WESTERN STATES OFFICE AND 

PROFESSIONAL EMPLOYEES PENSION FUND

THIRD SUSPENSION APPLICATION 

Exhibit 14

Exhibit 14: Page 1 of 62
WESTERN STATES OFFICE AND

PROFESSIONAL 

EMPLOYEES

PENSION FUND

SUMMARY PLAN DESCRIPTION

AND

PLAN BOOKLET

This SPD and Plan Booklet is current as of January 1, 2017.

OPEIU

Exhibit 14: Page 2 of 62
CONTENTS

Pages

Letter from Trustees i 

Special Notices ii

Why Do We Have A Pension Plan? iii

Summary of Age and Service Requirements iv

YOUR PENSION PLAN

Participation 1 

Hours of Work 2 

Vesting Credit 3 

Benefit Credits and Determination of Benefits 5 

Retirement Benefits 7 

Survivor Benefits in Event of Your Death 18 

Disability Benefits 21 

Circumstances Under Which Benefits Will Not Be

 Received and Pension Credits Will Be Lost 22 

How You Apply for Benefits 26 

Claims Appeal Procedures 28 

Review Procedures 29 

Rollovers 30 

Other Provisions 32 

If Plan Merges or Terminates 34 

The Plan and Plan Administration 35 

How to Secure Additional Information 37 

Your Rights Under ERISA 39 

ADDENDUM

Addendum A: Plan Technical Provisions 40 

Addendum B: Heroes Assistance and Relief Tax Act Amendment 46 

This booklet contains important information about your retirement benefits. 

After you have read this booklet please file it with your valuable papers. You 

should keep your annual status reports with your booklet.

Exhibit 14: Page 3 of 62
LETTER FROM THE BOARD OF TRUSTEES

WESTERN STATES OFFICE AND PROFESSIONAL

EMPLOYEES PENSION FUND

1220 S.W. Morrison St, Suite 300 

Portland. OR 97205-2222 

Toll-Free: (800) 413-4928 

Local: (503) 222-7694 

TO COVERED EMPLOYEES, BENEFICIARIES,

AND PARTICIPATING EMPLOYERS:

The Trustees of the Western States Office and Professional Employees Pension Fund (called 

the “Pension Plan” or “Plan” in this booklet) are pleased to present you with a revised edition of 

your Pension Plan Booklet. 

Pages 1 through 37 of this Booklet, written in everyday language, constitute the formal 

Pension Plan as well as the “Summary Plan Description” required by ERISA.

The IRS requires that all tax-qualified pension plans must be updated and restated from time 

to time to reflect legislative and regulatory changes. This version of the Plan is updated and restated 

by the Board of Trustees to comply with the “PPA” restatement requirement.

1

 The Board of 

Trustees has submitted this Plan to the IRS for a favorable advance determination letter and adopts 

this Plan subject to IRS approval. No amendment to the Plan shall take away any vested right of a 

Participant who was previously vested. 

REVIEW THIS BOOKLET CAREFULLY TO ASCERTAIN YOUR STATUS AND 

RIGHTS UNDER THE PLAN. If you have any question, the Plan Administration Office will be 

happy to assist you if you have any questions. 

THE TRUSTEES OF THE WESTERN STATES

OFFICE AND PROFESSIONAL EMPLOYEES

PENSION FUND

1

 “PPA” stands for the Pension Protection Act. This PPA restatement includes good faith amendments for subsequently 

adopted legislative and regulatory changes.

Exhibit 14: Page 4 of 62
SPECIAL NOTICES

OBLIGATIONS OF PARTICIPANTS

It is extremely important that you keep the Plan Administration Office informed of any 

change in your address. This is your obligation and failure to fulfill it could possibly delay the 

payment of your benefits. The importance of our having your current, correct address on file cannot 

be overstated! It is the ONLY WAY the Trustees can contact you regarding changes and other 

developments affecting your interests under the Plan. 

 It is also important that you designate a beneficiary and notify the Plan Administration Office 

if you wish to change your designated beneficiary. Failure to do so may result in the wrong person 

obtaining benefits. This is especially important if you are divorced.

You should contact the Plan Administration Office for a copy of the Plan’s current forms if 

you have a change in address or desire a change in beneficiary. The forms are available for 

downloading at the Plan’s website: http://www.wsp.aibpa.com. 

PLAN INTERPRETATIONS:

Only the Board of Trustees is authorized to interpret the Plan. Employers, unions and their 

representative, and individual Trustees are not authorized to interpret this Plan. 

The Plan Administration Office is the Agent for the Board of Trustees. Any questions you 

have about the Plan should be directed only to the Board of Trustees or the Plan Administration 

Office. Address your inquiries to: 

Board of Trustees

Western States Office and Professional Employees Pension Fund

c/o Benesys, Inc.

1220 S.W. Morrison St, Suite 300 

Portland. OR 97205-2222 

PLAN ADMINISTRATION OFFICE: 

Address and contract information for the Plan Administration Office:

BeneSys, Inc. 

1220 S.W. Morrison St, Suite 300 

Portland. OR 97205-2222 

Toll-Free: (800) 413-4928 

Local (Oregon): (503) 222-7694 

A copy of the Plan document, important Plan administration documents and downloadable 

forms are available at the Plan’s website: http://www.wsp.aibpa.com. 

Exhibit 14: Page 5 of 62
WHY DO WE HAVE

A PENSION PLAN?

Supplementing Social Security retirement is a concern of many individuals when they retire. 

Some of us prepare for our retirement during our younger years. Many of us ignore the problem 

when we are young, thinking that retirement is in the future. When we finally become concerned 

about adequate income, it may be too late to accumulate sufficient funds to care adequately for our 

needs.

One method of supplementing Social Security benefits is through a pension plan provided for 

by collective bargaining agreements between employers and unions. This method allows us to 

accumulate pension credits during our active working years. Such a program – for office and 

professional employees who are represented by the Office and Professional Employees International 

Union – is described in this booklet. 

All of the benefits provided by the Western States Office and Professional Employees 

Pension Plan are in addition to Social Security benefits. Thus, Social Security benefits, your 

employer-union negotiated pension plan, and your own personal assets can combine to provide you 

with an income during your retirement years.

Exhibit 14: Page 6 of 62
SUMMARY OF AGE AND SERVICE REQUIREMENTS

FOR BENEFITS PROVIDED BY THE

WESTERN STATES OFFICE AND

PROFESSIONAL EMPLOYEES

PENSION PLAN

YOU BECOME ELIGIBLE FOR BENEFITS

BASED ON YOUR AGE AND LENGTH OF SERVICE

YOUR

AGE

BENEFIT TYPE WITH 5 YEARS VESTING CREDIT

(INCLUDING 2 YEARS OF CONTRIBUTORY VESTING CREDIT)

Any Age Eligible for Disability Benefit if you have 200 hours of work during 

the twelve months prior to your disability. 

Ages 55 through 64 Eligible for Early Retirement Benefit.

Ages 65 & Older2 Eligible for Normal Retirement Benefit.

Age 70-1/2 Mandatory receipt of Retirement Benefits on April 1st following the 

calendar year in which you attain age 70-1/2 if you are not still 

working or if you are a 5% owner of your employer. 

SPECIAL RULE – If you are AGE 65 or older with two or more years of contributory Vesting 

Credit, see page 6 for possible qualification for Normal Retirement Benefits.

YOUR SURVIVORS BECOME ELIGIBLE FOR CERTAIN BENEFITS UPON YOUR DEATH 

BASED ON YOUR LENGTH OF SERVICE.

 

YOUR

AGE

BENEFIT TYPE WITH 5 YEARS VESTING CREDIT

(INCLUDING 2 YEARS OF CONTRIBUTORY VESTING CREDIT)

Any Age Lifetime Benefit to spouse or other party (if you elect an annuity option with a 

survivor’s benefit). 

2

 Normal Retirement at age 65 is effective for retirement on or after January 1, 2010. Prior to that date Normal 

Retirement was available at age 62.

Exhibit 14: Page 7 of 62
Your

WESTERN STATES OFFICE AND PROFESSIONAL

EMPLOYEES PENSION PLAN

This Plan is current as of January 1, 2017. 

On October 14, 2014, the Board of Trustees adopted this updated and 

restated Plan in order to comply with the Pension Protection Act of 2006, 

and subsequent legislative, regulatory and discretionary changes. This Plan 

was submitted to the IRS for approval. The IRS issued a favorable 

advisory letter dated July 18, 2016. The advisory letter covers the updated 

and restated Plan, as well as subsequent amendments.

Benefits earned prior to October 14, 2014, are subject to, and paid according to, the Plan 

provisions then in effect. The former Plan Booklets (and Summary of Material 

Modifications) describe those benefits and will be furnished to you upon written request. 

PARTICIPATION

You are a Participant in the Western States Office and Professional Employees Pension Plan 

when: 

(a) you are covered by a collective bargaining agreement negotiated by a local of the 

Office and Professional Employees International Union under which your Employer 

agrees to make pension contributions into the Western States Office and Professional 

Employees Pension Fund, and 

(b) your Employer has been approved by the Board of Trustees as a contributing 

Employer, and

(c) your Employer has made pension contributions on your behalf for at least 200 hours 

of work in any calendar year. 

You may also become a participant if you meet the requirements of Section 3.3 of the Trust

Agreement for the Western States Office and Professional Employees Pension Fund and your 

participation is approved by the Board of Trustees. 

Retirees and other beneficiaries are considered participants.

There are many different collective bargaining agreements in force between the various local 

Unions and the hundreds of contributing Employers. Your own collective bargaining agreement will 

state when your Employer makes contributions on your behalf and the amount of the contributions. 

The entire cost of the Pension Plan is paid by the Employers. No contributions by employees are 

permitted by the Plan.

Exhibit 14: Page 8 of 62
You should be certain that the Plan Administration Office has your correct address, birth 

date, employment records, and other information needed by the Plan. You should file an 

“Enrollment Form and Past Service Claim” with the Plan Administration Office. This form is 

available from your Employer, your local Union office, the Plan Administration Office or online at 

the Plan’s website: http://www.wsp.aibpa.com. 

Exhibit 14: Page 9 of 62
HOURS OF WORK

“Hours of Work” are used in determining Vesting Credits (page 3), Benefit Credits (page 4), 

and Breaks in Service (page 21).

An “hour of work” means an hour for which you are either directly or indirectly entitled to 

payment by a contributing Employer for the performance of duties for the Employer or for a period 

of time during which no duties were performed, or an hour for which back pay is paid by the 

Employer.

An hour in which you perform no duties for the Employer will be credited according to 

Department of Labor regulation 2530.200b-2(b) and (c).

You will not receive credit for more than 501 hours of work for any single continuous period 

of time during which you performed no duties and during which your Employer is not required to 

contribute to the Pension Plan on your behalf. 

Your Employer normally reports and contributes only on hours for which you are paid. You 

will receive hours of work for the period of time that you have qualified military service and you are 

reemployed pursuant to the Uniformed Services Employment and Reemployment Rights Act. If you 

are entitled to credit for hours for which you have not been paid or are paid by another party (such as 

for disability benefits which were paid for by the Employer), you should contact the Plan 

Administration Office for the appropriate reporting form or download the form online at: 

http://www.wsp.aibpa.com. If you qualify, you will be credited with the appropriate number of 

hours. 

The contribution will be computed by multiplying the number of qualified hours by your 

Employer’s pension contribution, or its equivalent, as stated in your collective bargaining agreement 

at the date the hours were earned.

Exhibit 14: Page 10 of 62
VESTING CREDIT

If you lose or quit your job after you earn five years of Vesting Credit, as described below, 

but before becoming qualified for a normal or early retirement benefit, you still have a right to 

receive benefits at retirement age. This right is called a “vested” right or a “deferred vested benefit.”

PAST SERVICE VESTING CREDIT

Past Service Vesting Credit is based on employment, prior to the time the first pension 

contribution is made on your behalf, with any Employer who has been, is, or becomes a contributing 

Employer to this Pension Plan. 

You earn one year of Past Service Vesting Credit for each calendar year in which you had 

500 hours or more of work for such an Employer subsequent to any break in continuous service. A 

break in continuous service for determining Past Service Vesting Credit occurred if you did not have 

an hour of work for a contributing Employer for two successive calendar years. If the first month for 

which Employer contributions are made on your behalf is other than January, you will receive a 

partial year of Past Service Vesting Credit for that year.

CONTRIBUTORY SERVICE VESTING CREDIT

After you become a participant in the Plan, you will receive one year of Contributory Service 

Vesting Credit for each calendar year during which you have 200 hours of work in any capacity for 

any contributing Employer or receive credit pursuant to the Uniformed Services Employment and 

Reemployment Rights Act.

