance as of the Early Retirement 

Date. We recognize your interpretation is different. 

Under your interpretation of Articles 8 and 11, anyone with 10 years of vesting 

service (whether as an early retiree under Article 8 or a deferred vested retiree under 

Article 11) would earn a higher pension benefit than someone who came up just short of 

10 years vesting service, yet worked until normal retirement age at 65. In other words, 

under your interpretation, anyone with 10 years of service has their Supplementary 

Retirement Benefit calculated differently than what Article 6 provides. Such a two-tier 

Supplementary Retirement Benefit scheme is not supported anywhere in the Plan 

language. 

Prior Plan Benefit Calculations Submitted with Your Appeal 

You orovided two prior plan calculations for former participants, 1,------------, ~ ____ _____'I to support your appeal claims. We will discuss the benefit calculation 

for first and explain why we do not think it is relevant. 

We note that the calculation fori ~t Tab C of your Appeal involves a 

participant who retired in May 1993 at age 68 with a "Late Retirement" benefit under 

Article 7.2(b). Because I I deferred retirement beyond his Normal Retirement 

Date, the late retirement calculation, which was done by Hewitt Associates, does not 

offer insight into relevant Plan practice for participants with an Early Retirement Benefit. 

The provisions surrounding late retirement benefit calculations differ in actuarial 

principles from early retirement calculation procedures. Thus, we are unable to conclude 

that this practice supports your claims for the six appellants - none of them have yet to 

defer retirement past their Normal Retirement Date. 

Regarding the calculation for j 1 at TAB B of your Appeal, we note 

that he retired in 1987, over 16 years before the Plan terminated. 

In reviewing 1 I calculation, we noticed that the Basic Plan Account 

was determined using an immediate annuity factor at the actual (early) retirement date, 

which was prior to the Normal Retirement Date; the net Supplementary Plan Benefit is 

further reduced for early distribution. We do not think this interpretation of Plan 

language is correct or reasonable. In fact, our Actuary for the Board, 1 

~-----~ 

confirmed this conclusion. His findings are at Appendix 2. 

Even if we concluded that the I Icalculation supported the appeal claim 

raised by you, it is only one calculation - done 16 years prior to Plan termination. We 

wanted to consider whether other prior early retirement calculations could be found. 

8 
Our Independent Efforts to Find Other Insights into Early Retirement Calculations 

In an effort to obtain other prior calculations that would be helpful in answering 

your appeal, we contacted the Benefits Manager at Rowe listed on the first page of Tabs 

Band C of your appeal and a number of actuaries listed if the calculation sheets. In 

addition, our consultant actuary,1 I also contacted _ I at Hewitt 

Associates. Hewitt was the plan actuary prior to the plan's termination; [ r was 

the senior actuary assigned to the Rowe Plan. While he had no more examples of past 

calculations, he was in a position to offer our consultant actuary additional insight into 

the correct calculation procedures. 

,-----_----=-cA=;fter discussing the matters raised in your appeal with our consultant actuary, 

"----__ ~I reviewed the applicable plan provisions. His interpretations were consistent 

with PBGC's that the Plan intended to offset the Basic Benefit at Normal Retirement and 

reduce any net benefit for early distribution at a rate of '14 of 1 % for each month that the 

distribution precedes age 65. 

We contacted the Benefit Manager who provided us a packet of information, 

apparently also sent to you, on a former Rowe Plan participant who is not an appellant. 

We cannot disclose this individual's name in accordance with the Privacy Act. We will 

refer to this participant as the "Unnamed Former Participant." 8 

The handwritten calculations in the case of the Unnamed Former Participant are 

for an Early Retirement Benefit five months prior to age 65. This is the exact scenario 

raised in the appeal, and this Plan calculation was done in the late 1990s, much closer to 

Plan termination than the calculation you provided. 

The methodology used to calculate the Unnamed Former Participant's expected. 

Early Retirement Benefit at age 64 and 7 months includes calculating the "Deferred to 

Age 65 Life Annuity" value of the Basic Account. This age-65 annuity amount, also 

referred to on the calculation document as the "Annuity Equivalent of Basic Account 

payable at Age 65" is subtracted from the Accrued Supplementary Benefit to reach a final 

age-65 retirement benefit. This age-65 benefit is then reduced by l!4 of 1 % for each 

month of the (5 months) early retirement. The Unnamed Former Participant's 

handwritten early retirement estimate reflects the calculation of the Supplementary 

Benefit pursuant to the plain language in Article 6, not the methodology you advocate in 

the Appeal Brief. This evidence strongly supports the PBGC's interpretation of the Plan 

documents. 

