CPTF000043 CPTF - 
CPTF000044 CPTF - 
CPTF000045 CPTF - 
CPTF000046 CPTF - 
CPTF000047 CPTF - 
CPTF000048 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid 

insolvency

6.0

Does the application include the plan actuary’s certification that, taking into account the 

proposed suspension and, if applicable, a proposed partition, the plan is projected to avoid 

insolvency if the suspension takes effect and, the supporting illustrations, including the following?

• the plan year-by-year projections demonstrating projected solvency during the relevant 

period,

• separately identifying the available resources (and the market value of assets and changes 

in cash flow) during each of those years?

See section 3.02 of Revenue Procedure 2017-43.

Document 6.1 is the Actuarial Certification of Plan Solvency under IRC §432(e)(9)(C)(i) as of the 

Proposed Benefit Suspension Effective Date of July 1, 2021. Document 6.2 contains supporting 

illustrations for this Actuarial Certification. This includes Exhibit II, which is a year-by-year 

solvency projection which demonstrates that the Pension Fund will become insolvent in the plan 

year ending April 30, 2033. Exhibit III demonstrates that the Pension Fund will avoid insolvency 

with the Proposed Benefit Suspensions taking effect July 1, 2021. These Exhibits each separately 

identify the market value of assets, contributions, investment earnings, benefit payments and 

plan expenses. The Actuarial Certification in Document 6.1 and the supporting exhibits in 

Document 6.2 are based upon our interpretation of the requirements under Revenue Procedure 

2017-43, Section 3.02.

CPTF000049 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid 

insolvency

6.1

Document 6.1

Plan Actuary’s Certification that the Plan Is Projected to Avoid Insolvency

This letter and the attached exhibits of Document 6.2 have been prepared by United Actuarial 

Services, Inc. at the request of the Board of Trustees of the Carpenters Pension Trust Fund –

Detroit and Vicinity. United Actuarial Services, Inc. certifies under IRC §432(e)(9)(C)(i) that the 

Plan is projected to avoid insolvency within the meaning of IRC §418E, taking into account the 

proposed benefit suspension effective July 1, 2021 and assuming such suspension continues 

indefinitely. This certification is also intended to comply with regulation §1.432(e)(9)-1 and 

Revenue Procedure 2017-43. A summary of the proposed benefit suspension can be found in 

Document 2.1. Checklist Item #25 describes the actuarial assumptions and methodology used in 

the reports filed with this application, as required under Revenue Procedure 2017-43, Section 

4.02(3).

This certification is based on the May 1, 2019 actuarial valuation report dated March 9, 2020 (see 

Document 41.1) and the May 1, 2020 actuarial certification dated July 29, 2020 (see Document 

5.1). The Market Value of assets as of June 30, 2020 (the start of the “initial period” as defined 

in Revenue Procedure 2017-43, Section 3.02, as required under regulation §1.432(e)(9)-

1(d)(5)(iv)(C)(1)) was furnished by BeneSys, Inc. and certified by Bultynck and Co., PLLC. 

This certification is intended to demonstrate, as required under IRC §432(e)(9) and regulation 

§1.432(e)(9)-1, that the proposed benefit suspensions are reasonably projected to avoid 

insolvency as described in IRC §418E. The results may not be appropriate for any other purpose. 

Future actuarial measurements may differ significantly from the current measurements 

presented in this certification due to factorssuch as the following: plan experience differing from 

that anticipated by the economic or demographic assumptions, changes in economic or 

demographic assumptions, or changes in plan provisions. 

The results are based on my best interpretation of existing laws and regulations and are subject 

to revision based on future regulatory or other guidance.

United Actuarial Services, Inc. does not provide, nor charge for, investment, tax or legal advice. 

None of the comments made herein should be construed as constituting such advice. We are 

not aware of any direct or material indirect financial interest or relationship that could create a 

conflict of interest that would impair the objectivity of our work. 

I am a member of the American Academy of Actuaries and meet the Qualification Standards of 

the American Academy of Actuaries to render the actuarial opinion contained herein. To the best 

of my knowledge, the information supplied is complete and accurate. As required by IRC 

CPTF000050 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid 

insolvency

6.2

§432(b)(3)(B)(iii), the projected industry activity is based on information provided by the plan 

sponsor. In my opinion, the projections are based on reasonable actuarial estimates, 

assumptions and methods that (other than projected industry activity) offer my best estimate of 

anticipated experience under the Plan.

Certified by:

Erika L. Creager, EA, MAAA

Enrollment Number: 20-07288

11590 N. Meridian St., Suite 610

Carmel, IN 46032

Phone: 317-580-8631

CPTF000051 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid 

insolvency

6.3

Document 6.2

Actuarial Solvency Certification Supporting Exhibits

EXHIBIT I Value of Plan Assets at Beginning and End of the “Initial Period”

EXHIBIT II Deterministic Projection of Current Plan without Proposed Suspension

EXHIBIT III Deterministic Projection with Proposed Suspension

EXHIBIT IV Breakdown of Benefit Payouts for Exhibit II

EXHIBIT V Breakdown of Benefit Payouts for Exhibit III

CPTF000052 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid 

insolvency

6.4

Exhibit I – Value of Plan Assets at Beginning and End of the “Initial Period”

The projected change in Market Value of Assets from July 1, 2020 through April 30, 2021 (the 

“initial period” as defined in Revenue Procedure 2017-43, Section 3.02) is shown below. The 

Market Value of assets as of July 1, 2020 was furnished by BeneSys, Inc. and certified by Bultynck 

and Co., PLLC. The actuarial assumptions used are described in Checklist Item #25.

From July 1, 2020

through April 30, 2021

1. Market Value at beginning of period $ 730,707,581

2. Employer contributions 85,387,500

3. Withdrawal liability payments 1,323,196

4. Other income -

5. Benefit payments 132,069,522

6. Administrative expenses 5,075,000

7. Investment earnings/(loss) 38,237,594

8. Projected Market Value at end of period

= (1)+(2)+(3)+(4)-(5)-(6)+(7) $ 718,511,349

CPTF000053 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.5

Exhibit II – Deterministic Projection of Current Plan without Proposed Suspension

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2021 through April 30, 2033 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2021 $721,637,632 $98,242,244 $1,333,196 $0 $157,972,946 $6,106,627 $61,377,850 $718,511,349 $876,484,295 5.55

4/30/2022 $718,511,349 $103,950,000 $36,159 $963,841 $162,448,079 $4,688,160 $44,682,185 $701,007,295 $863,455,374 5.32

4/30/2023 $701,007,295 $103,950,000 $36,159 $963,841 $166,639,988 $4,288,676 $34,079,051 $669,107,682 $835,747,670 5.02

4/30/2024 $669,107,682 $102,465,000 $36,159 $963,841 $170,890,892 $4,391,604 $37,036,288 $634,126,474 $805,017,366 4.71

4/30/2025 $634,126,474 $102,465,000 $36,159 $763,841 $175,407,017 $4,497,002 $34,850,320 $592,187,775 $767,594,792 4.38

4/30/2026 $592,187,775 $102,465,000 $36,159 $613,841 $179,746,729 $4,604,930 $28,681,611 $539,632,727 $719,379,456 4.00

4/30/2027 $539,632,727 $102,465,000 $36,159 $613,841 $183,853,956 $4,715,448 $25,839,087 $480,017,410 $663,871,366 3.61

4/30/2028 $480,017,410 $102,465,000 $36,159 $613,841 $187,816,469 $4,828,619 $18,498,226 $408,985,548 $596,802,017 3.18

4/30/2029 $408,985,548 $102,465,000 $36,159 $613,841 $191,709,019 $4,944,506 $12,134,246 $327,581,269 $519,290,288 2.71

4/30/2030 $327,581,269 $102,465,000 $36,159 $613,841 $195,195,904 $5,063,174 $9,346,809 $239,784,000 $434,979,904 2.23

4/30/2031 $239,784,000 $102,465,000 $36,159 $613,841 $198,256,947 $5,184,690 $8,248,500 $147,705,863 $345,962,810 1.75

4/30/2032 $147,705,863 $102,465,000 $36,159 $613,841 $200,894,090 $5,309,123 $4,183,036 $48,800,686 $249,694,776 1.24

4/30/2033 $48,800,686 $102,465,000 $36,159 $613,841 $203,022,898 $5,436,542 ($168,412) insolvent $146,310,732 0.72

CPTF000054 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.6

Exhibit III – Deterministic Projection with Proposed Suspension

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2021 through April 30, 2052 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)

-(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2021 $721,637,632 $98,242,244 $1,333,196 $0 $157,972,946 $6,106,627 $61,377,850 $718,511,349 $876,484,295 5.55

4/30/2022 $718,511,349 $103,950,000 $36,159 $963,841 $133,717,059 $4,688,160 $45,615,943 $730,672,073 $864,389,132 6.46

4/30/2023 $730,672,073 $103,950,000 $36,159 $963,841 $130,564,993 $4,288,676 $46,521,816 $747,290,220 $877,855,213 6.72

4/30/2024 $747,290,220 $102,465,000 $36,159 $763,841 $133,219,618 $4,391,604 $47,457,612 $760,401,610 $893,621,228 6.71

4/30/2025 $760,401,610 $102,465,000 $36,159 $613,841 $136,150,959 $4,497,002 $48,206,283 $771,074,932 $907,225,891 6.66

4/30/2026 $771,074,932 $102,465,000 $36,159 $613,841 $139,043,884 $4,604,930 $48,802,522 $779,343,640 $918,387,524 6.61

4/30/2027 $779,343,640 $102,465,000 $36,159 $613,841 $141,877,505 $4,715,448 $49,244,303 $785,109,990 $926,987,495 6.53

