Central States, Southeast and Southwest Areas Pension Plan

Item #19 

Does the application include the information required by section 5.02. 

The information concerning contribution levels (section 5.02(1)(a)) is attached as document 

number 19.1. 

The information concerning levels of benefit accruals, including any prior reductions in the rate of 

benefit accruals (section 5.02(1)(b)) is attached as document number 19.2. 

The information concerning prior reductions, if any, of adjustable benefits under § 432(e)(8) 

(section 5.02(1)(c)) is attached as document number 19.3. 

The information concerning any prior suspension of benefits under § 432(e)(9) (section 5.02(1)(d)) 

is attached as document number 19.4. 

The information concerning measures undertaken by the plan sponsor to retain or attract 

contributing employers (section 5.02(1)(e)) is attached as document number 19.5. 

The information concerning the impact on plan solvency of the subsidies and ancillary benefits, if 

any, available to active participants (section 5.02(2)) is attached as document number 19.6. 

The information concerning compensation levels of active participants relative to employees in the 

participants’ industry generally (section 5.02(3)) is attached as document number 19.7. 

The information concerning competitive and other economic factors facing contributing employers 

(section 5.02(4)) is attached as document number 19.8. 

19.0
 

 

 

 

 

Checklist No. 19 / Rev. Proc § 5.02(1)(a):

19.1.1
Checklist No. 19 / Rev. Proc. § 5.02(1)(b):

Levels of benefits accruals, including any prior reductions in the rate of benefit accruals.

The current rate of benefit accruals under the Central States Plan is 1% of contributions 

(1% of contributions made on behalf of a participant is added to the participant’s monthly benefit 

upon retirement). This 1% accrual rate has been in effect since January 1, 2004. Prior to that time 

the accrual rate was 2%. 

19.2.1
Checklist No. 19 / Rev. Proc. § 5.02(1)(c):

Prior reductions of adjustable benefits under the PPA (IRC § 432(e)(8)) and other measures to 

forestall insolvency under the Fund’s rehabilitation plan. 

1. The Pension Protection Act (“PPA”) became effective in January 2008, and that 

statute provided the Trustee with additional tools to help address the Pension Fund’s financial 

difficulties.

2. The Trustees have approved and annually updated a rehabilitation plan each year 

beginning with 2008, as required of all multiemployer pension funds certified to be in critical 

status under the PPA. 

3. As authorized under the PPA [IRC § 432 (e)(8)], the Fund’s rehabilitation plan 

has provided for the elimination of “adjustable benefits” (essentially any benefits other than

those already in pay status prior to 2008, disability benefits in pay status at any time, and the 

accrued benefits (i.e., Contribution-Based Pensions) payable at age 65). The following events 

trigger a loss of adjustable benefits under the rehabilitation plan:

a) application of the rehabilitation plan’s Default Schedule; 

b) application of the rehabilitation plan’s Distressed Employer Schedule; and 

c) application of the rehabilitation plan’s Rehabilitation Plan Withdrawal rule (under 

which bargaining units that voluntarily withdraw from the Fund, or are complicit 

in a withdrawal, incur the elimination of all adjustable benefits).

4. The Fund’s actuary advises that in total, as of December 31, 2014 adjustable 

benefits with an accumulated present value of approximately $1.64 billion (as reflected in the 

Fund’s funding standard account) have been eliminated under these rehabilitation plan rules, 

including the elimination of the adjustable benefits attributable to the United Parcel Service, Inc. 

bargaining unit that withdrew from the Pension Fund at the end of 2007. 

19.3.1
5. As noted above, in 2009, the Fund for the first time was certified to be in critical 

status under the PPA and was also projected to become insolvent in 2022. 

6. As an additional part of the effort to forestall this projected insolvency, under a 

2010 amendment to the rehabilitation plan, the Trustees approved a rule establishing age 57 as 

the minimum retirement age under the Plan, and this rule was made effective on June 1, 2011. 

Prior to this amendment, there were minimum service requirements for various types of 

pensions, and reductions in benefit amounts for pre-age 65 retirements for those who did not 

qualify for early retirement pension, but there was not a minimum retirement age.

7. In formulating the rehabilitation plan and in the process of annually updating that 

plan, the Trustees considered a more expansive rule that would have eliminated all the adjustable 

benefits of all active participants, but as noted above, determined that doing so would likely (a) 

cause many active participants to withdraw their support for the Plan, (b) increase Employer 

withdrawals, and (c) ultimately cause a more rapid deterioration of the Fund’s financial condition 

and an acceleration of its projected insolvency. 