TOTAL SERVICE VESTING CREDIT

Your Total Service Vesting Credit in years is the total of your Past Service Vesting Credit 

and your Contributory Service Vesting Credit. You cannot earn more than one year of Vesting 

Credit in any one calendar year.

VESTED STATUS

You are a Vested Participant if:

(a) you have five years of Total Service Vesting Credit, including two years of 

Contributory Service Vesting Credit, provided that you did not incur a 

Permanent Break in Service on or before December 31, 1988; or

Exhibit 14: Page 11 of 62
(b) you are age 55 or older and have five years of Past Service Vesting Credit at the 

time your “Employer”, as defined in the next sentence, becomes a contributing 

Employer on or after January 1, 2005. For purposes of this paragraph, the term 

“Employer” means an Employer with a stable and large work force that 

participates in the plan and whose demographics are determined to be 

actuarially acceptable at the time the Employer becomes a contributing 

Employer.3

Please Note: Vesting service credit is used only to determine vested status. Benefits 

Credits are determined in a different manner (see following section).

3

 The rule under this paragraph (b) is effective as of September 1, 2004.

Exhibit 14: Page 12 of 62
BENEFIT CREDITS AND 

DETERMINATION

OF BENEFITS

You earn Benefit Credits as soon as you become a participant in the Pension Plan. These 

Benefits Credits may be for Past Service or for Contributory Service. 

PAST SERVICE BENEFIT CREDIT

Past Service Benefit Credit is based on employment, prior to the time the first pension 

contribution is made on your behalf, in work classifications generally recognized as covered by the 

collective bargaining agreement with an Employer who becomes a contributing Employer in the 

Pension Plan. Past Service Benefit Credit is available only on your original entry into the Pension 

Plan. The Board of Trustees, in your Employer’s participation agreement and as a condition for 

your Employer’s participation in the Pension Plan, may limit the Past Service Benefit Credit for your 

Employer’s employees.

You receive one year of Past Service Benefit Credit for each calendar year in which you had 

at least 500 hours of work for the Employer in such work classifications since your last break in 

continuous service. You must have been employed on the first working day of the first calendar 

year for which Past Service Benefit Credit is earned. A break in continuous service for determining 

Past Service Benefit Credit occurs if you did not have an hour of work for a contributing Employer 

for two successive calendar years. If the first month for which Employer contributions are made on 

your behalf is other than January, you will receive a partial year of Past Service Benefit Credit for 

that year.

Please Note: 

IN NO EVENT WILL YOU BE GIVEN MORE THAN FIFTEEN 

YEARS OF PAST SERVICE BENEFIT CREDIT

Exhibit 14: Page 13 of 62
FOR RETIREMENTS ON AND AFTER JANUARY 1, 2002. 

Past Service Benefit

Your Past Service Benefit is computed by multiplying the number of years of Past Service 

Benefit Credit you earned by $8.20 (maximum of $123.00). 

Contributory Service Benefit

For Participants who were not retired on December 31, 2003, or since your last permanent 

break in service, your Contributory Service Benefit is computed by multiplying specific percentages 

(Benefit Percentage) times the dollar amount of Employer contributions, including contributions 

pursuant to the Uniformed Services Employment and Reemployment Rights Act, credited on your 

behalf (credited contributions) since your last Permanent Break in Service, if any, as follows:

Contribution Service Period Benefit Percentage on Annual Contributions

Up to and including $6,240 Above $6,240

(1) Prior to January 1, 1997 3.65% 0%

(2) January 1, 1997, through December 31, 2000 3.65% 1.80%

(3) January 1, 2001, through December 31, 2002 3.20% 1.80%

(4) January 1, 2003, through December 31, 2003 2.20% 1.80%

(5) January 1, 2004, through December 31, 2009 1.80% 1.80%

(6) January 1, 2010 and thereafter .75% .75%

Your contributory Service Benefit is the sum of (1), (2), (3), (4), (5) and (6). 

Total Service Benefit

Your Total Service Benefit is the sum of your Past Service Benefit and your Contributory 

Service Benefit. At the end of each Plan Year, the Plan Administration Office will calculate your 

Total Service Benefit and mail a report to you. Please immediately notify the Plan Administration 

Office if you have questions or think a correction should be made in any part of your report. 

Exhibit 14: Page 14 of 62
RETIREMENT BENEFITS

ELIGIBILITY

Once you earn five years of Total Service Vesting Credit, including at least two years of 

Contributory Service Vesting Credit, you are qualified for an Early Retirement Benefit at age 55 or a 

Normal Retirement at age 65. 

Special 

Eligibility 

Rule

If you reach age 65 without earning five years of Total Service Vesting 

Credit but have earned at least two years of Contributory Service Vesting 

Credit (one year of which must be earned during the Plan Year 

immediately prior to retirement) and have earned at least $10.00 of Total 

Service Benefit, you are qualified for a retirement benefit.

WHEN DO BENEFITS BEGIN?

Normal Retirement or Early Retirement Benefits will begin after you satisfy all eligibility 

requirements and you retire from any contributing Employer. In order to be retired you must have 

no hours of employment with any contributing Employer during the full calendar month in which 

retirement benefits are first received. A proper application must be filed and approved before any 

retirement benefits are paid. In no event will retirement benefits begin earlier than the first of the 

month following the month in which the application is received. See page 24 for instructions on 

how to apply for benefits. 

Normal Retirement Benefit: Normal Retirement Benefits may begin on the first day of the 

month following the month in which your 65th birthday occurs.4

Early Retirement Benefit: Early Retirement Benefits may begin on the first day of the 

month specified in your Pension Application but no earlier than the month following 

the month in which your 55th birthday occurs.5

Mandatory Retirement Benefit at Age 70 1⁄2: Retirement Benefits will begin on the April 

1st following the calendar year in which you attain age 70 1⁄2 if you are not still working

or if you are a 5% owner of your employer.

4

 Normal Retirement at age 65 is effective for retirement on or after January 1, 2010. Prior to that date the Normal 

Retirement age is 62. 5

 Early retirement was available under the “Rule of 80” prior to January 1, 2010.

Exhibit 14: Page 15 of 62
FORMS OF RETIREMENT BENEFITS

The law requires that following standard forms of retirement benefits:

Married Participants: Employee and 50% to Spouse Benefit 

Single Participants: Straight Life Annuity. 

All payment of retirement benefits must be consistent with the “required minimum 

distribution” requirements of IRC §401(a)(9). The regulations and provisions of IRC §401(a)(9) 

will prevail if there is an inconsistency between the Pension Plan and the regulations and provisions 

of IRC §401(a)(9). The Plan Administration office will inform you if your benefit distributions are 

subject to the required minimum distribution rules. 

FOR NORMAL RETIREMENT – AGE 65 

Please Note: In order to elect any optional form of benefit your spouse’s consent 

must be in writing and acknowledged before a notary public.

A. SPOUSE AS BENEFICIARY

1. STANDARD FORM – EMPLOYEE AND 50% TO SPOUSE BENEFIT

If you have a spouse at the time of your retirement, this is the form of benefit 

which must be paid unless you elect any of the optional forms of benefit and your 

spouse consents to your election. 

Under this Standard Form of benefits a monthly benefit will be paid to you 

during your lifetime. If your spouse is living at the time of your death, a benefit equal 

to 50% of your pension will be paid to your spouse for the remainder of your spouse’s 

lifetime. Your monthly benefit under this form is computed by reducing your Total 

Service Benefit to provide for payments during the expected lifetime of you and your 

spouse. The amount of the reduction will depend on the age of you and your spouse.

2. OPTIONAL ANNUITY FORMS

With your spouse’s consent, you may waive the 50% survivor’s annuity and 

choose instead an annuity with either: (a) a 100% spousal annuity; or (b) a 66-2/3% 

spousal annuity. If you select one of these alternative forms of benefits and if your 

spouse is living at the time of your death, a benefit equal to either 100% or 66-2/3% of 

your pension will be paid to your spouse for the remainder of your spouse’s lifetime. 

Your monthly benefit under either of these forms is computed by reducing your Total 

Service Benefit to provide for payments during the expected lifetime of you and your 

spouse. The amount of the reduction depends on the age of you and your spouse.

Exhibit 14: Page 16 of 62
3. SPOUSAL BENEFIT WITH A POP-UP

You may select a Pop-Up benefit for any of the three alternative spousal 

benefits. A monthly benefit will be paid to you during your lifetime. If your spouse is 

living at the time of your death, your spouse will receive, for the remainder of the 

spouse’s life, the percentage (100%, 66-2/3% or 50%) selected. However, if your 

spouse predeceases you, your benefit will “pop-up” to an amount to provide you with 

a monthly benefit as if you were not married and elected the Five Year Benefit 

Guaranty. The pop-up will occur as of the first day of the month after the death of 

your spouse. Your monthly benefit under this form is computed by reducing your Total 

Service Benefit to provide for payments during the expected lifetime of you and your 

spouse and to provide for the pop-up benefit. The amount of the reduction will depend 

on the ages of you and your spouse.

4. LUMP SUM DISTRIBUTIONS

With your spouse’s consent, you may elect a lump sum distribution if the

present value of your accrued benefit is $5,000.00 or less.6 The distribution shall be 

made immediately and as a lump-sum payment. A distribution after the annuity 

starting date will not be permitted pursuant to this paragraph unless you and your 

spouse consent to the distribution.

B. BENEFICIARY OTHER THAN SPOUSE

You may choose one of the alternatives listed below if you are single or if you are 

married and your spouse consents. 

1. Straight Life Annuity 

A straight life annuity is an annuity payable over your life with no death 

benefit.

2. Joint Benefit with a contingent annuitant other than your Spouse. 

You may select a 100%, 66-2/3% or 50% joint benefit with someone 

other than your spouse as the contingent annuitant. Your contingent annuitant

may be any person such as a child, mother, brother, sister or friend. The value 

of your projected benefits at the date of your retirement must satisfy the 

minimum incidental benefit requirement.7

6

 This provision is effective for plan years beginning after December 31, 2004. 7

 See Treas. Reg. §1.401(a)(9)-6 Q&A-2.

Exhibit 14: Page 17 of 62
C. PENSION ENHANCEMENT

A “Pension Enhancement” option is available to you at retirement if you are entitled to 

a lump sum distribution of at least $10,000 from another tax qualified retirement plan (for 

example, a 401(k) plan). In that case, you may elect to rollover the distribution to this Plan to 

“enhance” you monthly pension benefit. Estimates of how much additional benefit will be 

generated by a rollover may be obtained from the Plan Administration Office. The best 

procedure is to request a formal estimate in writing. However, the Plan Administration Office 

can provide an estimate by phone. Pension Enhancements are determined using actuarial 

factors adopted by the Board.

Please Note: 

A unique feature of this Option guarantees that if the enhanced 

benefit you receive does not use all of the money you rolled over, your 

heirs will receive the remaining balance in the event of your death. 

D. CHANGE OF FORM OF BENEFIT OR JOINT ANNUITANT BY A RETIRED 

PARTICIPANT

Retired participants may not change the form of benefits being paid, except that one 

change may be made if either of the following situations applies:8

Upon written application, a retired participant who originally selected a Straight Life 

Annuity may change to a joint marital form (50%, 66-2/3% or 100% survivor option), 

designating the participant’s spouse as joint annuitant. The application for the change must 

be made within the first year of marriage. The amount payable under the new joint annuity 

will be reduced so that it is actuarially equivalent in value to the original benefit. In addition,

the benefit will be actuarially reduced by 1⁄2% for each full year that elapsed since the retiree 

originally retired.

The reduction in the amount of monthly benefit payment as a result of the above shall 

become effective on the first day of the second month following receipt of the retired 

participant’s complete, written application. However, if the retired participant thereafter dies 

within two years of the effective date, the change shall be retroactively cancelled and no 

change in the form of benefits being paid shall occur. The participant’s beneficiary shall then 

receive payment for all reductions in monthly benefits which occurred, including the 1⁄2% per 

year reductions. 

ADJUSTMENT FOR EARLY RETIREMENT

If you apply for an Early Retirement Benefit, the above forms of benefits also apply. 

However, your monthly benefit is reduced for early retirement as follows: 

8

 The section is effective for applications received after June 20, 2013. 

Exhibit 14: Page 18 of 62
(a) Benefits you earned when the Normal Retirement Age was 62 (for service before 

January 1, 2010) are not reduced if you retire after reaching age 62. If you retire 

before you reach age 62 the benefits you earned prior to January 1, 2010, are subject 

to reduction pursuant to Column (1) below. 

(b) Benefits you earned when the Normal Retirement Age is 65 (for service after 

December 31, 2009) are not reduced if you retire after reaching age 65. If you retire 

before you reach age 65 the benefits you earned after December 31, 2009, are subject 

to reduction pursuant to Column (2) below. 

Early Retirement Factors

Early Retirement Factor for Participants taking early retirement after January 1, 2010 

Your total early retirement benefit is the total of (a) and (b).