4/30/2028 $785,109,990 $102,465,000 $36,159 $613,841 $144,612,729 $4,828,619 $49,526,543 $788,310,185 $932,922,914 6.45

4/30/2029 $788,310,185 $102,465,000 $36,159 $613,841 $147,351,216 $4,944,506 $49,641,789 $788,771,252 $936,122,468 6.35

4/30/2030 $788,771,252 $102,465,000 $36,159 $613,841 $149,892,369 $5,063,174 $49,585,314 $786,516,023 $936,408,392 6.25

4/30/2031 $786,516,023 $102,465,000 $36,159 $613,841 $152,168,711 $5,184,690 $55,815,666 $788,093,288 $940,261,999 6.18

4/30/2032 $788,093,288 $102,465,000 $36,159 $613,841 $154,210,241 $5,309,123 $55,851,996 $787,540,920 $941,751,161 6.11

4/30/2033 $787,540,920 $102,465,000 $36,159 $613,841 $155,935,480 $5,436,542 $55,743,312 $785,027,210 $940,962,690 6.03

4/30/2034 $785,027,210 $102,465,000 $12,056 $637,944 $157,264,909 $5,567,019 $45,973,890 $771,284,172 $928,549,081 5.90

4/30/2035 $771,284,172 $102,465,000 $7,236 $642,764 $158,038,895 $5,700,627 $50,015,604 $760,675,254 $918,714,149 5.81

4/30/2036 $760,675,254 $102,465,000 $7,236 $642,764 $158,434,253 $5,837,442 $49,281,541 $748,800,100 $907,234,353 5.73

4/30/2037 $748,800,100 $102,465,000 $7,236 $642,764 $158,473,879 $5,977,541 $48,473,903 $735,937,583 $894,411,462 5.64

4/30/2038 $735,937,583 $102,465,000 $3,618 $646,382 $158,241,874 $6,121,002 $47,608,671 $722,298,378 $880,540,252 5.56

4/30/2039 $722,298,378 $102,465,000 $0 $650,000 $157,476,679 $6,267,906 $46,708,892 $708,377,685 $865,854,364 5.50

4/30/2040 $708,377,685 $102,465,000 $0 $650,000 $156,552,426 $6,418,336 $45,795,362 $694,317,285 $850,869,711 5.44

4/30/2041 $694,317,285 $102,465,000 $0 $650,000 $155,088,226 $6,572,376 $44,890,503 $680,662,186 $835,750,412 5.39

4/30/2042 $680,662,186 $102,465,000 $0 $650,000 $153,489,329 $6,730,113 $44,017,423 $667,575,167 $821,064,496 5.35

CPTF000055 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.7

Exhibit III – Deterministic Projection with Proposed Suspension (Cont.)

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments 6. Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2043 $667,575,167 $102,465,000 $0 $650,000 $151,543,284 $6,891,636 $43,194,276 $655,449,523 $806,992,807 5.33

4/30/2044 $655,449,523 $102,465,000 $0 $650,000 $149,096,235 $7,057,035 $42,452,801 $644,864,054 $793,960,289 5.33

4/30/2045 $644,864,054 $102,465,000 $0 $650,000 $146,609,729 $7,226,404 $41,816,485 $635,959,406 $782,569,135 5.34

4/30/2046 $635,959,406 $102,465,000 $0 $650,000 $143,911,423 $7,399,838 $41,300,636 $629,063,781 $772,975,204 5.37

4/30/2047 $629,063,781 $102,465,000 $0 $650,000 $140,968,745 $7,577,434 $44,566,592 $628,199,194 $769,167,939 5.46

4/30/2048 $628,199,194 $102,465,000 $0 $650,000 $137,723,183 $7,759,292 $44,615,636 $630,447,355 $768,170,538 5.58

4/30/2049 $630,447,355 $102,465,000 $0 $650,000 $134,371,393 $7,945,515 $44,897,210 $636,142,657 $770,514,050 5.73

4/30/2050 $636,142,657 $102,465,000 $0 $650,000 $130,988,789 $8,136,207 $45,433,118 $645,565,779 $776,554,568 5.93

4/30/2051 $645,565,779 $102,465,000 $0 $650,000 $127,451,704 $8,331,476 $46,248,529 $659,146,128 $786,597,832 6.17

4/30/2052 $659,146,128 $102,465,000 $0 $650,000 $123,863,146 $8,531,431 $47,371,216 $677,237,767 $801,100,913 6.47

CPTF000056 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.8

EXHIBIT IV – Breakdown of Benefit Payouts for Exhibit II

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2021 $6,164,029 $2,675,767 $149,133,150 $0

4/30/2022 $10,830,217 $4,351,799 $147,266,063 $0

4/30/2023 $15,622,441 $6,220,721 $144,796,826 $0

4/30/2024 $20,403,301 $8,320,258 $142,167,330 $3 

4/30/2025 $25,238,937 $10,759,649 $139,407,447 $984 

4/30/2026 $30,080,423 $13,316,898 $136,346,988 $2,420 

4/30/2027 $34,873,289 $15,851,131 $133,124,895 $4,641 

4/30/2028 $39,561,469 $18,515,612 $129,722,076 $17,312 

4/30/2029 $44,122,958 $21,273,924 $126,271,800 $40,337 

4/30/2030 $48,586,394 $24,039,218 $122,499,494 $70,798 

4/30/2031 $52,797,857 $26,700,502 $118,642,431 $116,157 

4/30/2032 $56,879,057 $29,178,327 $114,648,742 $187,964 

4/30/2033 $60,606,226 $31,592,783 $110,508,779 $315,110 

CPTF000057 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.9

EXHIBIT V – Breakdown of Benefit Payouts for Exhibit III

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2021 $6,164,029 $2,675,767 $149,133,150 $0

4/30/2022 $8,851,323 $3,374,001 $121,491,735 $0

4/30/2023 $12,254,436 $4,513,592 $113,796,965 $0 

4/30/2024 $16,077,257 $6,010,215 $111,132,143 $3 

4/30/2025 $19,989,645 $7,741,413 $108,418,917 $984 

4/30/2026 $23,951,329 $9,550,956 $105,539,179 $2,420 

4/30/2027 $27,915,908 $11,351,466 $102,605,490 $4,641 

4/30/2028 $31,837,212 $13,240,933 $99,517,272 $17,312 

4/30/2029 $35,688,478 $15,201,138 $96,421,263 $40,337 

4/30/2030 $39,500,786 $17,162,877 $93,157,908 $70,798 

4/30/2031 $43,146,363 $19,054,469 $89,851,722 $116,157 

4/30/2032 $46,717,315 $20,821,785 $86,483,177 $187,964 

4/30/2033 $50,011,326 $22,547,358 $83,061,686 $315,110 

4/30/2034 $53,001,281 $24,271,794 $79,548,963 $442,871 

4/30/2035 $55,677,700 $25,762,616 $75,995,843 $602,736 

4/30/2036 $58,127,052 $27,131,819 $72,399,430 $775,952 

4/30/2037 $60,344,428 $28,381,767 $68,760,754 $986,930 

4/30/2038 $62,295,350 $29,613,505 $65,080,007 $1,253,012 

4/30/2039 $64,016,940 $30,548,489 $61,382,345 $1,528,905 

4/30/2040 $65,597,517 $31,405,463 $57,692,142 $1,857,304 

4/30/2041 $66,819,222 $32,087,830 $53,980,758 $2,200,416 

4/30/2042 $67,858,637 $32,729,951 $50,296,844 $2,603,897 

CPTF000058 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #6 – 3.02 Plan Actuary’s Certification that the Plan is projected to avoid insolvency

6.10

EXHIBIT V – Breakdown of Benefit Payouts for Exhibit III (Cont.)

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2043 $68,670,864 $33,172,898 $46,630,516 $3,069,006 

4/30/2044 $69,180,898 $33,344,298 $43,010,350 $3,560,689 

4/30/2045 $69,552,429 $33,449,530 $39,457,512 $4,150,258 

4/30/2046 $69,790,256 $33,372,745 $35,981,280 $4,767,142 

4/30/2047 $69,750,175 $33,123,482 $32,608,118 $5,486,970 

4/30/2048 $69,447,181 $32,632,261 $29,350,852 $6,292,889 

4/30/2049 $68,910,100 $32,051,331 $26,232,239 $7,177,723 

4/30/2050 $68,107,468 $31,298,485 $23,271,062 $8,311,774 

4/30/2051 $67,044,857 $30,416,256 $20,484,384 $9,506,207 

4/30/2052 $65,739,562 $29,355,624 $17,886,852 $10,881,108 

CPTF000059 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #9 – 4.02(1) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency

9.0

Does the application include a demonstration that the proposed suspension is reasonably 

estimated to achieve the level necessary to avoid insolvency for the extended period, including 

illustrations regarding the plan’s solvency ratio and available resources? See section 4.02(1) of 

Revenue Procedure 2017-43.

Document 9.1 provides a demonstration that the proposed suspension is reasonably estimated 

to achieve the level necessary to avoid insolvency for the extended period on deterministic basis.

CPTF000060 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #9 – 4.02(1) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency

9.1

Document 9.1

Proposed Suspension Is Reasonably Estimated to

Enable the Pension Plan to Avoid Insolvency on a Deterministic Basis

This application filed on behalf of the Pension Plan includes an actuarial certification of plan 

solvency under ERISA § 305(e)(9)(c)(i) and IRC Section 432(e)(9)(C)(i) as of the effective date of 

the proposed benefit suspension, which is July 1, 2021. See Document 6.1 of Checklist Item #6.