8. In developing the proposed suspension plan, the Trustees have also considered the 

elimination of all PPA adjustable benefits accrued by terminated participants who have fewer 

than 20 years of Contributory Service Credit. However, even after the proposed plan of benefit 

suspension is given effect (so that the elimination of the terminated-participants’ adjustable 

benefits has a longer time horizon in which to improve the Fund’s overall financial condition, 

and the duration of the impact of the elimination of the benefits is not limited by a projected 

insolvency date), the Fund’s actuary has advised that this measure, in conjunction with potential 

suspension plans would result in a reduction in the overall “caps” (or upper limits as a percentage 

reduction from current benefits entitlements) on suspensions that the Trustees have built into 

their proposed suspension plan of less than 1% of pre-suspension benefits. The Trustees have 

19.3.2
determined that this amount of reduction in the maximum suspension for the general population 

of affected participants is not large enough to justify the elimination of all the PPA adjustable 

benefits of terminated participants who have less than 20 years of Service Credit. 

19.3.3
Checklist No. 19 / Rev. Proc. § 5.02(1)(d):

Any prior suspensions under § 432(e)(9). 

 The Central States Pension Fund has had no prior suspension under § 432(e)(9). 

19.4.1
Checklist #19 / Rev. Proc. § 5.02(1)(e): 

Measures undertaken to retain or attract Contributing Employers. 

1. One of the measures taken by the Trustees to retain Contributing Employers was 

to place “caps” on the contribution increases required under the rehabilitation plan. See Findings 

and Determinations, ¶¶ II.B. 5-6. That is, the caps were set on the basis of advice received from 

an expert financial consultant at a level judged to be reasonable in light of the Contributing 

Employer’s financial condition. Therefore, the caps on contribution rate increases were designed 

to assure that Employers contribute to the Fund at a level that is as high as possible without 

creating unreasonable risks of increased employer attrition.

2. In addition, in October 2011, the PBGC approved an application submitted by the 

Fund for approval of the use of an alternative method of determining Employer withdrawal 

liability.

3. Under this alternative method, a current Contributing Employer can effectively 

limit its future exposure to withdrawal liability by paying liability in a lump sum and then 

continuing to contribute to the Fund as a “New Employer”. 

4. An Employer that is not currently contributing to the Fund, and does not owe any 

outstanding withdrawal liability or other obligations to the Fund, can also qualify as a New 

Employer and become eligible for the alternative withdrawal liability method. 

5. Under this alternative (or “hybrid”) method approved by the PBGC, the New 

Employers’ withdrawal liability is to be determined based on the benefits accrued by each New 

Employer’s employees, plus a proportionate share of any underfunding that develops among the 

New Employers as a whole (the “New Employer Pool”). However, because the New Employer 

Pool is fully funded (in fact it is approximately 200% funded), and current contribution rates are 

19.5.1
more than sufficient to fund current benefits, the New Employers have a very low risk of 

incurring liability in the future.

6. The hybrid method helps to retain existing Employers and to attract new 

Contributing Employers because it offers a means of relieving concerns about potential growth 

in exposure to withdrawal liability. Further, the Fund will not enter an agreement resolving a 

Contributing Employer’s withdrawal liability and deeming the Employer to be a New Employer 

under the hybrid method unless the Employer commits to continue to contribute to the Fund for 

an extended period (usually 5-10 years) and at a guaranteed level of participation. 

7. Approximately 80 Employers have qualified as New Employers under the hybrid 

method to date and these Employers have paid approximately $130 million in withdrawal 

liability, while continuing to contribute to the Fund. 

19.5.2
Checklist No. 19 / Rev. Proc. § 5.02(2):

Impact on the Fund’s solvency of subsidized and ancillary benefits available to active 

participants.

1. The Fund has for some time offered benefits that include early retirement 

subsidies e.g., “25-and-out” and “30-and-out” Contributory Service Credit Pensions. 

2. As part of the benefit modification that became effective on January 1, 2004 (see

Findings and Determinations ¶ III.C.), the Trustees have acted to limit the cost of subsidized 

early retirement benefits, but there are still retired Fund participants in pay status who are 

receiving some subsidized early retirement benefits.

3. The Fund’s actuary has estimated that as of January 1, 2015 approximately 3% of 

the Fund’s total actuarial accrued liability of $35.1 billion is comprised of subsidized early 

retirement benefits accrued by currently active participants. 

4. Therefore, the impact on the Fund’s solvency of subsidies and ancillary benefits 

accrued by currently active participants is relatively minor, compared to the more pronounced 

impact of the early retirement subsidized benefits that are currently being paid to participants 

who have already retired and are in pay status; the Fund’s actuary estimates that as of January 1, 

2015, the latter benefits comprised approximately 16% of the Fund’s total actuarial accrued 

liability of $35.1 billion. 