Age at 

Retirement

Column (1) Column (2)

Early Retirement Factor: 

Actuarial reduction from age 62

Early Retirement Factor: 

Actuarial reduction from age 65

65 100% 100%

64 100% 90.56%

63 100% 82.16%

62 100% 74.67%

61 91.04% 67.98%

60 83.01% 61.99%

59 75.80% 56.60%

58 69.32% 51.76%

57 63.47% 47.39%

56 58.18% 43.45%

55 53.40% 39.87%

FOR POSTPONED RETIREMENT – AFTER NORMAL RETIREMENT AGE

The above forms of benefits also apply if you are eligible for a Normal Retirement Benefit 

and you postpone your retirement. In addition, if you postpone your retirement past the Normal 

Retirement Age your monthly benefit will be increased to reflect your late retirement. If you do not 

continue working for a contributing employer your Normal Retirement Benefit will be increased 

under (a) below. If you continue working for a contributing employer your benefit at retirement will 

the greater of (a) or (b) below.9

(a) your Normal Retirement Benefit increased at the rate of 1⁄2 of 1% for each full month 

you postpone retirement.10 

(b) your accrued benefit as of your postponed retirement date (your Normal Retirement 

Benefit increased by benefits you earn after your Normal Retirement Age).

9

 This provision is effective for retirement applications received after September 1, 2015. 10 This equals an increase of 6.0% per year.

Exhibit 14: Page 19 of 62
Please Note: 

The Plan Administration Office tracks your benefit accruals, but you 

should always review your benefit calculation at retirement to make sure 

all your benefit service is included. You can provide proof of your benefit 

service, whether before and after Normal Retirement Age, to the Plan 

Administration Office. The Plan Administration Office will increase 

postponed retirements using (a) above when there is no record of 

additional benefit accruals after Normal Retirement Age. The adjustment 

under (a) generally provides for a larger postponed retirement benefit. 

MANDATORY RETIREMENT BENEFIT AT AGE 70 1⁄2 

If you are a vested Participant, you are required to begin receiving benefits no later than 

April 1 of the calendar year following the year you attain age 70 1⁄2 if you are not still employed or 

if you are a 5% owner of your employer. You will have a significant income tax penalty if you do 

not commence to receive payments by that date.

Your benefit will be calculated according to the section entitled, “FOR POSTPONED 

RETIREMENT AFTER NORMAL RETIREMENT AGE.” If you continue to work and have 

contributions made on your behalf your benefit will be increased periodically and automatically to 

give you credit for additional Employer contributions. These increased benefits will be added to, 

and paid in the same form as, the benefits you are receiving. 

EXAMPLES OF HOW THE EARLY RETIREMENT REDUCTIONS AND THE 

POSTPONED RETIREMENT INCREASES OPERATE:

The following examples assume that you are a vested Participant and that you qualify for 

retirement on the applicable retirement dates. The amount of the early retirement reduction and the 

postponed retirement increases depends upon when you earned the benefits (before or after 

December 31, 2009) and when you retire. If you earn benefits both before and after December 31, 

2009, your benefit is the combination of both benefits. 

A. Benefits Accrued Before January 1, 2010

Early Retirement. Assume that before January 1, 2010, you earned a benefit of $2000 per 

month payable as a Straight Life Annuity at age 62. The Normal Retirement Age for this 

benefit is age 62 so there is a reduction for early retirement if you retire before that age. For 

example, the early retirement factor (see Column A on the following chart) at age 59, is 

75.80% so your benefit is $1,516 per month ($2000 x 75.80%) at age 59. There is no early 

retirement reduction for benefits earned before January 1, 2010, if you are age 62 or older 

when you retire. 

Exhibit 14: Page 20 of 62
Postponed Retirement. Under this same example, assume you postpone retirement until age 

66. The Actuarial Increase Factor (see Column H on the following chart) is 24%, which 

increases your benefit to $2,480 per month 

B. Benefits Accrued After December 31, 2009 

Early Retirement. Assume that after December 31, 2009, you earned a benefit of $250 per 

month payable as a Straight Life Annuity at age 65. The Normal Retirement Age for this 

benefit is age 65 so there is a reduction for early retirement if you retire before that age. For 

example, the early retirement factor (see Column F on the following chart) at age 64, is 

90.56% so your benefit is reduced to $226.00 per month ($250 x 90.56%) at age 64. There is 

no early retirement reduction for benefits earned on or after January 1, 2010, if you are age 

65 or older when you retire. 

Postponed Retirement. Under this same example, assume you postpone retirement until age 

67. The Actuarial Increase Factor (see Column I on the following chart) is 12%, which 

increases your $250 per month benefit to $280 per month ($250 + ($250 x 12%)).

Exhibit 14: Page 21 of 62
Examples of Early Retirement Reductions and Postponed Retirement Increases

Line Column A B C D E F G H I 

Retirement Date 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 1/1/2016 1/1/2017 1/1/2018

Age 59 60 61 62 63 64 65 66 67

a Accrued Benefit thru 

12/31/09 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000

b Age 62 Early 

Retirement Factor 75.80% 83.01% 91.04% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00%

c Age 62 Actuarial 

Increase Factor 0.00% 0.00% 0.00% 0.00% 6.00% 12.00% 18.00% 24.00% 30.00%

d Adjusted Benefit 

(a x b x (1+c)) $1,516 $1,660 $1,821 $2,000 $2,120 $2,240 $2,360 $2,480 $2,600

e Accrued Benefit 

after 12/31/09 $0 $50 $100 $150 $200 $250 $300 $350 $400

f Age 65 Early 

Retirement Factor 56.60% 61.99% 67.98% 74.67% 82.16% 90.56% 100.00% 100.00% 100.00%

g Age 65 Actuarial 

Increase Factor 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 6.00% 12.00%

h Adjusted Benefit 

(e x f x (1+g)) $0 $31 $68 $112 $164 $226 $300 $371 $448

i Straight Life Only if 

Benefits Earned 

Before and After 

12/31/2009 (d + h) $1,516 $1,691 $1,889 $2,112 $2,284 $2,466 $2,660 $2,851 $3,048

NOTICE AND ELECTION OF FORM OF BENEFIT

 

If you are married on your Normal Retirement Date, or on the date that you first become 

eligible for early retirement, the following will apply:

(a) You will receive a written explanation of the Standard Form of Benefit within a 

reasonable period of time before you are first eligible for either benefit. The 

explanation will include: (i) the terms and conditions of the Standard Form of benefit; 

(ii) your right to make, and the effect of, an election to waive the Standard Form of 

benefit; (iii) your spouse’s rights; and (iv) your right to make, and the effect of, a 

revocation of an election to waive the Standard Form of Benefit. 

(b) You are entitled to a specific written explanation of the Standard Form of benefit and 

the specific financial effect on you and your spouse of receiving, or failing to receive, 

the Standard Form of benefit. This information may be furnished at any time and will 

be furnished within 30 days of your request which must be made within 60 days of 

the receipt by mail or personal delivery of the original information.

(c) Your election to receive the Standard or Optional Form of benefit or a revocation of a 

prior election must be made at a time and in a form as the Board of Trustees may 

Exhibit 14: Page 22 of 62
direct; however, the election period will not end earlier than 60 days after the 

additional information described above is provided. The form and type of benefit 

cannot be changed once payments commence.

(d) You may elect to waive the Standard Form of benefit. Your spouse must consent in 

writing to a waiver of the Standard Form of benefit. Your spouse’s consent will 

not be required if it can be established that your spouse’s consent cannot be obtained 

because your spouse cannot be located. You may revoke a prior waiver at any time 

without your spouse’s consent; the number of revocations is unlimited. The time to 

waive the Standard Form of benefit is within the period of time commencing 180 

days before the annuity starting date and ending on the annuity starting date.11 The 

annuity starting date means: (i) the first day of the period for which an amount is 

payable as an annuity; or (ii) the first day on which all events have occurred which 

entitle you to a benefit not in the form of an annuity. 

11 The 180 day requirement is effective for distributions on or after January 1, 2007.

Exhibit 14: Page 23 of 62
ACTUARIAL EQUIVALENCE

The term “actuarial equivalence” is used to determine i two benefits have equal value. You 

can estimate your benefit under the Plan’s distributions options by using the tables set forth below. 

Ages are rounded to the nearest age. Other percentages apply for age differences of 11 years or 

greater. You should contact the Plan Administration Office if you want a formal estimate of your 

benefits. The Plan Administration Office also has more complete tables.

Table 1 Table 2

JOINT ANNUITY FACTORS

1. The annuity can be with your spouse or 

another beneficiary (with spouse’s consent, 

if married) 

2. No “Pop’Up” benefit

MARRIED JOINT ANNUITY FACTORS

1. Must be with your spouse

2. “Pop’Up” benefit provided

Beneficiary's Age 

Life Annuity 

with 50% 

survivor annuity

Life Annuity 

with 66 2/3% 

survivor annuity

Life Annuity 

with 100% 

survivor annuity

Life Annuity 

with 50% 

survivor annuity

Life Annuity 

with 66 2/3% 

survivor annuity

Life Annuity 

with 100% 

survivor annuity

55 0.8871 0.8549 0.7970 0.8785 0.8443 0.7833

56 0.8904 0.8590 0.8025 0.8813 0.8477 0.7878

57 0.8938 0.8633 0.8080 0.8841 0.8513 0.7923

58 0.8973 0.8676 0.8137 0.8870 0.8548 0.7970

59 0.9008 0.8719 0.8195 0.8900 0.8585 0.8017

60 0.9043 0.8763 0.8253 0.8929 0.8621 0.8065

61 0.9079 0.8808 0.8313 0.8959 0.8658 0.8114

62 0.9114 0.8853 0.8373 0.8989 0.8696 0.8163

63 0.9150 0.8898 0.8434 0.9019 0.8733 0.8213

64 0.9186 0.8944 0.8495 0.9049 0.8771 0.8263

Both Age 65 0.9222 0.8989 0.8557 0.9079 0.8808 0.8313

66 0.9258 0.9034 0.8618 0.9109 0.8846 0.8364

67 0.9293 0.9080 0.8680 0.9139 0.8884 0.8414

68 0.9329 0.9124 0.8742 0.9169 0.8921 0.8465

69 0.9363 0.9169 0.8803 0.9198 0.8959 0.8515

70 0.9397 0.9212 0.8863 0.9227 0.8996 0.8566

71 0.9431 0.9255 0.8923 0.9256 0.9032 0.8616

72 0.9463 0.9297 0.8981 0.9285 0.9069 0.8665

73 0.9495 0.9338 0.9039 0.9313 0.9105 0.8714

74 0.9526 0.9378 0.9095 0.9341 0.9140 0.8763

75 0.9556 0.9417 0.9150 0.9368 0.9175 0.8812

Exhibit 14: Page 24 of 62
EXAMPLES: 

The following examples assume the Participant is entitled to retire at age 65 and the Participant’s 

Total Service Benefit is $2000 per month. 

Table 1. Table 1 tells you the percentage of your Total Service Benefit payable to you for 

your life, and to your contingent annuitant at your death for his/her lifetime, under different 

age combinations. For example, assume you are age 65 and your contingent annuitant is age 

55. Your benefit options are: 

Benefit Total 

Service 

Benefit

Annuity 

Factor

Your lifetime 

benefit 

Contingent 

annuitant’s benefit 

Life Annuity with 

50% survivor 

annuity 

$2000 

per 

month 

.8871 $1,774.20 $887.10 (50%)

Life Annuity with 

66 2/3% survivor 

annuity 

$2000 

per 

month 

.8549 $1,709.80 $1139.87 (66 2/3%)

Life Annuity with 

100% survivor 

annuity 

$2000 

per 

month 

.7970 $1,594.00 $1,594.00 (100%)

Table 2. Table 2 tells you’re the percentages if you elect a benefit form with a “Pop-Up” 

feature (see page 8 above for an explanation). The “Pop-Up” benefit is only available if your 

contingent annuitant is your spouse. As you can see by comparing the tables, the amounts 

paid during your lifetime and the lifetime of your contingent annuitant, if you elect an 

annuity with a “pop-up” feature. 

Benefit Total 

Service 

Benefit

Annuity 

Factor

Your lifetime 

benefit 

Contingent 

annuitant’s benefit 

Life Annuity with 

50% survivor 

annuity 

$2000 

per 

month 

.8785 $1,757.00 $878.50 (50%)

Life Annuity with 

66 2/3% survivor 

annuity 

$2000 

per 

month 

.8443 $1,688.60 $1125.73 (66 2/3%)

Life Annuity with 

100% survivor 

annuity 

$2000 

per 

month 

.7833 $1,566.60 $1,566.60 (100%)

Please Note: 

The Plan’s current actuarial factors include the 1984 Unisex Pension 

Mortality Table set back six years with 7% interest.