Exhibit III of Checklist Item #6 provides an illustration based on the deterministic basis showing 

that the proposed suspension is reasonably estimated to avoid insolvency throughout the 

extended period. This illustration provides the market value and solvency ratio for Plan Years 

ending April 30, 2021 through April 30, 2052. 

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3).

CPTF000061 CPTF - 
CPTF000062 CPTF - 
CPTF000063 CPTF - 
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CPTF000095 CPTF - 
CPTF000096 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.0

Does the application include a demonstration that the limitations on individual suspensions are 

satisfied, including a description of each benefit based on disability, as defined under the plan, 

that is paid to an individual under the plan (without regard to whether the disability benefits are 

available to newly disabled participants) and calculations regarding:

• the guarantee-based limitation,

• the disability-based limitation,

• the age-based limitation, taking into account the guarantee-based limitation, and

• if applicable, the age-based limitation taking into account both the guarantee-based 

limitation and the disability-based limitation?

See section 4.01 of Revenue Procedure 2017-43.

Document 8.1 provides demonstrations that the proposed suspension satisfies the statutory 

limitations described in § 432(e)(9)(D)(i), (ii), and (iii).

CPTF000097 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.1

Document 8.1

Demonstration that the Limitations on

Individual Suspensions Are Satisfied

This document 8.1 illustrates how the proposed suspension satisfies the guarantee-based

limitation, the age-based limitation, and the disability-based limitation, as established under IRC 

Section 432(e)(9)(D)(i), (ii), and (iii), respectively.

Guarantee-based Limitation

The proposed suspension does not reduce the benefit of any participant or beneficiary to an 

amount that is less than 110% of the PBGC guarantee. 

If a participant’s benefit is split with an alternate payee under the terms of a qualified domestic 

relations order (QDRO), then the determination of the guaranteed level for both parties is based 

on the terms of the QDRO. Generally, if the QDRO provides the alternate payee a shared interest 

with the participant, then the participant’s total benefit is used for purposes of determining the 

guaranteed amount for both parties. If the QDRO provides a separate interest for the alternate 

payee, then the alternate payee’s separate benefit level is used to determine the guaranteed 

amount. If there are multiple QDROs with multiple alternate payees, this determination is made 

separately with respect to each applicable QDRO.

Age-Based Limitation

The proposed suspension does not affect any participant or beneficiary who will be age 80 or 

older as of July 31, 2021 (the end of the month in which the July 1, 2021 effective date of the 

proposed suspension occurs). The proposed suspension only partially affects any participant or 

beneficiary who will be age 75-79 as of July 31, 2021 (with proportionally more of the current 

benefit being protected the closer the participant or beneficiary is to age 80). 

In the event that the age-based limitation applies to a participant that has a QDRO, then the type 

of QDRO will determine whether the Pension Plan uses the participant’s or alternate payee’s age. 

If the QDRO provides the alternate payee a shared interest with the participant, then the 

participant’s age is used for purposes of applying the age-based limitation as of the proposed 

suspension’s effective date. Alternatively, if the QDRO provides a separate interest for the 

alternate payee, then the alternate payee’s age is used to determine the application of the agebased limitation. If there are multiple QDROs with multiple alternate payees, the determination 

of whose age to use is determined separately for each applicable QDRO.

The application of the age-based limitation for a participant who elected a joint and survivor 

benefit is based on the age of the participant as of July 31, 2021, unless he or she is deceased, in 

which case the surviving spouse’s age is used to determine the application of the age-based 

limitation.

CPTF000098 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.2

Section 4.01(3) of revenue procedure 2017-43 requires submission of sample calculations for 

each group defined in Checklist Item #2 that includes an individual who is over age 75 (as of July 

31, 2021). Note that no calculations are included for groups that have a sub-group designation 

of “2” as these the individuals in these groups have only post-5/1/2007 accruals and will not be 

affected by the suspension.

Section 4.01(3)(c) of revenue procedure 2017-43 requests submission of sample calculations on 

individuals who are between age 75 and 79 but have not commenced benefits. However, all plan 

participants satisfying the preceding criteria are past their IRC section 401(a)(9) required 

beginning date and ARE treated as being in pay status retroactive to such date. Therefore, no 

such calculations are included for the “A” group.

The “B groups” and “C groups” do not contain anyone over the age of 75, so no calculations are 

included for these groups.

Based on the preceding, sample age-based limitation calculations are submitted on the following 

groups:

• D1

• D3

Disability-based Limitation

The proposed suspension does not affect any disability benefit that is in pay status as of July 1, 

2021. Furthermore, if a disabled participant has converted to a retirement benefit on or prior to 

July 1, 2021, such participant’s benefit will not be reduced below the amount of the disability

benefit he or she was receiving immediately prior to conversion.

There are currently 3 types of disability benefits paid to an individual under the plan. 

1. Basic Disability Benefit – In order to be eligible for this benefit, the participant must be 

under age 62, have at least 5 credit years, and have a disability award from the Social 

Security Administration (SSA). The benefit is paid in the form of a temporary life annuity 

generally ending at age 62. The benefit amount is equal to the greater of: (a) 75% of the 

vested accrued benefit, or (b) $280, but is subject to a cap pursuant to the following table:

Number of 

Credit Years

Cap on Disability 

Benefit

5-9 $525

10-15 $625

16-19 $725

20-24 $1,050

25+ $1,350

CPTF000099 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.3

2. Lump Sum Disability Benefit – If a participant is disabled with an SSA award but has less 

than 5 credit years (the plan uses 3-7 year graded vesting), then he or she is eligible for a 

lump sum cash-out equal to the actuarial present value of his or her vested accrued 

benefit.

3. Lawsuit-related Disability Benefit – As the result of a settlement of a class action lawsuit 

in October 2016, most disabled participants who were in pay status as of 8/1/2013 and 

had taken a cut due to the 2013 rule change implementing the service-based cap 

described above, were restored to 95% of their pre-amendment disability benefit 

amount. After these people retire, the disability-based limitation will be applied based 

on the 95% of pre-amendment disability amount.

The following special rules apply to the application of the disability-based limitation:

• When the disability rules were changed in 2013 to require a disability award from the SSA, 

disabled retirees without such an award were allowed one year to obtain one. As a result 

of this change, some previously disabled participants ceased to qualify under the plan 

rules. These people will not receive any special protection under the disability-based 

limitation.

• As the result of the 2016 class action settlement, affected disabled participants who were:

a. In pay status on 8/1/2013, and

b. Converted to early retirement prior to October 2016, and

c. Had an early retirement benefit that was less than 95% of their prior disability 

benefit,

were granted a benefit increase to 95% of their pre-amendment disability amounts 

payable until age 62, at which time their benefit will increase to an unreduced, early

retirement benefit. For purposes of the disability-based limitation, the benefit payable 

until normal retirement age for these participants will be treated as a disability benefit.

If a participant’s benefit is split with an alternate payee under the terms of a QDRO, then the 

determination of the amount of the disability-based limitation for both parties is based on the 

terms of the QDRO. In the case of a separate interest QDRO, the alternate payee will generally 

not receive any portion of the disability-based limitation. The exception to this is in the case of 

an alternate payee who was assigned a portion of the participant’s disability benefit. In this case, 

such alternate payee will receive a disability-based limitation based on the portion of disability 

benefit assigned and the participant will not receive a disability-based limitation based on such 

portion.

CPTF000100 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.4

In the case of a shared interest QDRO, any disability-based limitation will be shared in the same 

manner as the benefit itself.

Surviving spouses and beneficiaries will not receive any disability-based limitation.

Sample Calculations

The sample calculations required by Section 4.01 of revenue procedure 2017-43 are attached to 

this the document as exhibits. Note that:

• There are no ERISA 4022A(a) forfeitable benefits,

• There are no ERISA 4022A(b)(1)(A) benefit increases that have been in effect for less than 

60 months,

• The limitations contained in ERISA 4022A(c)(2) have been reflected in the guaranteebased calculations,

• There have been no ERISA 4022A(d) benefit reductions made pursuant to IRC section 

411(a)(3)(E) (related to service with an employer rendered prior to such employer’s 

obligation to contribute to the plan where such employer subsequently ceases to have an 

obligation to contribute), and

• The ERISA 4022A(e) exclusion does not apply as the Secretary of the Treasury has not

determined that the plan fails to satisfy the requirements of IRC sections 401(a) or 

404(a)(2).

A listing of the attached exhibits appears below:

Exhibit #

Relevant 

Section of Rev. 

Proc. 2017-43 Description

I 4.01(1) Guarantee-based limitation for an individual currently receiving 

benefits

II 4.01(1) Guarantee-based limitation for the contingent beneficiary of an 

individual currently receiving benefits

III 4.01(1) Guarantee-based limitation for a future retiree

IV 4.01(2)

Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability 

benefit)

V 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit)

VI 4.01(2) Disability-based limitation for a future retiree who is currently 

receiving a temporary annuity disability benefit

CPTF000101 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.5

Exhibit #

Relevant 

Section of Rev. 