In addition to the prior calculation of an Early Retirement Benefit in the Unnamed 

¥C Former Participant's case, the Board received from the Hewitt Associates actuary 

mentioned above, a one-page pension calculation on I ~ne of the 

appellants. See Enclosure 2. Again, the calculation in the case ofl lapparently 

8 Based on fax cover sheets provided us by the Benefit Manager, we believe you may 

have received the calculations on the "Unnamed Former Participant." 

9 
done in early 2002, reflects the calculation of the Supplementary Benefit pursuant to the 

plain language in Article 6, not the methodology you advocate in the Appeal Brief.9 

Our Actuarial Consultant Review of Your Appeal Revealed an Error 

The Appeals Board currently contracts with an Actuarial Services firm, Bolton 

Partners, Inc., to do consultant actuarial work, when requested. We asked our actuarial 

consultant with Bolton Partners, Inc., who is familiar with PBGC policies and 

procedures, to review this case. The actuarial consultant reviewed your entire appeal, 

including attachments. He also had access to all of PBGC's records and actuarial 

databases in this case. Finally, we provided him all of the additional calculation sheets 

we received. Our actuarial consultant reached the same conclusions the Board did 

regarding the meaning of the plain language in Plan Article 6. 

Our actuarial consultant did, however, find an error in the PBGC calculation. 

PBGC erred in calculating the Basic Plan Account balance as of NRD. Essentially, 

PBGC failed to limit interest projections to the Normal Retirement Date, instead 

providing interest to the first of the following year. This calculation inflates the Basic 

Plan Account Balance, providing participants with a lower net benefit. 

Our actuarial consultant provided us the following detailed table which illustrates 

the extent of this actuarial error for each participant: 

Provided Valuation Revised Difference 

Basic Plan Account Account Between Difference 

Account on Projection to Projection to Projected in Monthly 

Aooellant Name 12-31-2005 NRD NRD Accounts Offset 

$324,414.02 $652,784.75 $637,126.82 $15,657.93 $139.38 

$29,575.96 $39,579.31 $37,520.72 $2,058.59 $18.32 

$36,511.09 $48,860.07 $48,387.87 $472.20 $4.20 

$27,692.18 $39,281.89 $38,153.94 $1,127.95 $10.04 

$54,243.64 $146,065.80 $140,500.53 $5,565.27 $49.54 

$123,692.00 $165,527.80 $158,449.74 $7,078.06 $63.00 

As stated earlier, Appendix 1 contains of the Appellants new benefit, 

whether elected at NRD or retiring effective 009. You will note that the 

NRD benefits shown at Appendix 1 for 

I Ihave increased by the same a'---m-o-u-n~t-a-s~t~e-d~if~:tI~er-e-n-ce~in~th-e-m-o-n~th~l-y-o~ff:~s-etreflected in the table above. For I !heir total offsets (while 

decreased as noted above) still result in a net Supplementary Retirement Benefit of $0.00. 

Our actuarial consultant recommended correcting this data, and the Board agreed. 

Revised benefit statements are included at Appendix 1; they reflect the revised and 

accurate benefit calculations. 

9 We recognize that the calculation for I fS for a retirement benefit at NRD. ~--~ 

10 
Summary a/Our Findings on Your Appeal 

,-----__ =In=--=summ==; ary, the Board examined two prior early retirement calculations: one for 

I provided by you and a Former Urmamed Partici~ant we ohtfined. We also 

examined the former Plan Actuary's retirement calculation forl from 2002. In 

two of the three calculations, the methodology used supported PBGC's interpretation of 

the Plan language. We find that the plain language of Article 6 is compelling, and the 

evidence we were able to locate on early retirement calculations outweighed the example 

you provided. We are further convinced this is the correct decision based on our actuarial 

consultant's review of your appeal and our own Board Actuary's review of the 

calculation at Appendix 2. 

Decision. 

Having applied the Plan provisions, the provisions of ERISA, other applicable 

law, and PBGC regulations and policies to the facts in this case, the Appeals Board has 

denied your appeal. We did, however, independently find an error in the manner in 

which benefits were calculated and have corrected it. The revised benefit statements at 

Appendix 1 will be the basis for PBGC's calculation of retirement benefits when each 

appellant applies for retirement benefits. 

This decision is PBGC's final Agency action regarding the issues raised in your 

consolidated appeal. The appellants, if they wish, may seek review of this decision in an 

appropriate federal district court. If your clients have questions, they may call PBGC's 

Customer Contact Center at 1-800-400-7242. 

Sincerely, 

William F. Condron, Jr. 

Member, Appeals Board 

Appendix 1: Summary of Benefit changes and revised Benefit Statements (13 pages). 

Appendix 2: Board Actuary's Comment onl I Calculation (2 pages) 

2 Enclosures 

1. PGBC Actuarial Case remo (6 nages). 

2. Pension calculation fo Jl page). 

11