Exhibit 14: Page 25 of 62
SURVIVOR BENEFITS

IN EVENT OF YOUR DEATH

PRE-RETIREMENT DEATH BENEFIT – SINGLE PARTICIPANTS

 Your beneficiary will receive a lump sum Death Benefit equal to $500 per year of service (up 

to a maximum of $5,000) if:12

(a) your death occurs on or after January 1, 2010, 

(b) contributions were made to the Plan on your behalf in the month preceding the month 

of your death; and 

(c) you are not married at the time of your death. 

PRE-RETIREMENT DEATH BENEFIT – MARRIED PARTICIPANTS

Your surviving spouse will receive a “qualified preretirement annuity” or “QPSA” if you die 

before your annuity starting date, unless you waived the qualified preretirement annuity and elected 

an option form of benefit with the consent of your spouse.13 

The amount of the QPSA depends upon whether you die before or after your earliest 

retirement age under the Plan. Payments under a QPSA that begin earlier or later that the earliest 

retirement age under the Plan shall be actuarially adjusted, using reasonable actuarial factors, to 

reflect the early or delayed payments.

(a) If you die after your earliest retirement age under the Plan your spouse (if 

any) will receive the same benefit that would be payable to the spouse 

assuming you actually retired on the day before your death and elected the 

Standard Form of retirement benefit (50% survivor’s annuity). 

(b) If you die on or before your earliest retirement age your spouse (if any) will 

receive will receive the same benefit that would be payable to the spouse 

assuming you had: 

(1) terminated employment on the date of death (except for an individual 

who terminated service prior to the date of death);

(2) survived the earliest retirement age;

(3) retired with the Standard Form of retirement benefit (50% survivor’s 

annuity) at the earliest retirement age; and

(4) died on the date after the earliest retirement age.

12 This Pre-Retirement Death Benefit-Single Participants is effective January 1, 2010. 13 This Pre-Retirement Death Benefit-Married Participants is effective January 1, 2010.

Exhibit 14: Page 26 of 62
POST-RETIREMENT DEATH BENEFIT

If your death occurs after your retirement, your spouse or other beneficiary will receive the 

survivor benefits described on pages 7-8 under the Standard or Option Annuity Forms of retirement 

benefits depending upon the form of benefit you were receiving.

TO WHOM ARE BENEFITS PAID?

Your Death Benefit is payable is paid to the beneficiary of record in the Plan Administration 

Office. If you are married your spouse is automatically your beneficiary. Your Death Benefit will 

be paid according to the Default Beneficiary Priority set forth below if there is no designated 

beneficiary of record on the date when a Death Benefit becomes payable.

A. Default Beneficiary Priority.

Your Death Benefit will be paid in the following default order of priority if you have no 

beneficiary designation of record with the Plan Administration Office or if your named beneficiary 

predeceases you: 

(1) to your spouse unless your spouse consents to the designation of another 

beneficiary; or 

(2) to a person designated by you as your beneficiary if you do not have a spouse 

or if your spouse consents in writing to another beneficiary; or 

(3) to your children and children of deceased children per stirpes (“children” 

includes natural children, step-children and adopted children); or 

(4) to your parents; or 

(5) to your brothers and sisters and nieces and nephews, who are children of 

deceased sisters and brothers, per stirpes; or

(6) to your estate.

B. Special Beneficiary Designation Rules.

All beneficiary designations are subject to the following rules: 

(1) Spousal Consent Requirements. Your spouse’s consent to an alternate 

beneficiary must be in writing, on a form provided by the Plan Administration 

Office, and your spouse’s signature must be notarized (acknowledged before a 

notary public). 

(2) Divorce Voids Spouse as Beneficiary. If you designated your spouse as your 

beneficiary at the time you were married and you subsequently divorce that

spouse, the designation of your former spouse as your beneficiary is void as of 

the date of your divorce. In that case, your death benefits are payable under 

Exhibit 14: Page 27 of 62
the Default Beneficiary Priority provided under paragraph A. above, unless 

you have named an alternate beneficiary.

Please Note: 

You should contact the Plan Administration Office for a new beneficiary 

designation form if you are divorced. The form can also be downloaded 

from the Plan’s website: http://www.wsp.aibpa.com.

(3) Beneficiary Designations Not Effective Until Recorded. Your beneficiaries 

must be recorded on your initial enrollment form or on a change of 

beneficiary form available from the Plan Administration Office or 

downloadable from the Plan’s website at: http://www.wsp.aibpa.com. 

Designation, revocations, or changes of named beneficiaries must be recorded 

in the Plan Administration Office in order to be effective. 

SURVIVOR BENEFIT ADMINISTRATION

A. Disclaimers. 

If a beneficiary disclaims any interest in a Participant’s death benefit, in a form and manner 

satisfactory to the Administrator, the beneficiary shall be treated as having predeceased the Participant

with respect to the disclaimed interest. The Administrator may adopt the requirements of Section 2518 

of the Code or other applicable state or federal laws to establish the form and manner of the disclaimer.

B. Minors.

The Administrator may distribute a minor beneficiary’s share of any death benefits as provided 

below for Incompetent Participants (page 25). 

Exhibit 14: Page 28 of 62
DISABILITY BENEFITS

A. ELIGIBILITY

If you incur a total and long-term disability before reaching age 55, you will be eligible for a 

disability benefit if you:14

(1) earned five (5) years of Total Service Vesting Credit, including two years of 

Contributory Service Vesting Credit; and

(2) had contributions made on your behalf for at least 200 hours of work during the 

twelve-month period immediately preceding the onset of your disability; and 

(3) submitted evidence of disability satisfactory to the Board of Trustees. A Social 

Security Disability Award may be evidence of your disability but it will not be the 

sole criteria for determining if you will receive a disability pension.

B. WHAT IS A DISABILITY?

Disability, as defined for purpose of this Plan, is complete and continuous inability, resulting 

from sickness or injury, to engage in any and every gainful occupation for which you are reasonably 

qualified if such condition is expected to continue for a long and indefinite period. 

C. WHEN DO BENEFITS BEGIN?

Your Disability Benefit will begin on the first day of the month following the earlier of the 

date of your Social Security Disability Award Date, or the later of: (1) six months after 

commencement of the disability, or (2) the date on which your application is received by the Plan 

Administration Office. You will receive a disability benefit retroactive to the date of your Social 

Security Disability Award Date if you submit an application with the Social Security Award to the 

Plan Office within 90 days of receipt of the award. A proper application must be filed before any 

disability benefit will be paid. See page 20 for instructions on how to apply for benefits. 

D. HOW ARE BENEFITS COMPUTED?

Your monthly Disability Benefit will be an amount equal to 50% of your Total Service 

Benefit (see page 5). This amount will not be reduced if you are less than age 55. 

E. HOW LONG DO BENEFITS CONTINUE?

Your monthly Disability Benefit will continue until the earlier of: (1) you recover from your 

disability, or (2) your death, or (3) your 55th birthday (you may apply for Early Retirement Benefits 

at that time if you are eligible). The Board of Trustees may from time to time require proof of 

continued disability. 

14 These Disability Benefit provisions are effective January 1, 2010.

Exhibit 14: Page 29 of 62
CIRCUMSTANCES UNDER WHICH 

BENEFITS WILL NOT BE 

RECEIVED AND PENSION CREDIT 

WILL BE LOST

BREAK IN SERVICE

 You will lose all accumulated Vesting and Benefit Credits if you incur a Permanent Break in 

Service and you are not a Vested Participant. 

You incur a One-Year Break in Service in any calendar year in which you are not employed 

by a Contributing Employer, in any capacity, for at least 200 hours. However, your qualified 

military service will be credited as hours of work pursuant to the Uniformed Services Employment 

and Reemployment Act which may prevent a Break in Service. See page 2.

You incur a Permanent Break in Service when you have five consecutive One-Year Breaks 

in Service. If you have at least a One-Year Break in Service, which is not a Permanent Break in 

Service, and you are re-employed, depending on your collective bargaining agreement, you will 

either participate immediately upon re-employment or after satisfying the requirements set forth in 

your collective bargaining agreement.

EXAMPLE

Assume you have three years of Vesting Credit. You could leave employment with a 

Contributing Employer for four years and return the fifth year without incurring a permanent Break 

in Service, if you had at least 200 hours of work during the fifth year. Each of the four years would 

be a One-Year-Break in Service year. If, during the fifth year, you did not have 200 hours of work, 

you would then have another year One-Year Break in Service or a total of five consecutive OneYear Breaks in Service. Therefore, you would then incur a Permanent Break in Service which 

results in your losing all prior accumulated Vested Credits and Benefits Credits.

EXCEPTIONS TO BREAK IN SERVICE RULES

The Break in Service Rules do not apply for any year in which you fail to have 200 hours of 

work due to sickness or injury, military service or you are covered by a reciprocal plan. You will be 

required to provide satisfactory proof to the Trustees in order to be granted an exception to the Break 

in Service Rule. You will receive credit of not more than 200 hours of work to prevent a One-Year 

Break in service if you are absent from work because of the adoption of a child, pregnancy, birth of a 

child, or caring for a child immediately after birth or adoption. During the absence you will receive 

credit for hours of work which normally would have been credited to you. The hours of work 

credited under this paragraph will be granted in the Plan Year in which your absence commenced if 

the credited hours of work are necessary to prevent a One-Year Break in Service; otherwise, the 

hours of work will be credited in the immediate following Plan Year. You must notify the Plan 

Administration Office if you wish the hours credited to you. 

Exhibit 14: Page 30 of 62
You will not have a Break in Service during your first year of employment with a 

contributing Employer if you have less than 200 hours of work. 

RETURNING TO WORK AFTER RETIREMENT

A. SUSPENSION RULE

After you have retired and are receiving benefits, your monthly benefits will be suspended if 

you return to work for a participating Employer and have 40 or more hours of work per month for 3 

consecutive months.15 The suspension rule does not apply to you if you are receiving benefits under 

the rule for “Mandatory Retirement Benefit at Age 70-1/2” as described on page 6. 

B. REINSTATEMENT RULES AND SUSPENSION

If your benefits are suspended, you may apply for reinstatement of your pension benefits if 

you have less than 40 hours of work in a month. The following additional rules apply to Participants 

who take early retirement on or after August 1, 2009: 

1. If you take early retirement you may have your benefits reinstated once after a 

suspension. Your pension benefits will not be payable until Normal Retirement Age 

if you take early retirement and:

• your benefits are suspended under the Suspension Rule described above, and

• your benefits are subsequently reinstated, and 

• your benefits are again suspended under the Suspension Rule. 

2. Suspended pension benefit payments are forfeited and not paid. The forfeiture does 

not affect your normal retirement benefit (or the actuarial equivalent thereof) payable 

at Normal Retirement Age.

3. There is an exception to the rule that your pension benefits are not payable until 

Normal Retirement Age if your benefits are suspended more than once after early 

retirement. The exception is that your benefits are payable before Normal Retirement 

Age pursuant to a distribution option or provision other than early retirement. An 

example is the payment of death benefits.

C. ACCRUAL OF BENEFITS AFTER RETIREMENT

If you continue to work for a participating employer after early retirement and your benefits 

are not suspended, you will continue to earn additional benefits. Your benefits will be recalculated 

yearly.

15 These Returning To Work After Retirement rules are effective as of June 5, 2009.

Exhibit 14: Page 31 of 62
If you continue to work for a participating employer after Normal Retirement Age and your 

benefits are not suspended, you will not earn additional benefits in a year in which you work if the 

actuarial value of the benefits that you receive in the year exceed the benefits that you would earn 

from working in that year. 

If, during your period of re-employment after your benefits were suspended, contributions 

were made on your behalf for at least 500 hours of work prior to reinstatement of benefits, your 

Total Service Benefit will be recomputed and increased as if your employment had been continuous 

with an actuarial adjustment made for retirement benefits previously received.

UNCLAIMED BENEFITS16

A. MISSING PARTICIPANTS 

The Administrator, by certified or registered mail addressed to the Participant’s or 

Beneficiary’s last known address of record with the Administrator, union or employer, shall notify 

any Participant or Beneficiary that he or she is entitled to a distribution under the Plan, and the 

notice shall state the provisions of this section. 

1. Location Steps. If the Administrator is unable to locate and notify a Participant or 

beneficiary at his or her last known address, then the Administrator shall attempt to 

notify the Participant according to the Plan’s missing participant policy, and

applicable rules prescribed by the Internal Revenue Service and/or the U.S. 

Department of Labor. Reasonable costs of trying to locate the Participant may be 

charged to the Participant’s benefit. 