Proc. 2017-43 Description

VII 4.01(2)

Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability benefit 

that was equal to 95% of his or her pre-8/1/2013 disability 

benefit due to the October 2016 settlement)

VIII 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit that was equal to 95% of 

his or her pre-8/1/2013 disability benefit due to the October 

2016 settlement)

IX 4.01(2)

Disability-based limitation for a future retiree who is currently 

receiving a disability benefit equal to 95% of his or her pre8/1/2013 disability benefit due to the October 2016 settlement

X 4.01(2)

Disability-based limitation for an individual who had previously 

received a retirement benefit that is treated like a disability 

benefit due to the October 2016 settlement

XI 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual who had previously received a retirement benefit that 

is treated like a disability benefit due to the October 2016

settlement

XII 4.01(2)

Disability-based limitation for an individual who is currently 

receiving a retirement benefit that is treated like a disability 

benefit due to the October 2016 settlement

XIII 4.01(3) Group D1 retiree who is between age 75 and 79 as of 7/31/2021

XIV 4.01(3) Beneficiary of a group D1 retiree who is between age 75 and 79 

as of 7/31/2021

XV 4.01(3) Group D3 retiree who is between age 75 and 79 as of 7/31/2021

XVI 4.01(3) Beneficiary of a group D3 retiree who is between age 75 and 79 

as of 7/31/2021

CPTF000102 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.6

Exhibit I - Guarantee-based limitation for an individual currently receiving benefits

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 12/4/1952

Date of retirement (DOR) 1/1/2018

Age at retirement date 65 years, 0 months

Age at suspension date 68 years, 7 months

Disabled? No

Current monthly benefit $ 117.35 

Amount of current monthly benefit earned prior to 5/1/2007 $ 117.35 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 5

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 117.35 

PBGC accrual rate $ 23.47 

PBGC guaranteed accrual rate $ 20.35 

PBGC guaranteed benefit (no greater than current benefit) $ 101.76 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 111.94 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 117.35 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 37.57

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 79.80

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 79.80

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 111.94 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 111.94 

Final Monthly Benefit under Proposed Suspension $ 111.94 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes

Disability limit? No

Age-based limit? No

CPTF000103 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.7

Exhibit II - Guarantee-based limitation for the contingent beneficiary of an individual currently 

receiving benefits

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 10/20/1946

Date of retirement (DOR) 5/1/2011

Age at retirement date 64 years, 6 months

Age at suspension date 74 years, 9 months

Disabled? No

Current monthly benefit $ 33.76

Amount of current monthly benefit earned prior to 5/1/2007 $ 33.76

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 6

Form of pension Joint and 100% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 33.76 $ 33.76

PBGC accrual rate $ 5.63 $ 5.63

PBGC guaranteed accrual rate $ 5.63 $ 5.63

PBGC guaranteed benefit (no greater than current benefit) $ 33.76 $ 33.76

110% of PBGC guaranteed benefit (no greater than current benefit) $ 33.76 $ 33.76

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 33.76 $ 33.76

MPRA Reduction for benefit earned prior to 5/1/2007 $ 10.80 $ 10.80

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 22.96 $ 22.96

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 22.96 $ 22.96

Step 3 or 110% of PBGC guaranteed benefit if greater $ 33.76 $ 33.76

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 33.76 $ 33.76

Final Monthly Benefit under Proposed Suspension $ 33.76 $ 33.76

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes Yes

Disability limit? No No

Age-based limit? No No

CPTF000104 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.8

Exhibit III - Guarantee-based limitation for a future retiree

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 8/9/1977

Age at suspension date 43 years, 11 months

Disabled? No

Accrued monthly benefit $ 132.00 

Amount of accrued monthly benefit earned prior to 5/1/2007 $ 63.27 

Amount of accrued monthly benefit earned on and after 5/1/2007 $ 68.73 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 7

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Accrued monthly benefit, without regard to LRF $ 132.00 

PBGC accrual rate $ 18.86 

PBGC guaranteed accrual rate $ 16.89 

PBGC guaranteed benefit (no greater than current benefit) $ 118.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 130.08 

Calculation of Monthly Benefit under Proposed Suspension

Accrued monthly benefit $ 132.00 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 20.25

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 43.02

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 68.73 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 111.75

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 130.08 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 130.08 

Final Monthly Benefit under Proposed Suspension $ 130.08 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes

Disability limit? No

Age-based limit? No

CPTF000105 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.9

Exhibit IV - Disability-based limitation for an individual currently receiving retirement benefits 

(who previously received a disability benefit)

Suspension Limitation: Disability Benefit

Date of birth 3/2/1947

Date of retirement (DOR) 4/1/2009

Age at retirement date 62 years, 0 months

Age at suspension date 74 years, 4 months

Disabled? Yes

Current monthly benefit $ 1,937.06 

Protected disability benefit $ 1,652.81 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,937.06 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 15

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,937.06 

PBGC accrual rate $ 129.14 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 536.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 589.88 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,937.06 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 619.86

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 1,317.20

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,317.20

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,317.20

Step 5: Step 4 or disability benefit if greater $ 1,652.81 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 1,652.81 

Final Monthly Benefit under Proposed Suspension $ 1,652.81 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000106 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.10

Exhibit V - Disability-based limitation for the contingent beneficiary of an individual currently 

receiving retirement benefits (who previously received a disability benefit)

Suspension Limitation: Disability Benefit

Date of birth 5/31/1950

Date of retirement (DOR) 6/1/2005

Age at retirement date 55 years, 0 months

Age at suspension date 71 years, 2 months

Disabled? Yes

Current monthly benefit $ 1,440.59 

Protected disability benefit $ 1,399.38 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,440.59 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 25

Form of pension Joint and 50% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 1,440.59 $ 720.30 

PBGC accrual rate $ 57.62 $ 28.81 

PBGC guaranteed accrual rate $ 35.75 $ 24.36 

PBGC guaranteed benefit (no greater than current benefit) $ 893.75 $ 608.98 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 983.13 $ 669.88 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 1,440.59 $ 720.30 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 460.99 $ 230.50

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 979.60 $ 489.80

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 979.60 $ 489.80

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 983.13 $ 669.88 

Step 5: Step 4 or disability benefit if greater $ 1,399.38 $ 669.88 

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 1,399.38 $ 669.88 

Final Monthly Benefit under Proposed Suspension $ 1,399.38 $ 669.88 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No Yes

Disability limit? Yes No

Age-based limit? No No

CPTF000107 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.11

Exhibit VI - Disability-based limitation for a future retiree who is currently receiving a 

temporary annuity disability benefit

Suspension Limitation: Disability Benefit

Date of birth 5/5/1961

Date of Disability retirement (DOR) 10/1/2009

Age at Disability retirement date 48 years, 4 months

Age at suspension date 60 years, 2 months

Disabled? Yes

Current monthly disability benefit $ 423.65 

Accrued monthly benefit $ 564.86 

Amount of accrued benefit earned prior to 5/1/2007 $ 564.86 

Amount of accrued benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 9

Form of pension Disability

Calculation of 110% of PBGC Guarantee

Accrued benefit, without regard to LRF $ 564.86 

PBGC accrual rate $ 62.76 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 321.75 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 353.93 

Calculation of Monthly Benefit under Proposed Suspension

Accrued Monthly benefit $ 564.86 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 180.76

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 384.10

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 384.10

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 384.10

Step 5: Step 4 or disability benefit if greater $ 423.65

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 423.65

Final Monthly Benefit under Proposed Suspension $ 423.65

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000108 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.12

Exhibit VII - Disability-based limitation for an individual currently receiving retirement benefits 

(who previously received a disability benefit that was equal to 95% of his or her pre-8/1/2013 

disability benefit due to the October 2016 settlement)

Suspension Limitation: Disability Benefit

Date of birth 3/16/1953

Date of retirement (DOR) 4/1/2011

Age at retirement date 58 years, 0 months

Age at suspension date 68 years, 4 months

Disabled? Yes

Current monthly benefit $ 2,996.70 

Protected disability benefit $ 2,694.55 

Amount of current monthly benefit earned prior to 5/1/2007 $ 2,996.70 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 22

Form of pension Joint and 75% Survivor

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 2,996.70 

PBGC accrual rate $ 136.21 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 786.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 865.15 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 2,996.70 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 958.94

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,037.76

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 2,037.76

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 2,037.76

Step 5: Step 4 or disability benefit if greater $ 2,694.55 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 2,694.55 

Final Monthly Benefit under Proposed Suspension $ 2,694.55 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000109 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.13

Exhibit VIII - Disability-based limitation for the contingent beneficiary of an individual currently 

receiving retirement benefits (who previously received a disability benefit that was equal to 

95% of his or her pre-8/1/2013 disability benefit due to the October 2016 settlement)

Suspension Limitation: Disability Benefit

Date of birth 1/14/1949

Date of retirement (DOR) 2/1/2010

Age at retirement date 61 years, 0 months

Age at suspension date 72 years, 6 months

Disabled? Yes

Current monthly benefit $ 4,367.07 

Protected disability benefit $ 4,078.36 

Amount of current monthly benefit earned prior to 5/1/2007 $ 4,367.07

Amount of current monthly benefit earned on and after 5/1/2007 $ -

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 19

Form of pension Joint and 75% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 4,367.07 $ 3,275.30 

PBGC accrual rate $ 229.85 $ 172.38 

PBGC guaranteed accrual rate $ 35.75 $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 679.25 $ 679.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 747.18 $ 747.18 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 4,367.07 $ 3,275.30 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 1,397.46 $ 1,048.10

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,969.61 $ 2,227.20

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 2,969.61 $ 2,227.20

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 2,969.61 $ 2,227.20

Step 5: Step 4 or disability benefit if greater $ 4,078.36 $ 2,227.20

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 4,078.36 $ 2,227.20

Final Monthly Benefit under Proposed Suspension $ 4,078.36 $ 2,227.20

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No No

Disability limit? Yes No

Age-based limit? No No

CPTF000110 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.14

Exhibit IX - Disability-based limitation for a future retiree who is currently receiving a disability 

benefit equal to 95% of his or her pre-8/1/2013 disability benefit due to the October 2016

settlement

Suspension Limitation: Disability Benefit

Date of birth 11/23/1960

Date of Disability retirement (DOR) 6/1/2012

Age at Disability retirement date 51 years, 6 months

Age at suspension date 60 years, 8 months

Disabled? Yes

Current monthly disability benefit $ 1,959.60 

Accrued monthly benefit $ 2,750.32 

Amount of accrued benefit earned prior to 5/1/2007 $ 2,750.32 

Amount of accrued benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 18

Form of pension Disability

Calculation of 110% of PBGC Guarantee

Accrued benefit, without regard to LRF $ 2,750.32 

PBGC accrual rate $ 152.80 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 643.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 707.85 