2. Distribution. If (i) the present value of the Participant’s vested benefit is greater than

the Plan limit for lump sum distributions and the Participant has passed the 

Retirement Date, and (ii) the Participant or Beneficiary fails to claim the Participant’s 

benefits or make his or her whereabouts known in writing to the Administrator by the 

earlier of (x) the date that is immediately prior to three years (adjusted according to 

the abandonment period of the escheat laws of the applicable state) after the date of 

notification, or (y) the Participant’s required beginning date for distributions under 

IRC §401(a)(9), then the Administrator and Trustee shall hold, administer and 

distribute the Participant’s account balance as follows:

(a) If the whereabouts of the Participant are unknown, but the whereabouts of the 

Participant’s Beneficiary are then known to the Board may direct the 

Administrator to make distributions to the Beneficiary.

(b) If the Participant and the Participant’s Beneficiary are unknown to the 

Administrator, but the whereabouts of one or more of the Participant’s 

relatives by blood, adoption or marriage are known to the Administrator, the 

Board may direct the Administrator to make distributions of the Participant’s 

16 This provision added effective May 31, 2016.

Exhibit 14: Page 32 of 62
account to any one or more of such relatives and in such proportions as the 

Board may determine.

(c) If the Administrator does not know or learn the whereabouts of any of the 

above persons within the time limits prescribed above, then the Board may 

declare the Participant’s benefit to be treated as a forfeiture; provided, 

however, the benefit shall be reinstated in the event that the Participant or 

Beneficiary shall subsequently make a valid claim. 

(d) If a Participant or Beneficiary makes a valid claim after a benefit shall be 

declared forfeited above, (i) the benefit shall be adjusted for late retirement as 

provided in the Plan; (ii) interest and/or earnings on unpaid benefits shall be 

based on the Plan’s investment returns, losses and expenses for the Plan’s 

least risky investment, as determined by the Board; and (iii) any payment 

made pursuant to this provision shall operate as a complete discharge of all 

obligations of the Board and Administrator to the extent of the distributions so 

made.

B. INCOMPETENT PARTICIPANTS 

 If, in the opinion of the Administrator, a Participant, alternate payee or beneficiary shall be or 

become legally incompetent to manage his or her affairs by reason of minority, illness, or injury or 

other defect, then any distribution from the Participant, alternate payee or beneficiary’s account will 

be paid for his or her benefit in such of the following ways as the Employer or Administrator shall 

direct:

1. to the attorney in fact of the Participant, alternate payee or beneficiary holding a 

current, valid power of attorney, or 

2. if to any minor beneficiary, to the minor beneficiary’s parent or legal guardian as 

custodian under the Uniform Transfers to Minors Act in effect under the laws of the 

state in which the minor beneficiary is domiciled at the time of distribution, or 

3. to the court-appointed conservator, guardian, or other fiduciary having authority over 

the estate of the Participant, alternate payee or beneficiary.

Exhibit 14: Page 33 of 62
HOW YOU APPLY

FOR BENEFITS

Please Note: 

Please review your Claim for Benefits carefully and attach all required 

documents requested on the application form. An incomplete application 

will mean a delay in the processing of your benefits.

You must file a Claim for Benefits with the Plan Administration Office before you can 

receive any of the benefits provided by this Plan. The form is available at the Plan’s Administration 

Office, from your local union or can be downloaded at the Plan’s website: 

http://www.wsp.aibpa.com. This application form is to be used for all claims for benefits. 

RETIREMENT BENEFIT – NORMAL AND EARLY

In order not to delay the arrival of your first benefit check, you should file a Claim for 

Benefits in advance of your actual retirement date. All claims must include a proof of age. See the 

back of the application form for instruction and types of acceptable proof. If you are married, you 

should also include proof of marriage and a proof of the date of birth of your spouse. 

You should also review the Standard and Optional Forms of retirement benefits to determine 

which form you wish to select. If a person other than your spouse is named as a contingent 

annuitant under Option B (Employee and 50% to Beneficiary other than Spouse), you must furnish 

proof of age for such person. 

Prior to receiving your first benefit check, you will be required to elect the form of benefit 

you wish to receive. This election must be signed by both you and your spouse, if any, and returned 

to the Plan Administration Office before the final processing of your application can take place. 

DISABILITY BENEFITS

If you become disabled and you believe your disability is likely to last more than six months, 

you should file a claim as soon as possible. It is desirable to file your claim at the same time you file 

for your Social Security Benefits. The Plan Administration Office will send you a medical report 

form for your doctor to complete and may request a copy of your Social Security Disability 

determination.

Exhibit 14: Page 34 of 62
DEATH BENEFITS

Your beneficiary must file a claim with the Plan Administration Office before any death 

benefit may be paid. A certified copy of the death certificate must be included with the claim. You 

should advise your beneficiary of this benefit and this booklet should be kept with your important 

papers so that your beneficiary may file a proper application. 

WHAT HAPPENS AFTER YOUR CLAIM IS FILED

Upon receipt of your benefit application, the Plan Administration Office reviews the claim 

for completeness and either requests additional information or acknowledges receipt of your claim. 

You will also be sent a benefit election form if your type of claim requires it.

Benefits in this Plan are based upon contributions credited on your behalf. Therefore, final 

processing of your claim cannot be completed until receipt of your Employer’s last remittance on 

your behalf. Employer reports are due by the 20th of the month following the month in which the 

hours were worked. 

Example: Contributions for hours worked in January are due by February 20th. After 

receiving the final contribution, the Plan Administration Office determines your eligibility and 

computes your benefit. You will then be notified of the amount of your benefit, the effective date, 

and the date when you can expect to receive your first payment. 

WHEN DO THE MONTHLY CHECKS GET MAILED?

The Plan Administration Office mails the monthly benefit checks on the last working day of 

the month. You should receive your check by the third day of the following month. Please contact 

the Plan Administration Office if your check does not arrive by the 7th of the month. 

Exhibit 14: Page 35 of 62
CLAIMS APPEAL

PROCEDURES 

WHAT HAPPENS IF YOUR CLAIM IS DENIED?

The Plan Administration Office will notify you in writing if your claim is denied in 

whole or in part.17 The notice will state the following:

1. The specific reason or reasons the claim was denied; 

2. The specific reference to the Plan provisions on which the denial is based; 

3. A description of any additional material or information necessary for you to 

perfect the claim and an explanation of why the material or information is 

necessary;

4. The steps you should take if you wish to submit the claim denial for review. 

The notice of denial will be given within 30 days after the claim is filed. However, 

the Administrator may obtain a 15 day extension of time to make a decision if the 

Administrator is not able to make a decision for reasons beyond its control. To obtain the 

extension, the Administrator will:

a. give you written notice of the extension prior to the expiration of the 30 days; 

b. advise you of the circumstances requiring the extension of time;

c. advise you of the expected date of the decision; and 

d. state the additional information, if any, that you failed to submit and permit 

you at least 45 days to provide the information. 

17 These Claims Appeal Procedures are effective for appeals after December 31, 2002.

Exhibit 14: Page 36 of 62
REVIEW PROCEDURES 

APPLICATION FOR REVIEW

You or your duly authorized representative may request a review of the denied claim by 

filing a written application for a review within 180 days after receipt of the written notification of the 

denial. The Board of Trustees may consider a late application if it concludes that the delay in filing 

was for a reasonable cause.

REVIEW PROCEDURES

When an application is received, the claim and its denial will receive a full and fair review by 

the Board of Trustees. As part of the review procedure you, or your duly authorized representative, 

may review and copy pertinent documents and submit issues and comments in writing. You or your 

duly authorized representative may appear before the Board of Trustees. 

NOTICE OF DECISION ON REVIEW

The Board of Trustees will decide the appeal at its next quarterly meeting unless the appeal 

was received within 30 days of the Board of Trustees meeting in which case the decision shall be 

made at the second meeting following the receipt of the appeal. If special circumstances require, the 

Board of Trustees may delay a decision until its third meeting following receipt of the appeal 

provided that you are given notice. The notice will be given prior to commencement of the 

extension; will state the special circumstances which require the extension; and will state the 

expected date of the decision. The Board of Trustees will notify you, in writing, as soon as possible 

of its decision but not later than 5 days after the decision. 

You can not undertake any legal action for a claim until all rights under the claims appeal procedures 

have been exhausted. 

Exhibit 14: Page 37 of 62
ROLLOVERS 

A. ROLLVERS FROM THE PLAN: PARTICIPANTS

You may elect have any portion of an “eligible rollover distribution” paid in a “direct 

rollover” to an “eligible retirement plan” that you specify, at the time and in the manner prescribed 

by the Board of Trustees. The terms used in the preceding sentence are defined below.

1. Eligible Rollover Distribution. An “eligible rollover distribution” is any 

distribution of all, or any portion of, the balance to the credit of the distributee, as 

provided in this paragraph. 

(a) Excluded Distributions. An eligible rollover distribution does not include any 

distribution that is one of a series of substantially equal periodic payments (not 

less frequently than annually) made for the life (or life expectancy) of the 

distributee or the joint lives (or joint life expectancies) of the distributee and the 

distributee’s designated beneficiary; or for a specified period of 10 years or 

more; or any distribution to the extent the distribution is required under IRC 

§401(a)(9); the portion of any distribution that is not includible in gross income. 

(b) Included Distributions. For purposes of the Plan direct rollover provisions, a 

portion of a distribution shall not fail to be an eligible rollover distribution 

merely because the portion consists of after-tax Employee contributions which 

are not includible in gross income. However, the portion of the distribution 

attributable to after-tax Employee contributions may be transferred only to an 

individual retirement account or annuity described in IRC §408(a) or (b), or to 

a qualified defined contribution plan described in IRC §401(a) or IRC 

§403(a), that agrees to separately account for amounts so transferred, 

including separately accounting for the portion of such distribution which is 

includible in gross income and the portion of such distribution which is not so 

includible.18 

2. Eligible Retirement Plan. An eligible retirement plan is an individual retirement 

account described in IRC §408(a), an individual retirement annuity described in IRC 

§408(b) or IRC §408A(b),19 a qualified trust described in IRC §401(a) that accepts the 

distributee's eligible rollover distribution, an annuity plan described in IRC §403(a), an 

annuity contract described in IRC §403(b), and an eligible plan under IRC §457(b) 

which is maintained by a state, political subdivision of a state, or any agency or 

instrumentality of a state or political subdivision of a state and which agrees to 

separately account for amounts transferred into such plan from this Plan. 

3. Direct Rollover. A direct rollover is a payment by a plan directly to the specified 

eligible retirement plan.

18 This rule on after-tax contributions is effective for direct rollovers after December 31, 2006.

19 IRC 408A(b) is a “Roth” IRA and is effective for eligible rollover distributions (effective on or after June 1, 2007.

Exhibit 14: Page 38 of 62
B. ROLLOVERS FROM THE PLAN: SURVIVING SPOUSES AND ALTERNATE 

PAYEES

The rules provided in paragraph A. above for participants make direct rollovers from the Plan 

shall also apply to a surviving spouse, spouse or former spouse of a Participant who is an alternate 

payee under a Qualified Domestic Relations Order.

C. ROLLOVERS FROM THE PLAN: NONSPOUSE BENEFICIARIES

A nonspouse beneficiary of deceased participant may elect, at the time and in the manner 

prescribed by the Board of Trustees, to have any portion of his or her distribution paid as a direct 

rollover. However, an “eligible retirement plan” for a distributee who is a nonspouse beneficiary 

shall be limited to an individual retirement account described in IRC §408(a) or an individual 

retirement annuity described in IRC §408(b) established by the nonspouse beneficiary to accept the 

direct rollover as an “inherited IRA” under IRC § 402(c)(11) (the IRA must be established in a 

manner that identifies it as an IRA with respect to a deceased individual and also identifies the 

deceased individual and the beneficiary).20

D. ROLLOVERS TO THE PLAN: PENSION ENHANCEMENT OPTION

You may elect to have your pension increased by the actuarial equivalent of a rollover as 

provided in this section. All rollovers to the Plan are subject to advance approval by the Plan 

Administrator and must comply with the Plan’s rollover policy.

(a) The rollover must satisfy the requirements direct rollover provided that the transferred 

assets would be included in gross income if the assets were not transferred to the Plan. 

(b) A Pension Enhancement Option is available to you on or after the date you commence 

to receive a Normal, Early, of Delayed Retirement Benefit.

(c) The original amount of any rollover must be a minimum of $10,000.

(d) A rollover will be permitted not earlier than 90 days before the commencement of the 

payment of a Pension Enhancement Option. If you are eligible for a Disability Benefit, 

a rollover will be permitted within 90 days of the time that you qualify for the Normal 

Retirement Benefit. 

(e) The benefits paid to you under the Pension Enhancement Option will be in the same 

form, with the exception stated in paragraph (f), below, as the benefits selected under 

this plan and will be calculated using reasonable actuarial assumptions.

(f) Upon your death and the death of a beneficiary, who you select to have a survivor's 

annuity, a single sum death benefit will be paid to an alternate beneficiary designated 

by you in an amount equal to the excess, if any, of the amount of the rollover over the 

total of the monthly benefits paid attributable to the rollover.