Calculation of Monthly Benefit under Proposed Suspension

Accrued Monthly benefit $ 2,750.32 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 880.10

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 1,870.22

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,870.22

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,870.22

Step 5: Step 4 or disability benefit if greater $ 1,959.60

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 1,959.60

Final Monthly Benefit under Proposed Suspension $ 1,959.60

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000111 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.15

Exhibit X - Disability-based limitation for an individual who had previously received a 

retirement benefit that is treated like a disability benefit due to the October 2016 settlement

Suspension Limitation: Disability Benefit

Date of birth 9/11/1959

Date of retirement (DOR) 6/1/2009

Age at retirement date 52 years, 8 months

Age at suspension date 61 years, 10 months

Disabled? Yes

Current monthly benefit $ 1,061.76 

Protected disability benefit $ 917.18 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,005.80 

Amount of current monthly benefit earned on and after 5/1/2007 $ 55.96 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 14

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,061.76 

PBGC accrual rate $ 75.84 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 500.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 550.55 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,061.76 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 321.86

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 683.94

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 55.96 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 739.90

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 739.90

Step 5: Step 4 or disability benefit if greater $ 917.18 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 917.18 

Final Monthly Benefit under Proposed Suspension $ 917.18 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000112 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.16

Exhibit XI - Disability-based limitation for the contingent beneficiary of an individual who had 

previously received a retirement benefit that is treated like a disability benefit due to the 

October 2016 settlement

Suspension Limitation: Disability Benefit

Date of birth 8/30/1957

Date of retirement (DOR) 8/1/2013

Age at retirement date 55 years, 11 months

Age at suspension date 63 years, 11 months

Disabled? Yes

Current monthly benefit $ 4,487.78 

Protected disability benefit $ 3,890.44 

Amount of current monthly benefit earned prior to 5/1/2007 $ 4,032.42 

Amount of current monthly benefit earned on and after 5/1/2007 $ 455.36 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 23

Form of pension Joint and 50% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 4,487.78 $ 2,243.89 

PBGC accrual rate $ 195.12 $ 97.56 

PBGC guaranteed accrual rate $ 35.75 $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 822.25 $ 822.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 904.48 $ 904.48 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 4,487.78 $ 2,243.89 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 1,290.37 $ 645.19

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,742.05 $ 1,371.02

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 455.36 $ 227.68 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 3,197.41 $ 1,598.70

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 3,197.41 $ 1,598.70

Step 5: Step 4 or disability benefit if greater $ 3,890.44 $ 1,598.70

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 3,890.44 $ 1,598.70

Final Monthly Benefit under Proposed Suspension $ 3,890.44 $ 1,598.70

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No No

Disability limit? Yes No

Age-based limit? No No

CPTF000113 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.17

Exhibit XII - Disability-based limitation for an individual is currently receiving a retirement 

benefit that is treated like a disability benefit due to the October 2016 settlement

Suspension Limitation: Disability Benefit

Date of birth 2/14/1958

Date of retirement (DOR) 9/1/2013

Age at retirement date 55 years, 6 months

Age at suspension date 63 years, 5 months

Disabled? Yes

Current monthly benefit $ 2,720.67 

Protected disability benefit $ 2,720.67 

Amount of current monthly benefit earned prior to 5/1/2007 $ 2,720.67 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 19

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 2,720.67 

PBGC accrual rate $ 143.19 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 679.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 747.18 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 2,720.67 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 870.61

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 1,850.06

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,850.06

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,850.06

Step 5: Step 4 or disability benefit if greater $ 2,720.67 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 2,720.67 

Final Monthly Benefit under Proposed Suspension $ 2,720.67 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF000114 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.18

Exhibit XIII - Group D1 retiree who is between age 75 and 79 as of 7/31/2021

Suspension Limitation: Age-based Limitation

Date of birth 5/31/1944

Date of retirement (DOR) 8/1/2012

Age at retirement date 68 years 2 months

Age at suspension date 77 years 2 months

Disabled? No

Current monthly benefit $ 672.42 

Amount of current monthly benefit earned prior to 5/1/2007 $ 672.42 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.4464

Total years of service as of April 30, 2020 10

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 464.89 

PBGC accrual rate $ 46.49 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 357.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 393.25 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 672.42 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 215.17

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 457.25

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 457.25

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 457.25

Months from age 80 (at suspension date, max 60 mos) 34

Monthly benefit after age-based limitation $ 550.49

Final Monthly Benefit under Proposed Suspension $ 550.49

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

CPTF000115 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.19

Exhibit XIV - Beneficiary of a group D1 retiree who is between age 75 and 79 as of 7/31/2021

Suspension Limitation: Age-based Limitation

Participant date of birth 3/23/1943

Beneficiary date of birth 2/27/1943

Date of retirement (DOR) 4/1/2005

Participant Age at retirement date 62 years, 0 months

Spouse Age at suspension date 78 years, 5 months

Disabled? No

Current monthly benefit $ 640.35 

Amount of current monthly benefit earned prior to 5/1/2007 $ 640.35 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 7

Form of pension Survivor Benefit (50% Joint & Survivor)

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 640.35 

PBGC accrual rate $ 91.48 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 250.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 275.28 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 640.35 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 204.91

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 435.44

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 435.44

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 435.44

Months from age 80 (at suspension date, max 60 mos) 19

Monthly benefit after age-based limitation $ 575.46

Final Monthly Benefit under Proposed Suspension $ 575.46

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

CPTF000116 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.20

Exhibit XV - Group D3 retiree who is between age 75 and 79 as of 7/31/2021

Suspension Limitation: Age-based Limitation

Date of birth 2/14/1942

Date of retirement (DOR) 5/1/2008

Age at retirement date 66 years, 2 months

Age at suspension date 79 years, 5 months

Disabled? No

Current monthly benefit $ 1,212.58 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,093.01 

Amount of current monthly benefit earned on and after 5/1/2007 $ 119.57 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2020 7

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,212.58 

PBGC accrual rate $ 173.23 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 250.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 275.28 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,212.58 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 349.76

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 743.25

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 119.57 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 862.82

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 862.82

Months from age 80 (at suspension date, max 60 mos) 7

Monthly benefit after age-based limitation $ 1,171.77

Final Monthly Benefit under Proposed Suspension $ 1,171.77

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

CPTF000117 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied

8.21

Exhibit XVI - Beneficiary of a group D3 retiree who is between age 75 and 79 as of 7/31/2021

Suspension Limitation: Age-based Limitation

Beneficiary date of birth 9/12/1945

Date of retirement (DOR) 2/1/2008

Age at retirement date 62 years, 4 months

Age at suspension date 75 years, 10 months

Disabled? No

Current monthly 

benefit $ 849.73

Amount of current monthly benefit earned prior to 5/1/2007 $ 837.45

Amount of current monthly benefit earned on and after 5/1/2007 $ 12.28

Late retirement factor (LRD) applied to current benefit 1.0160

Total years of service as of April 30, 2020 11

Form of pension Beneficiary

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 836.35

PBGC accrual rate $ 76.03

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 393.25

110% of PBGC guaranteed benefit (no greater than current benefit) $ 432.58

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 849.73

MPRA Reduction for benefit earned prior to 5/1/2007 $ 267.98

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 569.47

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 12.28

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 581.75

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 581.75

Months from age 80 (at suspension date, max 60 mos) 50

Monthly benefit after age-based limitation $ 626.41

Final Monthly Benefit under Proposed Suspension $ 626.41

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

CPTF000118 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.0

Does the application include an illustration that the proposed suspension is reasonably estimated 

to achieve the level necessary to avoid insolvency for the extended period utilizing stochastic 

projections? (This illustration is optional if the plan is not required to appoint a retiree 

representative under § 432(e)(9)(B)(v)).

See section 4.02(2) of Revenue Procedure 2017-43.

Document 10.1 provides a demonstration that the proposed suspension is reasonably estimated 

to achieve the level necessary to maintain a positive asset value for the extended period utilizing

stochastic projections.

CPTF000119 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.1

Document 10.1

Proposed Suspension Is Reasonably Estimated to

Enable the Pension Plan to Avoid Insolvency Utilizing Stochastic Projections

This Document 10.1 summarizes the results of 5,000 stochastic trials. Each trial consists of a 

projection of the market value of Plan assets for the plan years ending April 30, 2021 through 

2052.

Probability of maintaining positive assets over the extended period: 66.08%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are shown 

below in graphical format in Exhibit I and in tabular format in Exhibit II. 

The capital market assumptions used for stochastic modeling assume a fixed transition from 

Portfolio A to Portfolio B on May 1, 2033 and a transition from B back to A on May 1, 2046. These 

assumed dates are based on the results of our deterministic modeling.

In order to provide additional information on the sensitivity of these projections to the assumed 

portfolio transition dates, we have included Exhibits III and IV. Exhibit III provides a frequency 

distribution of the date that negative cash flow first exceeds 7.5% of assets (which would trigger 

a transition to Portfolio B) and develops a median date for this transition of May 1, 2031. Exhibit 

IV provides additional stochastic results.

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

CPTF000120 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.2

Exhibit I – Graphical Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Utilizing Stochastic Projections

CPTF000121 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.3

Exhibit II – Tabular Presentation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Utilizing Stochastic Projections

Plan Year 

Ending

Market Value of Plan Assets – 5,000 Trials

5

th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2020 $721,637,632 $721,637,632 $721,637,632 $721,637,632 $721,637,632 

4/30/2021 $718,511,349 $718,511,349 $718,511,349 $718,511,349 $718,511,349 

4/30/2022 $614,794,838 $679,932,348 $728,462,679 $783,220,505 $875,367,610 

4/30/2023 $579,478,337 $675,727,426 $748,311,108 $831,343,918 $969,948,788 

4/30/2024 $552,927,238 $666,570,851 $758,452,812 $870,392,972 $1,059,103,016 

4/30/2025 $523,375,623 $654,721,046 $764,913,860 $903,912,112 $1,127,985,765 

4/30/2026 $497,278,118 $646,460,127 $774,110,779 $935,086,508 $1,202,709,544 

4/30/2027 $458,492,748 $636,052,758 $782,930,417 $964,394,241 $1,267,502,586 

4/30/2028 $433,356,396 $616,882,661 $784,660,601 $979,835,248 $1,357,876,114 

4/30/2029 $400,090,280 $598,459,004 $783,429,663 $1,008,086,592 $1,426,298,354 

4/30/2030 $362,732,682 $575,687,856 $783,353,229 $1,038,054,634 $1,513,826,687 

4/30/2031 $334,879,227 $557,587,994 $783,793,166 $1,057,977,992 $1,618,437,753 

4/30/2032 $291,713,967 $539,099,318 $780,319,215 $1,080,896,667 $1,722,722,593 

4/30/2033 $249,563,914 $515,109,601 $765,365,182 $1,103,887,346 $1,825,900,926 

4/30/2034 $197,650,501 $482,489,525 $756,893,216 $1,124,555,354 $1,920,740,934 

4/30/2035 $146,718,742 $451,445,481 $745,692,126 $1,146,563,332 $2,018,162,850 

4/30/2036 $91,803,074 $416,017,763 $724,679,774 $1,159,746,136 $2,126,219,937 

4/30/2037 $36,428,961 $378,987,433 $717,791,312 $1,181,112,119 $2,216,039,172 

4/30/2038 insolvent $338,979,940 $696,654,712 $1,206,611,971 $2,297,900,164 

4/30/2039 $295,192,194 $679,558,676 $1,233,472,532 $2,427,133,553 

4/30/2040 $255,321,586 $667,040,529 $1,265,976,969 $2,552,851,236 

4/30/2041 $210,126,569 $649,359,627 $1,283,674,009 $2,756,375,240 

4/30/2042 $161,391,671 $641,555,510 $1,314,653,092 $2,830,079,791 

4/30/2043 $116,271,132 $619,532,039 $1,359,908,550 $2,994,198,999 

4/30/2044 $67,775,183 $603,850,153 $1,394,408,566 $3,195,301,857 

4/30/2045 $19,992,225 $592,888,541 $1,420,246,042 $3,368,143,237 

4/30/2046 insolvent $582,617,489 $1,475,931,491 $3,563,101,461 

4/30/2047 $575,405,796 $1,540,600,206 $3,803,852,972 

4/30/2048 $563,217,689 $1,621,413,023 $4,047,206,970 

4/30/2049 $566,019,146 $1,703,922,581 $4,446,104,741 

4/30/2050 $558,207,864 $1,797,051,711 $4,713,307,638 

4/30/2051 $563,750,787 $1,897,965,861 $5,130,235,571 

4/30/2052 $567,077,077 $1,988,465,212 $5,489,678,140 

CPTF000122 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.4

Exhibit III – Frequency Distribution of Portfolio B Transition

First Year that Projected Cash Flows are Less Than -7.5% of Assets (Portfolio B Trigger)

May 1, Trials Percent

Cumulative

Percent May 1, Trials Percent

Cumulative

Percent

2022 0 0.00% 0.00% 2037 51 1.02% 63.18%

2023 2 0.04% 0.04% 2038 31 0.62% 63.80%

2024 67 1.34% 1.38% 2039 25 0.50% 64.30%

2025 257 5.14% 6.52% 2040 21 0.42% 64.72%

2026 408 8.16% 14.68% 2041 13 0.26% 64.98%

2027 418 8.36% 23.04% 2042 10 0.20% 65.18%

2028 433 8.66% 31.70% 2043 11 0.22% 65.40%

2029 375 7.50% 39.20% 2044 6 0.12% 65.52%

2030 297 5.94% 45.14% 2045 1 0.02% 65.54%

20311 244 4.88% 50.02% 2046 2 0.04% 65.58%

2032 201 4.02% 54.04% 2047 1 0.02% 65.60%

20332 161 3.22% 57.26% 2048 0 0.00% 65.60%

2034 114 2.28% 59.54% 2049 2 0.04% 65.64%

2035 82 1.64% 61.18% 2050 1 0.02% 65.66%

2036 49 0.98% 62.16% 2051 0 0.00% 65.66%

never 1,717 34.34% 100.00%

5,000 100.00%

1 Median transition date is 5/1/2031

2 Assumed transition date for basic modeling is 5/1/2033

CPTF000123 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #10 – 4.02(2) Demonstration that Proposed Suspension Is Reasonably Estimated 

to Enable the Plan to Avoid Insolvency Utilizing Stochastic Projections

10.5

Exhibit IV – Additional Stochastic Results

We present below the probability of maintaining a positive asset value over the extended period

under our baseline portfolio transition dates for capital market assumptions and under two 

alternate assumptions. We also present the probability of avoiding the trigger for Portfolio C 

(triggered when negative cash flow exceeds 12.5% of assets).

Scenario

Assumed Portfolio 

Transition Dates

Probability of 

Maintaining Positive 

Asset Values

Probability of 

Avoiding Portfolio 

A to B B to A C Trigger

Baseline 5/1/2033 5/1/2046 66.08% 55.82%

Alternate #1 5/1/2031 5/1/2046 65.72% 54.96%

Alternate #2 5/1/2031 never 65.60% 54.98%

CPTF000124 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to 

not Materially Exceed the Level Necessary to Avoid Insolvency

11.0

Does the application include a demonstration that the proposed suspension is not projected to 

materially exceed the level necessary to avoid insolvency, including:

• the plan-year-by-plan-year projections demonstrating projected insolvency during the 

relevant period, and

• a separate identification of the available resources (and the market value of assets and 

changes in cash flow) during each of those years?

See section 4.03 of Revenue Procedure 2017-43.

Document 11.1 provides a demonstration that the proposed suspension is not projected to 

materially exceed the level necessary to avoid insolvency based on a deterministic projection.

Document 11.2 provides a demonstration of the probability that the plan will maintain a positive 

fund balance throughout the entire extended period prepared using stochastic projections and 

assuming that the dollar amount of the proposed suspension for each participant and beneficiary 

was reduced as described in Section 4.03 of the Revenue Procedure.

CPTF000125 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to 

not Materially Exceed the Level Necessary to Avoid Insolvency

11.1

Document 11.1

Demonstration That the Proposed Suspension Is Not Projected To Materially Exceed the Level 

Necessary to Avoid Insolvency Based On a Deterministic Projection

As required by Revenue Procedure 2017-43, Section 4.03, the application must include a 

deterministic projection demonstrating that, if the dollar amount of the proposed suspension for 

each participant and beneficiary was reduced by the greater of:

• 5% of the reduction in payment proposed for that participant or beneficiary, or 

• 2% of that participant’s or beneficiary’s payment determined without regard to the 

proposed reduction,

then the Plan would not be reasonably estimated to avoid insolvency. For purposes of this 

checklist item, we interpret the phrase “avoid insolvency” to mean that the plan satisfies the 

requirements of sub-paragraphs (1)-(3) of Regulation 1.432(e)(9)-1(d)(5)(ii)(A).

Exhibit I provides plan-year-by-plan-year projections demonstrating that, under the reduced 

suspension as described above, the plan would not satisfy the requirements of sub-paragraph (3) 

of Regulation 1.432(e)(9)-1(d)(5)(ii)(A), requiring that, 

Unless the plan’s projected funded percentage (within the meaning of section 

432(j)(2)) at the end of the extended period using the deterministic projection 

described in paragraph (d)(5)(ii)(A)(1) of this section exceeds 100 percent, that 

projection shows that, during each of the last five plan years of that period, neither 

the plan’s solvency ratio nor its available resources (as defined in section 

418E(b)(3)) is projected to decrease.

and therefore does not “avoid insolvency.” Available resources are separately identified for each 

year.

The illustration is based on the actuary’s interpretation of the requirements under Revenue 

Procedure 2017-43, Section 4.03. 

Checklist Item #25 describes each of the assumptions used, as required under Revenue 

Procedure 2017-43, Section 4.02(3).