20 This paragraph is effective for distributions after December 31, 2006.

Exhibit 14: Page 39 of 62
OTHER PROVISIONS

ALIENATION OF BENEFITS

The provisions of this Plan are intended as a personal protection for you. You do not have 

any right to assign, anticipate or transfer any assets held for your benefit. The benefits under this 

Plan are not subject to seizure by legal process or in any way subject to the claims of your creditors 

except for: (a) a claim that the Trustees may have against you; (b) a QDRO. The Plan’s benefits, or 

the Plan assets, are not considered your asset in the event of your insolvency or bankruptcy. 

QUALIFIED DOMESTIC RELATIONS ORDERS

A “Qualified Domestic Relations Order” or “QDRO” means a domestic relations order 

which creates or recognizes an Alternate Payee’s rights to, or assigns to an Alternate Payee, all or a 

portion of the Participant’s benefits under this Plan. The domestic relations order shall specify: (a) 

the name and last known mailing address of the Participant and each Alternate Payee; (b) the amount 

or percentage of the Participant’s account balance payable to each Alternate Payee or the method to 

calculate the amount payable to each Alternate Payee; (c) the number of payments or periods to 

which the order shall apply; and (d) a statement that the order shall apply to this Plan. The Plan 

Administration Office shall determine whether a domestic relations order is a “Qualified Domestic 

Relations Order” upon following consistently applied reasonable procedures adopted by the 

Trustees. 

(a) A domestic relations order shall mean any judgment, decree, or order (including 

approval of a property settlement agreement) which: 

(1) relates to the provision of child support, alimony payments, or marital 

property rights to a spouse, former spouse, child, or other dependent of a 

Participant, and 

(2) is made pursuant to a state domestic relations law (including a community 

property law).

(b) An “Alternate Payee” means any spouse, former spouse, child or other dependent of a 

Participant who is recognized by a domestic relations order as having a right to 

receive all, or a portion of, the benefits payable under a plan with respect to such 

Participant.

(c) A domestic relations order that otherwise satisfies the requirements for a qualified 

domestic relations order (“QDRO”) will not fail to be a QDRO: (1) solely because the 

order is issued after, or revises, another domestic relations order or QDRO; or (2) 

solely because of the time at which the order is issued, including issuance after the 

annuity starting date or after the Participant’s death.21

21 This paragraph is effective April 6, 2007.

Exhibit 14: Page 40 of 62
ACCUMULATION OF BENEFITS FROM MORE THAN ONE EMPLOYER

You accumulate benefits from employment with any Employer participating in this Plan. 

This includes a move between jurisdictions of different locals of the Office and Professional 

Employees International Union AFL-CIO providing both locals are participants in this Pension Plan. 

RECIPROCITY AGREEMENTS

Reciprocity agreements exist between the Pension Plans covering members of OPEIU Local 

3 in San Francisco and OPEIU Local 30 in Los Angeles. If you are transferring covered 

employment between this Fund and the San Francisco or Los Angeles Funds, be sure to notify both 

Plan Administration Offices within 30 days of such transfer. You will be advised of your status. 

MAXIMUM BENEFIT

The maximum annual retirement benefit payable under this Pension Plan shall not exceed the 

amount permitted under IRC Section 415. The maximum salary for calculating benefits shall not 

exceed the limit permitted under IRC Section 401(a)(17). The maximum Annual Compensation 

shall not exceed the sum of $200,000.00 as adjusted for cost of living increase in accordance with 

IRC §401(a)(17)(B). The cost of living increase in effect for a calendar year shall apply to Annual 

Compensation for the determination period that begins with or within the calendar year. 

For purposes of the requirements described above, Annual Compensation shall include salary 

deferrals which are not includible in gross income of the Employee under IRC §§125, §132(f), 

§402(e)(3), §402(h) or §403(b). 

The definition of compensation in IRC §401(a)(17) is used for purposes of: (1) applying the 

limitations of IRC §415 (except as otherwise provided in this Plan); (2) determining who is an HCE 

under IRC §414(q); (3) determining who is a key-employee under IRC §; and (4) the minimum topheavy contributions and benefits required by IRC §416. 

DISTRIBUTION NOTICES

Distribution notices shall be provided not more than 180 days before the distribution date (or 

annuity starting date, if applicable) in applying the notice requirements under IRC §402(f) (rollover 

notice), IRC §411(a)(11) (consent to distribution) or IRC §417 (annuity notice).22 

 

22 This paragraph is effective as of January 1, 2007.

Exhibit 14: Page 41 of 62
IF THE PLAN MERGES WITH

ANOTHER PLAN OR TERMINATES

MERGER PROCEDURES

If the Plan merges or consolidates with, or transfers assets or liabilities to, any other plan, the 

benefits each participant will be entitled to receive will be equal to the benefit that the participant 

would have been entitled to receive immediately before the merger, consolidation or transfer as if 

the Plan had then terminated. This provision shall apply only to the extent determined by the 

Pension Benefit Guaranty Corporation. 

TERMINATION PROCEDURES

The Board of Trustees has the right to discontinue or terminate this Plan in whole or in part. 

The rights of all affected Participants to any benefit accrued to the date of the termination, partial 

termination or discontinuance will be governed by ERISA sections 404(a) and 4281 and the 

regulations there under. 

PLAN TERMINATION INSURANCE

Your pension benefits under this multiemployer plan are insured by the Pension Benefit 

Guaranty Corporation (“PBGC”), a federal insurance agency. A multiemployer plan is a collectively 

bargained pension arrangement involving two or more unrelated employers, usually in a common 

industry. 

 The PBGC’s multiemployer plan program provides financial assistance to plans that are 

insolvent. A multiemployer plan is considered insolvent if the plan is unable to pay benefits (at least 

equal to the PBGC’s guaranteed benefit limit) when due.

The maximum benefit that the PBGC guarantees is set by law. Under the multiemployer 

program, the PBGC guarantee equals a participant’s years of service multiplied by: (1) 100% of the 

first $5 of the monthly benefit accrual rate and (2) 75% of the next $15. The PBGC’s maximum 

guarantee limit is $16.25 per month times a participant’s years of service. For example, the 

maximum annual guarantee for a retiree with 30 years of service would be $5,850. 

The PBGC guarantee generally covers: (1) normal and early retirement benefits; (2) 

disability benefits if you become disabled before the plan becomes insolvent; and (3) certain benefits 

for your survivors. 

The PBGC guarantee generally does not cover: (1) benefits greater than the maximum 

guaranteed amount set by law; (2) benefit increases and new benefits based on plan provisions that 

have been in place for fewer than 5 years at the earlier of: (i) the date the plan terminates or (ii) the 

time the plan becomes insolvent; (3) benefits that are not vested because you have not worked long 

enough; (4) benefits for which you have not met all of the requirements at the time the plan becomes 

insolvent; and (5) non-pension benefits, such as health insurance, life insurance, certain death 

benefits, vacation pay and severance pay.

Exhibit 14: Page 42 of 62
 For more information about the PBGC and PBGC guarantied benefits, you can ask the 

Administrative Office or the PNGC. Inquiries to the PNGC should be addressed as follows: 

PBGC Technical Assistance Division

1200 K Street, N.W., Suite 930 

Washington, D.C. 20005-4026 

Phone: 202-326-4000 (not a toll-free number). TTY/TDD users may call the federal relay 

service toll-free at 1-800-877-8339 and ask to be connected to 202-326-4000. 

Additional information about the PBGC’s pension insurance program is available through the 

PBGC’s website on the Internet at http://www.pbgc.gov.

Exhibit 14: Page 43 of 62
THE PLAN AND PLAN 

ADMINISTRATION

The Western States Office and Professional Employees Pension Fund was organized in 1959 

to implement the provisions for a pension program in the collective bargaining agreements between 

OPEIU Local 29 (Oakland, California) and OPEIU Local 11 (Portland, Oregon) with Consolidated 

Freightways and Pacific Intermountain Express. The Plan operates according to an Agreement and 

Declaration of Trust, as amended. Copies of the Trust Agreement are on file at your local union 

office and at the Plan Administration Office and are available for your inspection. 

PARTICIPATING EMPLOYERS

The Trust Agreement provides for the admission, subject to Trustee acceptance, of any local 

union of the Office and Professional Employees International Union which has a pension agreement 

in effect with an Employer and of any Employer who has a collective bargaining agreement with a 

local union which includes a pension agreement. 

A complete list of contributing Employers and participating unions sponsoring the Plan may 

be inspected at the Plan Administration Office. Upon written request to the Plan Administration 

Office, Plan participants and beneficiaries may receive information whether a particular Employer or 

local union participates in the Plan and, if so, the address of the Employer and/or local union. In 

addition, Plan participants and beneficiaries may request a copy of the applicable collective 

bargaining agreement.

BOARD OF TRUSTEES

The administrator of the Plan is the Board of Trustees – one half represents participating 

unions and one half represents participating Employers. Local Union No. 11 and Local Union No. 

29 of the Office and Professional Employees International Union each have the right to appoint one 

union trustee. The union trustees have the right to select the other union trustees that are not selected 

by Local Union No. 11 or Local Union No. 29. The employer trustees have the right to select the 

other employer trustees if there is a vacancy. You can obtain a list of the current trustees by 

contacting the Plan Administration Office. All correspondence to the trustees should be sent to the 

Plan Administration Office.

In order to assist in the administration of the Plan, the Board of Trustees has engaged a 

professional staff including a third party administrator, an attorney, an actuary, an auditor, 

investment managers; an investment monitor. The day-to-day management of the Plan is provided 

by the Plan Administration Office.

Exhibit 14: Page 44 of 62
ACCUMULATION OF ASSETS

Income of the Plan consists of Employer contributions and earnings from investments. 

Expenses of the Plan include operational costs and the payment of benefits. The balance goes into 

the reserves for payment of future benefits after expenses are deducted from income.

All monies received by the Plan are placed in an interest-bearing account. Investments are 

made by the investment manager according to the investment policy adopted by the Board of 

Trustees. 

THE PENSION PLAN

A duty of the Board of Trustees is to develop, adopt and manage the Plan and to review and 

modify the Plan from time to time as may be required by actuarial and legal requirements. The Plan 

of the Western States Office and Professional Employees Pension Fund as adopted and amended by 

the Board of Trustees has been described earlier in this booklet. The Plan provides eligible 

participants with monthly benefits upon normal or early retirement and upon permanent disability. 

The amount of contribution is determined by collective bargaining agreements between the 

local unions and the Employers. The level of benefits is determined actuarially and is based on 

contribution income, investment yield, mortality rates, turnover of employees, general economic 

conditions and other factors affecting income and costs. Actuarial evaluations are performed by 

enrolled actuaries retained by the Trustees on the participants’ behalf. Cost projection and 

determination of benefit levels are made by the Trustees based on advice of the actuary and 

consultants. 

PLAN INFORMATION

Plan fiscal year: January 1st to December 31st. 

Plan Tax Identification Number: 94-6076144. 

Address of the Board of Trustees and Plan Administration Office:

BeneSys, Inc. 

1220 S.W. Morrison St, Suite 300 

Portland. OR 97205-2222 

Toll-Free: (800) 413-4928 

Local: (503) 222-7694 

Agent for service of process: BeneSys, Inc. 

Exhibit 14: Page 45 of 62
HOW TO SECURE 

ADDITIONAL 

INFORMATION 

You should contact the Plan’s Administration Office if you wish to be certain of your right to 

any particular benefit. Only the Board of Trustees is authorized to give binding answers and only if 

you have furnished full and accurate information concerning your situation. Employers, unions and 

their representatives are not authorized to interpret this Plan. 

PLAN DOCUMENTS

 Certain documents and other information may be of interest to you. These are: 

1. Latest annual report filed with Internal Revenue Service (Form 5500) 

2. Latest Summary Plan Description filed with Department of Labor

3. Amended Agreement and Declaration of Trust

4. Collective Bargaining Agreements (specify Employer name)

5. Employer participation agreements

6. Reciprocity Agreements and Rules

Procedures for Review of Plan Documents:

Plan documents are available for review at the Plan Administration Office or your Local 

Union Office during normal business hours. It is suggested that you contact the Plan Administration 

Office for an appointment prior to visiting the Plan Administration Office. Plan documents are also 

available at the Plan’s website: http://www.wsp.aibpa.com and can be downloaded at no charge. 

Procedure for Requesting Copies of Plan Documents:

Requests for copies of Plan Documents must be in writing and must specify the documents 

which you wish to receive. 

 Requests should be addressed to: 

Western States Office and Professional Employees Pension Fund

c/o BeneSys, Inc.