CPTF000126 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to not Materially Exceed the Level 

Necessary to Avoid Insolvency

11.2

Exhibit I – Deterministic Projection Based on Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2021 through April 30, 2052 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2021 $721,637,632 $98,242,244 $1,333,196 $0 $157,972,946 $6,106,627 $61,377,850 $718,511,349 $876,484,295 5.55

4/30/2022 $718,511,349 $103,950,000 $36,159 $963,841 $135,947,772 $4,688,160 $45,543,445 $728,368,862 $864,316,634 6.36

4/30/2023 $728,368,862 $103,950,000 $36,159 $963,841 $133,373,191 $4,288,676 $46,280,840 $741,937,835 $875,311,026 6.56

4/30/2024 $741,937,835 $102,465,000 $36,159 $763,841 $136,158,042 $4,391,604 $47,014,208 $751,667,397 $887,825,439 6.52

4/30/2025 $751,667,397 $102,465,000 $36,159 $613,841 $139,219,227 $4,497,002 $47,538,841 $758,605,009 $897,824,236 6.45

4/30/2026 $758,605,009 $102,465,000 $36,159 $613,841 $142,230,484 $4,604,930 $47,888,412 $762,773,007 $905,003,491 6.36

4/30/2027 $762,773,007 $102,465,000 $36,159 $613,841 $145,170,503 $4,715,448 $48,060,190 $764,062,246 $909,232,749 6.26

4/30/2028 $764,062,246 $102,465,000 $36,159 $613,841 $148,008,036 $4,828,619 $48,048,092 $762,388,683 $910,396,719 6.15

4/30/2029 $762,388,683 $102,465,000 $36,159 $613,841 $150,842,649 $4,944,506 $47,843,419 $757,559,947 $908,402,596 6.02

4/30/2030 $757,559,947 $102,465,000 $36,159 $613,841 $153,463,951 $5,063,174 $47,440,502 $749,588,324 $903,052,275 5.88

4/30/2031 $749,588,324 $102,465,000 $36,159 $613,841 $155,808,771 $5,184,690 $52,967,708 $744,677,571 $900,486,342 5.78

4/30/2032 $744,677,571 $102,465,000 $36,159 $613,841 $157,905,104 $5,309,123 $52,525,155 $737,103,499 $895,008,603 5.67

4/30/2033 $737,103,499 $102,465,000 $36,159 $613,841 $159,670,219 $5,436,542 $51,898,910 $727,010,648 $886,680,867 5.55

4/30/2034 $727,010,648 $102,465,000 $12,056 $637,944 $161,026,643 $5,567,019 $41,930,814 $705,462,800 $866,489,443 5.38

4/30/2035 $705,462,800 $102,465,000 $7,236 $642,764 $161,808,413 $5,700,627 $45,445,440 $686,514,200 $848,322,613 5.24

4/30/2036 $686,514,200 $102,465,000 $7,236 $642,764 $162,196,058 $5,837,442 $44,148,709 $665,744,409 $827,940,467 5.10

4/30/2037 $665,744,409 $102,465,000 $7,236 $642,764 $162,215,128 $5,977,541 $42,741,376 $643,408,116 $805,623,244 4.97

4/30/2038 $643,408,116 $102,465,000 $3,618 $646,382 $161,948,956 $6,121,002 $41,237,818 $619,690,976 $781,639,932 4.83

4/30/2039 $619,690,976 $102,465,000 $0 $650,000 $161,133,830 $6,267,906 $39,659,464 $595,063,704 $756,197,534 4.69

4/30/2040 $595,063,704 $102,465,000 $0 $650,000 $160,149,524 $6,418,336 $38,025,266 $569,636,110 $729,785,634 4.56

4/30/2041 $569,636,110 $102,465,000 $0 $650,000 $158,609,487 $6,572,376 $36,355,681 $543,924,928 $702,534,415 4.43

4/30/2042 $543,924,928 $102,465,000 $0 $650,000 $156,927,859 $6,730,113 $34,671,607 $518,053,563 $674,981,422 4.30

CPTF000127 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to not Materially Exceed the Level 

Necessary to Avoid Insolvency

11.3

Exhibit I – Deterministic Projection Based on Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03

(cont.)

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2043 $518,053,563 $102,465,000 $0 $650,000 $154,887,399 $6,891,636 $32,988,704 $492,378,232 $647,265,631 4.18

4/30/2044 $492,378,232 $102,465,000 $0 $650,000 $152,333,143 $7,057,035 $31,336,243 $467,439,297 $619,772,440 4.07

4/30/2045 $467,439,297 $102,465,000 $0 $650,000 $149,735,101 $7,226,404 $29,734,833 $443,327,625 $593,062,726 3.96

4/30/2046 $443,327,625 $102,465,000 $0 $650,000 $146,917,288 $7,399,838 $28,196,543 $420,322,042 $567,239,330 3.86

4/30/2047 $420,322,042 $102,465,000 $0 $650,000 $143,848,770 $7,577,434 $29,118,233 $401,129,071 $544,977,841 3.79

4/30/2048 $401,129,071 $102,465,000 $0 $650,000 $140,469,886 $7,759,292 $27,825,041 $383,839,934 $524,309,820 3.73

4/30/2049 $383,839,934 $102,465,000 $0 $650,000 $136,983,272 $7,945,515 $26,675,578 $368,701,725 $505,684,997 3.69

4/30/2050 $368,701,725 $102,465,000 $0 $650,000 $133,462,341 $8,136,207 $25,685,306 $355,903,483 $489,365,824 3.67

4/30/2051 $355,903,483 $102,465,000 $0 $650,000 $129,786,031 $8,331,476 $24,872,564 $345,773,540 $475,559,571 3.66

4/30/2052 $345,773,540 $102,465,000 $0 $650,000 $126,056,175 $8,531,431 $24,257,737 $338,558,671 $464,614,846 3.69

CPTF000128 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to 

not Materially Exceed the Level Necessary to Avoid Insolvency

11.4

Document 11.2

Demonstration That the Proposed Suspension Is Not Projected To Materially Exceed the Level 

Necessary to Avoid Insolvency Based On a Stochastic Projection

As required by Revenue Procedure 2017-43, Section 4.03, the application must include a 

demonstration utilizing stochastic projections that, if the dollar amount of the proposed 

suspension for each participant and beneficiary was reduced by the greater of:

• 5% of the reduction in payment proposed for that participant or beneficiary, or 

• 2% of that participant’s or beneficiary’s payment determined without regard to the 

proposed reduction,

then the Plan would not be reasonably estimated to avoid insolvency.

For purposes of this checklist item, we interpret the phrase “avoid insolvency” to mean that the 

plan satisfies the requirements of sub-paragraphs (1)-(3) of Regulation 1.432(e)(9)-1(d)(5)(ii)(A). 

Exhibit I provides a projection demonstrating that, under the reduced suspension as described 

above, the plan would not satisfy the requirements of sub-paragraph (3) of Regulation 

1.432(e)(9)-1(d)(5)(ii)(A). Since the reduced suspension does not satisfy sub-paragraph (3), it 

cannot “avoid insolvency” regardless of the results of stochastic projections.

This Document 11.2 summarizes the results of 5,000 stochastic trials. Each trial consists of a 

projection of the market value of Plan assets for the plan years ending April 30, 2021 through 

2052 assuming implementation of the hypothetical reduced suspension as outlined above. We 

calculated the percentage of trials that resulted in fund assets remaining above $0 during the 

entire extended period as follows:

The probability of positive assets over the entire extended period is: 57.14%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are shown 

below in graphical format in Exhibit I and in tabular format in Exhibit II. 

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

CPTF000129 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to 

not Materially Exceed the Level Necessary to Avoid Insolvency

11.5

Exhibit I – Graphical Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03 Utilizing 

Stochastic Projections

CPTF000130 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #11 – Demonstration that the Proposed Suspension is Reasonably Estimated to 

not Materially Exceed the Level Necessary to Avoid Insolvency

11.6

Exhibit II – Tabular Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03 Utilizing 

Stochastic Projections

Plan Year 

Ending

Market Value of Plan Assets – 5,000 Trials

5

th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2020 $721,637,632 $721,637,632 $721,637,632 $721,637,632 $721,637,632 

4/30/2021 $718,511,349 $718,511,349 $718,511,349 $718,511,349 $718,511,349 

4/30/2022 $612,675,791 $677,709,778 $726,162,979 $780,833,777 $872,834,432 

4/30/2023 $574,706,520 $670,555,118 $742,927,114 $825,629,036 $963,718,725 

4/30/2024 $545,385,298 $658,521,744 $749,721,707 $861,536,536 $1,048,969,379 

4/30/2025 $511,901,181 $642,862,316 $752,435,960 $890,780,238 $1,113,066,064 

4/30/2026 $480,643,150 $630,052,866 $757,402,679 $917,401,739 $1,183,183,847 

4/30/2027 $441,151,166 $614,336,338 $760,931,143 $941,285,990 $1,240,963,409 

4/30/2028 $411,509,610 $590,197,896 $758,336,193 $951,429,638 $1,322,647,250 

4/30/2029 $375,453,521 $568,326,879 $750,852,434 $973,972,914 $1,388,797,289 

4/30/2030 $333,501,612 $541,723,138 $743,791,241 $996,202,122 $1,466,157,474 

4/30/2031 $298,265,208 $516,741,677 $736,641,585 $1,009,548,807 $1,558,657,603 

4/30/2032 $251,741,920 $492,762,929 $727,546,580 $1,022,481,051 $1,649,114,450 

4/30/2033 $203,250,978 $460,644,135 $705,170,572 $1,037,517,557 $1,744,880,078 

4/30/2034 $146,275,407 $423,024,148 $689,139,367 $1,047,403,680 $1,832,030,937 

4/30/2035 $87,966,291 $382,869,371 $671,041,718 $1,058,779,493 $1,917,411,733 

4/30/2036 $25,215,408 $343,781,340 $641,691,195 $1,060,269,306 $2,009,305,934 

4/30/2037 insolvent $294,545,967 $620,175,139 $1,076,710,374 $2,097,418,674 

4/30/2038 $244,963,440 $593,605,158 $1,081,563,885 $2,155,834,692 

4/30/2039 $194,677,194 $564,770,912 $1,091,742,119 $2,262,135,526 

4/30/2040 $139,116,790 $539,613,453 $1,115,995,713 $2,366,919,169 

4/30/2041 $82,896,472 $509,917,439 $1,123,808,319 $2,565,308,434 

4/30/2042 $26,791,118 $480,606,213 $1,133,447,972 $2,623,860,414 

4/30/2043 insolvent $456,336,513 $1,160,926,391 $2,740,813,269 

4/30/2044 $427,269,400 $1,174,929,896 $2,913,895,298 

4/30/2045 $399,031,512 $1,190,623,571 $3,075,588,874 

4/30/2046 $368,569,779 $1,229,443,824 $3,243,313,481 

4/30/2047 $341,906,851 $1,277,756,584 $3,447,262,060 

4/30/2048 $318,161,804 $1,312,935,433 $3,657,306,542 

4/30/2049 $299,430,662 $1,373,034,644 $4,013,726,462 

4/30/2050 $284,415,544 $1,429,949,032 $4,272,292,371 

4/30/2051 $255,850,630 $1,517,921,540 $4,650,225,671 

4/30/2052 $242,577,702 $1,586,436,165 $4,925,796,080 

CPTF000131 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.0

Does the application include a demonstration that the proposed suspension is equitably 

distributed, including:

• information on the effect of the suspension on the plan in the aggregate,

• information on the effect of the suspension for different categories or groups,

• a list of the factors taken into account,

• an explanation of why none of the factors listed in § 432(e)(9)(D)(vi) were taken into 

account (if applicable),

• for each factor taken into account that is not one of the factors listed in § 432(e)(9)(D)(vi), 

an explanation why the factor is relevant, and

• an explanation of how any difference in treatment among categories or groups of 

individuals results from a reasonable application of the relevant factors?

See section 4.04 of Revenue Procedure 2017-43.

Document 12.1 presents the Pension Plan’s demonstration, in consultation with its actuary, that 

the proposed suspension is equitably distributed. 

CPTF000132 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.1

Document 12.1

The Pension Plan’s Demonstration

of Equitable Distribution

Effect of Proposed Suspension on the Plan in the Aggregate

Exhibit I provides the information on the effect of the suspension required by sub-section 

4.04(1)(a) of Revenue Procedure 2017-43 on an aggregate basis. 

Exhibit II provides the distribution of participants by benefit reduction percentage on an 

aggregate basis as required by sub-section 4.04(1)(b) of Revenue Procedure 2017-43.

Effect of Proposed Suspension on the Plan on a Group-by-group Basis

Exhibit III provides the information on the effect of the suspension described in sub-section 

4.04(1)(a) of Revenue Procedure 2017-43 broken out according to the groupings described in 

Checklist Item #2, as required by sub-section 4.04(2)(a) of Revenue Procedure 2017-43. 

Exhibits IV through XV provide the distribution of participants by benefit reduction percentage

described in sub-section 4.04(1)(b) of Revenue Procedure 2017-43 on a group-by-group basis, as 

required by sub-section 4.04(2)(a) of Revenue Procedure 2017-43. Note that groups B2 and C2 

do not include any participants, so there are no exhibits included for these groups.

Please refer to the following table:

Group Description Exhibit

A1 Non-Retired, pre-5/1/2007 accruals only IV

A2 Non-Retired, post-5/1/2007 accruals only V

A3 Non-Retired, pre- and post-5/1/2007 accruals VI

B1

Retiree with benefit reduction effective 8/1/2013, pre-5/1/2007 accruals 

only VII

B2

Retiree with benefit reduction effective 8/1/2013, post-5/1/2007 

accruals only n/a

B3

Retiree with benefit reduction effective 8/1/2013, pre- and post5/1/2007 accruals VIII

C1

Beneficiary of the October 2016 disability lawsuit settlement, pre5/1/2007 accruals only IX

C2

Beneficiary of the October 2016 disability lawsuit settlement, post5/1/2007 accruals only n/a

C3

Beneficiary of the October 2016 disability lawsuit settlement, pre- and 

post-5/1/2007 accruals X

D1 Retiree not included in a B or C group, pre-5/1/2007 accruals only XI

CPTF000133 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.2

Group Description Exhibit

D2 Retiree not included in a B or C group, post-5/1/2007 accruals only XII

D3 Retiree not included in a B or C group, pre- and post-5/1/2007 accruals XIII

Calculation of Average Benefits and Percentage Cuts

Average Benefits and Cuts for non-pay status participants were calculated assuming payment in 

the life form of benefit at normal retirement age (or current age if older). Pay status Average 

Benefits and Cuts were based upon actual benefits in pay status.

Handling of Non-Participants

Employees who have not yet satisfied the Plan’s initial participation requirements have been 

excluded from this analysis. There were 995 non-participants included in the valuation runs. 

None of these people had accruals before 5/1/2007 and therefore they are not impacted by the 

proposed suspension.

Identification of Factors Taken Into Account

<<counsel>>

Explanation as to Why No Factors Listed in IRC Section 432(e)(9)(D)(vi)(I) through (XI) Were 

Taken Into Account

<<counsel>>

Relevance of Factors Not Listed in IRC Section 432(e)(9)(D)(vi)(I) through (XI)

<<counsel>>

Differences in Treatment Among Groups Result from Reasonable Application of Relevant 

Factors

<<counsel>>

CPTF000134 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.3

Exhibit I –Effect of Suspension – Aggregate Basis

Group Count

Average Monthly

Benefit Before 

Suspension

Average Monthly

Benefit After 

Suspension

PV Reduction in 

Benefits

All 18,457 $ 1,467.82 $ 1,145.99 $ 510,478,182

CPTF000135 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.4

Exhibit II – Distribution of Participants by Benefit Reduction Percentage – Aggregate Basis

Benefit Reduction

Percentage Count

Percentage

of Total

None 5,171 28.02%

0.001% to 10% 2,316 12.55%

10.001% to 20% 2,097 11.36%

20.001% to 30% 4,515 24.46%

30.001% to 40% 4,358 23.61%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000136 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.5

Exhibit III – Effect of Suspension – Group-by-group Basis

Group Count

Average Monthly

Benefit Before 

Suspension

Average Monthly

Benefit After 

Suspension

PV Reduction in 

Benefits

A1 3,695 $ 606.94 $ 426.41 $ 41,536,308

A2 2,439 301.66 301.66 0

A3 4,966 2,230.95 1,739.21 127,897,801

B1 43 1,583.77 1,252.01 1,861,809

B2 0 0.00 0.00 0

B3 499 3,912.78 2,895.80 66,685,629

C1 22 2,003.63 1,469.65 1,137,134

C2 0 0.00 0.00 0

C3 270 2,690.76 1,998.06 17,467,890

D1 5,225 1,329.05 1,094.84 142,207,795

D2 8 141.15 141.15 0

D3 1,290 2,556.33 1,868.98 111,683,815

CPTF000137 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.6

Exhibit IV – Distribution of Participants by Benefit Reduction Percentage – Group A1

Benefit Reduction

Percentage Count

Percentage

of Total

None 300 8.12%

0.001% to 10% 721 19.51%

10.001% to 20% 289 7.82%

20.001% to 30% 236 6.39%

30.001% to 40% 2,149 58.16%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000138 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.7

Exhibit V – Distribution of Participants by Benefit Reduction Percentage – Group A2

Benefit Reduction

Percentage Count

Percentage

of Total

None 2,439 100.00%

0.001% to 10% 0 0.00%

10.001% to 20% 0 0.00%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000139 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.8

Exhibit VI – Distribution of Participants by Benefit Reduction Percentage – Group A3

Benefit Reduction

Percentage Count

Percentage

of Total

None 99 1.99%

0.001% to 10% 639 12.87%

10.001% to 20% 1,260 25.37%

20.001% to 30% 2,333 46.98%

30.001% to 40% 635 12.79%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000140 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.9

Exhibit VII – Distribution of Participants by Benefit Reduction Percentage – Group B1

Benefit Reduction

Percentage Count

Percentage

of Total

None 1 2.33%

0.001% to 10% 5 11.63%

10.001% to 20% 4 9.30%

20.001% to 30% 33 76.74%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000141 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.10

Exhibit VIII – Distribution of Participants by Benefit Reduction Percentage – Group B3

Benefit Reduction

Percentage Count

Percentage

of Total

None 1 0.20%

0.001% to 10% 3 0.60%

10.001% to 20% 10 2.00%

20.001% to 30% 484 97.00%

30.001% to 40% 1 0.20%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000142 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.11

Exhibit IX – Distribution of Participants by Benefit Reduction Percentage – Group C1

Benefit Reduction

Percentage Count

Percentage

of Total

None 0 0.00%

0.001% to 10% 3 13.64%

10.001% to 20% 19 86.36%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000143 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.12

Exhibit X – Distribution of Participants by Benefit Reduction Percentage – Group C3

Benefit Reduction

Percentage Count

Percentage

of Total

None 6 2.22%

0.001% to 10% 5 1.85%

10.001% to 20% 32 11.85%

20.001% to 30% 226 83.71%

30.001% to 40% 1 0.37%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000144 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.13

Exhibit XI – Distribution of Participants by Benefit Reduction Percentage – Group D1

Benefit Reduction

Percentage Count

Percentage

of Total

None 2,297 43.96%

0.001% to 10% 863 16.52%

10.001% to 20% 414 7.92%

20.001% to 30% 479 9.17%

30.001% to 40% 1,172 22.43%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000145 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.14

Exhibit XII – Distribution of Participants by Benefit Reduction Percentage – Group D2

Benefit Reduction

Percentage Count

Percentage

of Total

None 8 100.00%

0.001% to 10% 0 0.00%

10.001% to 20% 0 0.00%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000146 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension Is Distributed 

Equitably

12.15

Exhibit XIII – Distribution of Participants by Benefit Reduction Percentage – Group D3

Benefit Reduction

Percentage Count

Percentage

of Total

None 21 1.63%

0.001% to 10% 79 6.12%

10.001% to 20% 85 6.59%

20.001% to 30% 705 54.65%

30.001% to 40% 400 31.01%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF000147 CPTF -