1220 S.W. Morrison St, Suite 300 

Portland. OR 97205-2222 

Exhibit 14: Page 46 of 62
YOUR RIGHTS

UNDER ERISA

As a Participant in Western States Office and Professional Employees Pension Fund you are 

entitled to certain rights and protections under the Employee Retirement Income Security Act of 

1974 (ERISA). ERISA provides that all Plan participants shall be entitled to:

Receive Information About Your Plan and Benefits

1. Examine, without charge, at the Plan’s Plan Administration Office and at union 

offices, all Plan documents, including collective bargaining agreements, and copies of 

all documents filed by the Plan with the U.S. Department of Labor, such as annual 

reports (Form 5500) and updated summary plan descriptions. 

2. Obtain copies of all Plan documents and other Plan information upon written request 

to the Plan Administrative Office. The Trustees may make a reasonable charge for 

the copies. (See page 37 for details).

3. Receive a summary of the Plan’s annual report. The Trustees are required by law to 

furnish each participant with a copy of this summary financial report which will be 

mailed to you. 

4. Obtain a statement telling you whether you have a right to receive a pension at 

Normal Retirement age (age 65) and, if so, what your benefits would be at Normal 

Retirement age if you, now stop working under the Plan. If you do not have a right to 

a pension, the statement will tell you how many more years you have to work to get a 

pension. This statement must be requested in writing and is not required to be given 

more than once every twelve (12) months. The Plan must provide the statement free 

of charge.

Prudent Actions by Plan Fiduciaries

In addition to creating rights for Plan participants, ERISA imposes duties upon the people 

who are responsible for the operation of the Plan. The people who operate your Plan, called 

“fiduciaries” of the Plan, have a duty to do so prudently and in the interest of you and other plan 

participants and beneficiaries. No one, including your Employer, your union, or any other person, 

may fire you or otherwise discriminate against you in any way to prevent you from obtaining a 

pension benefit or exercising your rights under ERISA. 

Enforce Your Rights

If your claim for a pension is denied or ignored, in whole or in part, you have a right to know 

why this was done, to obtain copies of documents relating to the decision without charge, and to 

appeal any denial, all with certain time schedules. 

Exhibit 14: Page 47 of 62
Under ERISA, there are steps you can take to enforce your rights. For instance, if you 

request materials from the Plan and do not receive them within 30 days, you may file suit in a 

federal court. In such a case, the court may require the Board of Trustees to provide the materials 

and pay you a daily penalty (up to $110 a day) until you receive the materials, unless the materials 

were not sent because of reasons beyond the control of the Board of Trustees. 

If you have a claim for benefits which is denied or ignored, in whole or in part, you may file 

suite in a state or federal court. In addition, if you disagree with the Plan’s decision, or lack of a 

decision, concerning the qualified status of a domestic relations order you may file suit in federal 

court. If the Plan fiduciaries misuse the Plan’s money, or if you are discriminated against for 

asserting your rights, you may seek assistance from the U.S. Department of Labor, or you may file 

suit in a federal court. The court will decide who should pay court costs and legal fees. If you are 

successful, the court may order the person you have sued to pay these costs and fees. If you lose, the 

court may order you to pay these costs and fees, for example, if the court finds that your claim is 

frivolous. 

Assistance with Your Questions

If you have any questions about your Plan, you should contact the Plan’s Administration 

Office. If you have any questions about this statement or about your rights under ERISA, or if you 

need assistance in obtaining documents from the Plan’s Administrative Office, you should contact 

the nearest office of the Employee Benefits Security Administration, U.S. Department of Labor, 

listed in your telephone directory or the Division of Technical Assistance and Inquiries, Employee 

Benefits Security Administration, U.S. Department of Labor, 200 Constitution Avenue N.W., 

Washington, D.C. 20210. You may also obtain certain publications about your rights and 

responsibilities under ERISA by call the publications hotline of the Employee Benefits Security 

Administration.

Exhibit 14: Page 48 of 62
ADDENDUM A:

PLAN TECHNICAL 

PROVISIONS REQUIRED

TO COMPLY WITH

INTERNAL REVENUE

CODE PROVISIONS

PENSION FUNDING EQUITY ACT OF 2004 PROVISIONS

A. Straight life Annuity Subject To Present Value Rules. 

The straight life annuity that is actuarially equivalent to the Participant’s form of benefit shall 

be determined under this Section if the form of the Participant’s benefit is either: (a) a nondecreasing 

annuity (other than a straight life annuity) payable for a period of not less than the life of the Participant 

(or, in the case of a qualified pre-retirement survivor annuity, the life of the surviving spouse), or (b) an 

annuity that decreases during the life of the Participant merely because of: (1) The death of the survivor 

annuitant (but only if the reduction is not below 50% of the benefit payable before the death of the 

survivor annuitant), or (2) the cessation or reduction of Social Security supplements or qualified 

disability payments (as defined in IRC §401(a)(11)).

B. Limitations Year prior to July 1, 2007. 

For Limitation Years beginning before July 1, 2007, the actuarially equivalent straight life 

annuity is equal to the annual amount of the straight life annuity commencing at the same annuity 

starting date that has the same actuarial present value as the Participant’s form of benefit computed 

using whichever of the following produces the greater annual amount: (a) the interest rate and the 

mortality table (or other tabular factor) specified in the Plan for adjusting benefits in the same form; 

and (b) 5 percent interest rate assumption and the “applicable mortality table” defined in the Plan for 

that annuity starting date.

C. Limitation Years beginning on or after July 1, 2007. 

For Limitation Years beginning on or after July 1, 2007, the actuarially equivalent straight 

life annuity is equal to the greater of: (a) the annual amount of the straight life annuity (if any) 

payable to the Participant under the Plan commencing at the same annuity starting date as the 

Participant’s form of benefit; and (b) the annual amount of the straight life annuity commencing at 

the same annuity starting date that has the same actuarial present value as the Participant’s form of 

benefit, computed using a 5 percent interest rate assumption and the applicable mortality table 

defined in the Plan for that annuity starting date. 

Exhibit 14: Page 49 of 62
D. Benefit Forms Subject to the Present Value Rules of Code Section 417(e)(3). 

(1) Form of Benefit. The straight life annuity that is actuarially equivalent to the 

Participant’s form of benefit shall be determined as indicated under this Section if the form 

of the Participant’s benefit is other than a benefit form described in Section A.

(2) Annuity Starting Date in small plans for Plan Years Beginning in 2009 and later. 

Notwithstanding anything in this Section to the contrary, if the annuity starting date of the 

Participant’s form of benefit is in a Plan Year beginning in or after 2009, and if the Plan is 

maintained by an eligible employer as defined IRC §408(p)(2)(C)(i), the actuarially 

equivalent straight life annuity is equal to the annual amount of the straight life annuity 

commencing at the same annuity starting date that has the same actuarial present value as the 

Participant’s form of benefit, computed using whichever of the following produces the 

greater annual amount: (a) the interest rate and the mortality table (or other tabular factor) 

specified in the Plan for adjusting benefits in the same form; and (b) a 5.5 percent interest 

rate assumption and the applicable mortality table.

(3) Annuity Starting Date in Plan Years Beginning After 2005. If the annuity starting 

date of the Participant’s form of benefit is in a Plan Year beginning after December 31, 2005, 

the actuarially equivalent straight life annuity is equal to the greatest of: (a) the annual 

amount of the straight life annuity commencing at the same annuity starting date that has the 

same actuarial present value as the Participant’s form of benefit, computed using the interest 

rate and the mortality table (or other tabular factor) specified in the Plan for adjusting 

benefits in the same form; (b) the annual amount of the straight life annuity commencing at 

the same annuity starting date that has the same actuarial present value as the Participant’s 

form of benefit, computed using a 5.5 percent interest rate assumption and the applicable 

mortality table for the distribution under section 1.417(e)-1(d)(2) of the Treasury regulations 

(determined in accordance with Article 25 for Plan Years after the effective date specified 

below); and (c) the annual amount of the straight life annuity commencing at the same 

annuity starting date that has the same actuarial present value as the Participant’s form of 

benefit, computed for the distribution under section 1.417(e)-1(d)(3) of the Treasury 

regulations and the applicable mortality table for the distribution under section 1.417(e)-

1(d)(2) of the Treasury regulations (determined in accordance with Article VIII for Plan 

Years after the effective date specified below), divided by 1.05. The effective date of the 

applicable mortality table for this section is for years beginning after December 31, 2008. 

(4) Annuity Starting Date in Plan Years Beginning in 2004 or 2005. If the annuity 

starting date of the Participant’s form of benefit is in a Plan Year beginning in 2004 or 2005, 

the actuarially equivalent straight life annuity is equal to the annual amount of the straight 

life annuity commencing at the same annuity starting date that has the same actuarial present 

value as the Participant’s form of benefit, computed using whichever of the following 

produces the greater straight life annuity: (a) the interest rate and the mortality table (or other 

tabular factor) specified in the Plan for adjusting benefits in the same form; and (b) a 5.5 

percent interest rate assumption and the applicable mortality table for the distribution under 

section 1.417(e)-1(d)(2) of the Treasury regulations 

Exhibit 14: Page 50 of 62
FINAL 415 REGULATIONS

Notwithstanding anything in this Plan to the contrary, the requirements under this section, IRC §415 

and the IRC §415 final regulations are incorporated herein by reference for limitation years 

beginning on or after July 1, 2007, except to the extent an earlier or later effective date is provided in 

the regulations or under this Plan. In no case shall nay benefit exceeding IRC §415 be accrued, 

distributed or otherwise payable in any form of payment at any time under the Plan. 

A. Grandfather provision. The application of the provisions of this Article shall not cause the 

maximum permissible benefit for any Participant to be less than the Participant’s accrued benefit 

under all the defined benefit plans of the employer or a predecessor employer as of the end of the 

last limitation year beginning before July 1, 2007, under provisions of the plans that were both 

adopted and in effect before April 5, 2007. The preceding sentence applies only if the provisions of 

such defined benefit plans that were both adopted and in effect before April 5, 2007, satisfied the 

applicable requirements of statutory provisions, regulations, and other published guidance relating to 

IRC §415 in effect as of the end of the last limitation year beginning before July 1, 2007, as 

described in section 1.415(a)-1(g)(4) of the Treasury regulations. 

B. Incorporation by reference. Notwithstanding anything contained in the Plan to the contrary, 

the limitations, adjustments, and other requirements prescribed in the Plan shall comply with the 

provisions of IRC §415 and the final regulations promulgated thereunder, the terms of which are 

specifically incorporated herein by reference as of the effective date of this Section, except where an 

earlier effective date is otherwise provided in the final regulations or in this Section. However, 

where the final regulations permit the Plan to specify an alternative option to a default option set 

forth in the regulations, and the alternative option was available under statutory provisions, 

regulations, and other published guidance relating to IRC §415 as in effect prior to April 5, 2007, 

and the Plan provisions in effect as of April 5, 2007, incorporated the alternative option, said 

alternative option shall remain in effect as a plan provision for Limitation Years beginning on or 

after July 1, 2007, unless another permissible option is selected in this Section. 

C. High three-year average compensation. For purposes of the Plan’s provisions reflecting IRC 

§415(b)(3) (i.e., limiting the annual benefit payable to no more than 100% of the Participant’s 

average annual compensation), a Participant’s average compensation shall be the average 

compensation for the three consecutive years of service, except that a Participant’s compensation for 

a year of service shall not include compensation in excess of the limitation under IRC §401(a)(17) 

that is in effect for the calendar year in which such year of service begins. If the Participant has less 

than three consecutive years of service, compensation shall be averaged over the Participant’s 

longest consecutive period of service, including fractions of years, but not less than one year. In the 

case of a Participant who is rehired by the Employer after a severance of employment, the 

Participant’s high three-year average compensation shall be calculated by excluding all years for 

which the Participant performs no services for and receives no compensation from the Employer (the 

“break period”), and by treating the years immediately preceding and following the break period as 

consecutive.

D. Adjustment to dollar limit after date of severance. In the case of a Participant who has had a 

severance from employment with the Employer, the defined benefit dollar limitation applicable to 

Exhibit 14: Page 51 of 62
the Participant in any Limitation Year beginning after the date of severance shall not be 

automatically adjusted under IRC §415(d). 

E. Compensation paid after severance from employment. For limitation years beginning on or 

after July 1, 2007, or such earlier date as specified below, compensation for a limitation year, within 

the meaning of IRC §415(c)(3), shall not include the following types of compensation paid by the 

later of 21⁄2 months after a Participant’s severance from employment with the employer maintaining 

the plan or the end of the Limitation Year that includes the date of the Participant’s severance from 

employment with the employer maintaining the plan. Any other payment of compensation paid after 

severance of employment that is not described in the following types of compensation is not 

considered compensation within the meaning of IRC §415(c)(3), even if payment is made within the 

time period specified above.

(1) Regular pay after severance from employment. Compensation shall include regular 

pay after severance of employment if: 

(a) The payment is regular compensation for services during the Participant’s 

regular working hours, or compensation for services outside the Participant’s 

regular working hours (such as overtime or shift differential), commissions, 

bonuses, or other similar payments; and 

(b) The payment would have been paid to the Participant prior to a severance 

from employment if the Participant had continued in employment with the 

employer.

(2) Leave cashouts and deferred compensation. Leave cashouts and deferred 

compensation shall be included in compensation, if those amounts would have been included 

in the definition of compensation if they were paid prior to the Participant’s severance from 

employment with the Employer maintaining the Plan, and the amounts are either: 

(a) Payment for unused accrued bona fide sick, vacation, or other leave, but only 

if the Participant would have been able to use the leave if employment had 

continued; or 

(b) Received pursuant to a nonqualified unfunded deferred compensation plan, 

but only if the payment would have been paid to the if the Participant had 

continued in employment with the employer and only to the extent that the 

payment is includible in the Participant’s gross income.

(3) Salary continuation payments for military service Participants. Compensation does 

include payments to an individual who does not currently perform services for the employer 

by reason of qualified military service (as that term is used in IRC §414(u)(1)) to the extent 

those payments do not exceed the amounts the individual would have received if the 

individual had continued to perform services for the employer rather than entering qualified 

military service. 

Exhibit 14: Page 52 of 62
(4) Salary continuation payments for disabled Participants. Compensation does include 

compensation paid to a Participant who is permanently and totally disabled (as defined in 

IRC §22(e)(3)) if the Participant is not a highly compensated employee (as defined in IRC 

§414(q)) immediately before becoming disabled, or to all Participants if the Plan provides for 

the continuation of compensation on behalf of all Participants who are permanently and 

totally disabled for a fixed or determinable period. 

F. Administrative delay. Compensation for a limitation year shall include amounts earned but 

not paid during the limitation year solely because of the timing of pay periods and pay dates, 

provided the amounts are paid during the first few weeks of the next limitation year, the amounts are 

included on a uniform and consistent basis with respect to all similarly situation Participants, and no 

compensation is included in more than one limitation year

G. No other multiemployer plan shall be aggregated with this Plan for purposes of applying the 

limits of IRC §415. 

PENSION PROTECTION ACT

A. Notices given to Participants pursuant to IRC §411(a)(11) in Plan Years beginning after 

December 31, 2006, shall include a description of how much larger benefits will be if the 

commencement of distributions is deferred. 

B. Notices to Participants shall include the relative values of the various optional forms of 

benefit, if any, under the Plan as provided in Regulations Section 1.417(a)-3. This provision is 

effective as of the applicable effective date set forth in Regulations (i.e., to qualified pre-retirement 

survivor annuity explanations provided on or after July 1, 2004; to qualified joint and survivor 

annuity explanations with respect to any distribution with an annuity starting date that is on or after 

February 1, 2006, or on or after October 2, 2004 with respect to any optional form of benefit that is 

subject to the requirements of IRC §417(e)(3) if the actuarial present value of that optional form is 

less than the actuarial present value as determined under IRC §417(e)(3)). 

PRESENT VALUE CALCULATION AND CHANGE IN APPLICABLE INTEREST RATE 

AND APPLICABLE MORTALITY ASSUMPTION

A. Prior to January 1, 2008. 

“Present value” for determining lump sum distributions is calculated using: (a) the 

“applicable interest rate” and (b) the “applicable mortality table.” The “applicable interest rate” 

means the annual interest rate of thirty (30) year Treasury securities as specified by the 

Commissioner of Internal Revenue for the month of October preceding the plan year of 

distribution. The “applicable mortality table” means the mortality table as defined in 

IRC §417(e)(3)(A)(ii)(I), which is prescribed by the Commissioner of Internal Revenue. Present 

value shall be calculated with an interest rate which shall be the lesser of the plan’s interest rate or 

the Pension Benefit Guaranty Corporation’s applicable interest rate as of the first day of the plan 

year which contains the annuity starting date 

Exhibit 14: Page 53 of 62
B. On or After January 1, 2008. 

The limitations of this following provisions shall first apply in determining the amount 

payable to a Participant having an annuity starting date on or after January 1, 2008, except as 

provided by the Pension Benefit Guaranty Corporation (PBGC) and/or the IRS. 

Applicable Interest Rate. For purposes of the Plan’s provisions relating to the calculation of 

the present value of a benefit payment that is subject to IRC §417(e), any provision 

prescribing the use of the annual rate of interest on 30-year U.S. Treasury securities shall be 

implemented by instead using the rate of interest determined by applicable interest rate 

described by IRC §417(e) after its amendment by PPA. Specifically, the applicable interest 

rate shall be the adjusted first, second, and third segment rates applied under the rules similar 

to the rules of IRC §430(h)(2)(C) for the month of October preceding the Plan Year of 

distribution or such other time as the Secretary of the Treasury may by regulations prescribe. 

For this purpose, the first, second, and third segment rates are the first, second, and third 

segment rates which would be determined under IRC §430(h)(2)(C) if: 

(1) IRC §430(h)(2)(D) were applied by substituting the average yields for the 

month described in clause (b) below for the average yields for the 24-month 

period described in such section, and 

(2) IRC §430(h)(2)(G)(i)(II) were applied by substituting “Section 

417(e)(3)(A)(ii)(II) for “Section 412(b)(5)(B)(ii)(II),” and

(3) The applicable percentage under IRC §430(h)(2)(G) is treated as being 20% in 

2008, 40% in 2009, 60% in 2010, and 80% in 2011. 

Applicable mortality assumption. For purposes of the Plan's provisions relating to the 

calculation of the present value of a benefit payment that is subject to IRC §417(e), any 

provision directly or indirectly prescribing the use of the mortality table described in 

Revenue Ruling 2001-62 shall be amended to prescribe the use of the applicable annual 

mortality table within the meaning of IRC §417(e)(3)(B), as initially described in Revenue 

Ruling 2007-67 and Notice 2008-85. 

Exhibit 14: Page 54 of 62
ADDENDUM B: 

HEART ACT 

AMENDMENT 

HEROES ASSISTANCE AND RELIEF TAX ACT OF 2008 AMENDMENT

In the case of a death occurring on or after January 1, 2007, if a Participant dies while performing 

qualified military service (as defined in Code § 414(u)), the survivors of the Participant are entitled 

to any additional benefits (other than benefit accruals relating to the period of qualified military 

service) provided under the Plan as if the Participant had resumed and then terminated employment 

on account of death. 

Exhibit 14: Page 55 of 62
Exhibit 14: Page 56 of 62
Attested to by:

L' ou,", Vl *fug

Joseph RÞínhar1, Pension

Exhibit 14: Page 57 of 62
, 

, 

On page i, the reference to "Pages I through 37" shall be changed to "Pages 1 through

41."

On page ii, the Plan shall be amended by adding the following new provision:PLAN ASSETS:

Employer contributions of any kind are deemed to be "plan assets" of the

Plan, as that term is defined under ERISA, as soon as the hours on which thecontributions are based are worked (or taken, in the case of covered nonwork time,

like leaves and vacations). The employer shall have a fiduciary duty over plan assets

under the employer's control. This provision shall be automatically considered a

contractual provision of all Participation Agreements and/or collective bargaining

agreements that require Plan contributions. The Plan shall be deemed to have a

beneficial and/or property interest in deemed plan assets under applicable state law.The Plan shall have the authority to take all actions allowed under ERISA to collectthe deemed plan assets.On page 13, the second paragraph under the title "MANDATORY RETIREMENT

BENEFIT AT AGE 70 Y2" shall be amended and restated as follows:

Your benefit will be calculated according to the section above

entitled, "FOR POSTPONED RETIREMENT AFTER NORMAL

RETIREMENT AGE." If you continue to work and have contributions

made to the Plan on your behalf, your benefit will be calculated according to the section below entitled, 66ACCRUAL OF BENEFITS AFTER

RETIREMENT." Any increase to your benefit will be added to, and paid in,the same form as the benefits you are receiving.

Starting on page 13, the paragraph under the title "A Benefits Accrued Before January

1,2010" shall be amended and restated as follows:

Earl]¡ Retirement. Assume that before January 1,2010, you earned a benefit

of $2,000 per month payable as a Straight Life Annuity at age 62. The

Normal Retirement Age for this benefit is age 62 so there is a reduction for

early retirement if you retire before that age. For example, the early

retirement factor (see Column A on the following chart) at age 59, is 75.80%

aJ.

4.

5.

6.

Exhibit 14: Page 58 of 62
6,

retirement until age 66. The Actuarial Increase Factor (see Column H on the

following chart) is 24Yo, which results in the following increased benefit:

Original benefit: $2,000 per month at age 66

Actuarial increase: $480 per month ($2,000 x24%o: $480)

Increased benefit: $2,480 per month ($2,000 + 480 : $2,480) at age 66

On page 14, the section titled "B Benefits Accrued After December 31, 2009" shall beamended and restated as follows:

Early Retirement. Assume that after December 31, 2009, you earned a

benefit of $250 per month payable as a Straight Life Annuity aL age 65. The

Normal Retirement Age for this benefit is age 65 so there is an actuarial

reduction for early retirement if you retire before that age. For example, the

early retirement factor (see Column F on the following chart) at age 64, is

90.560Á, which results in the following reduced benefit:

Original benefit: $250 per month at age 64

Reduced benefit: $226 per month ($250 x 90.56%) at age 64

Note: There is no early retirement reduction for benefits earned on or after

January 1,2010, if you are age 65 or older when you retire.

Postponed Retirement. Under this same example, assume you postpone

retirement until age 67. The Actuarial Increase Factor (see Column I on the

following chart) is l2o/o, which results in the following increased benefits:Original benefit: $250 per month at age 65

Actuarial increase: $30 per month ($250 x l2%o: $30)

Increased benefit: $280 per month ($250 + 30: $2S0) at age 67

Note: See section below entitled, í¿ACCRUAL OF BENEFITS AFTER

RETIREMENT" for the rules that apply when determining your

postponed retirement if you continue to work for a contributing

employer and accrue additional benefits.

Exhibit 14: Page 59 of 62
V'IESTERN STATES OFFICE &

PROFESSIONAL EMPOLYEES PENSTON

Plan Number: 001

Dear Appl-icant:Based on the information you provided, we are issuing this favorable determination letter for your plan listed above. However, our favorable

determination only applies to the status of your pJ-an under t.he Internal

Revenue Code and is not a determination on the effect of other federal or local

statutes. To use t.his fetter as proof of the plan's sLatus, yoü must. keep this letter, Lhe appli-cation forms, and all- correspondence with us about your application.

Your determination let.t.er does not apply to any qualification changes thatbecome effective, any guidance issued, or any statutes enacLed after t.he dates specified in the Cumul-ative List of Changes in PIan Requirements (the

Cumul-at.ive List) for the cycJ-e you submiLted your application under, unl-ess the

new item was identified i-n the Cumulative List.

Your plan's continued qualification in j-ts present form will depend on it.s

ef fect in operat.ion (Section 1.401-1(b) (3) of t.he Income Tax Regulations) . We

may review the status of the plan in operation periodically.You can find more informat.ion on favorable determination letters in Publication

794, Favorable Determination Letter, including:

The signifj-cance and scope of reliance on this letter,The effect of any efecLive determination request in your application materials,The reporting requirements for qualified p1ans, and

Examples of t.he effect of a plan's operation on its qualified st.atus.

You can get a copy of Publication 794 by visj-tirìg our website at www.irs.gov/formspubs or by calling 1-800-TAX-FORM (1-800-A29-3676) to reguesL

a copy.

This lett.er considered the 2013 Cumul-ative List. of Changes in PlanQualíf ication Requirements .

This determination letter applies to the amendment.s dated on

LeLl¿er 5274

Exhibit 14: Page 60 of 62
Vùe made this determination on t.he conditj-on that you adopt the proposed

amendment.s you submit.ted in your letter dated L/26/16, on or before t.he date the Income Tax Regulations provide under Sect.ion 401 (b) of the InLernal Revenue Code.

This letter replaces our letter dated on or about February 19, 2016-

The information on the encl-osed addendum is an integral part of this determination. Please be sure to read it and keep it with this l-etter.

rf you submitted a Form 2848, power of Attorney and Decl-aratíon of RepresentaLive, or Form 882r, Tax rnformation Authorization, with your application and asked us to send your aut.horized representative or appointee copies of written communications, we will send a copy of this letter to him or her.

If you have any questions, you can contact t,he person listed at the top of this 1et.t.er.

Sincerely, f4,^'^-93*

Karen D. Truss

Director, EP Rulíngs & AgreemenLs

Addendum

Let|-er 5274

Exhibit 14: Page 61 of 62
LetLer 5274

Exhibit 14: Page 62 of 62