19.6.1
Checklist No. 19 / Rev. Proc. § 5.02(3):

Compensation levels of active participants relative to employees in the participants’ industries 

generally. 

1. A June 10, 2015 News Release by the Bureau of Labor Statistics (“BLS”) entitled

Employer Costs for Employee Compensation (p. 22) reports that in the unionized sector of the 

“service producing industries,” which include transportation and warehousing -- industries in 

which a high percentage of the Fund’s active participants are engaged -- an average of $4.23 per 

hour of total employee compensation (or 9% of total compensation) is absorbed by retirement 

benefits. On the other hand, this same BLS study indicates that the non-unionized sector of the 

service producing industries have retirement benefit costs of $0.93 per hour (3.2% of total 

compensation). Further, although the average union employee (across all industries) enjoys 

higher wages than comparable non-union workers, in recent years non-union wages have grown 

more rapidly than union wages. See George L. Long, “Differences Between Union and NonUnion Compensation,” Monthly Labor Review (April 2013) (between 2001 and 2011 non-union 

wages grew at a rate of 28% faster than union wages). Based on this information, it appears 

likely that pension costs in the unionized sector of the economy as a whole are acting as a drag 

on wage growth in that sector. 

2. The discrepancy between the unionized and non-unionized pension costs and the 

problems created by that discrepancy are even more pronounced in the case of the Central States 

Pension Fund. For example, the Fund currently has 4,000 active participants who are working 

under the NMFA (or under contracts that mirror the NMFA wage rates and benefits). Over the 

last ten years, pension contributions under the NMFA have increased by approximately 69%, 

(after inflation) while wages under that labor agreement have been relatively stagnant. As a 

result, today NMFA Employers pay an average of approximately $17,500 per year in pension 

contributions for each bargaining unit employee; yet the average annual wage paid to NMFA 

19.7.1
employees is less than $50,000. This contrasts with the non-union trucking industry in which 

annual pension costs average between $1,000 and $3,000 per employee. 

3. As indicated above, the retirement benefit costs in the unionized sector of the 

service industries generally are significantly higher than in the non-unionized sector of those 

industries ($4.23 per hour for unionized retirement benefits, as opposed to $0.93 for nonunionized). Moreover, as is also discussed above, this discrepancy is even more pronounced in 

the case of the Fund: Fund participants working under the NMFA have pension contributions 

made on their behalf at the rate of approximately $10 per hour, which on average is more than 

20% of their total compensation. 

4. his large allotment of total compensation to retiree benefits naturally tends to 

suppress wage growth for the Fund’s participants, thus intensifying for them the impact of the 

general trend discussed above towards more rapid wage growth among non-unionized workers 

than unionized workers. 

5. At the same time that the Fund participants were being asked to sacrifice larger 

portions of their total compensation to fund pension contributions, they were experiencing 

reductions in the amount of pension benefit accruals they could expect to yield for every dollar 

contributed on their behalf. This decline in the participants’ benefit accruals on a per contribution 

dollar basis was due to the reduction (from 2% to 1%) in their accrual rates, and the other benefit 

modifications that the Trustees instituted in 2004. 

6. Due to these trends and the desire of many workers to augment their wages rather 

than to see increasing amounts of their total compensation dedicated to pension contributions 

particularly when approximately $0.50 of each dollar contributed to the Fund must be dedicated 

to paying unfunded pension obligations, the Trustees have determined (based on their experience 

with current trends in hiring and the preferences of the various bargaining units that participate in 

19.7.2
the Fund) that mandatory additional contribution rate increases beyond those already scheduled 

and the increases incorporated into the proposed suspension plan would be likely to (a) cause a 

net decline in support for the Fund among active participants and (b) to make it more difficult for 

Contributing Employers to attract and retain qualified employees. These consequences, in turn, 

will lead to more Employer withdrawals and to a decline in contribution revenue for the Fund. 

19.7.3
Checklist No. 19 / Rev. Proc. § 5.02(4):

Competitive and other factors facing Contributing Employers. 

1. As part of the 2010 rehabilitation plan update process, in September 2010 the 

Central States Pension Fund engaged Stout Risius and Ross (“SRR”), a consulting firm with 

business valuation expertise, to study the ability of the Fund’s Contributing Employers to 

continue to absorb contribution rate increases. In November 2010, SRR reported to the Trustees 

that a number of the Fund’s larger, publicly traded Employers -- whose pension contribution 

rates already were (or soon would be) at $342 per week under the National Master Freight 

Agreement (“NMFA”) and $348 per week under the National Master Auto Transporter’s 

Agreement (“NMATA”) -- could not reasonably be expected to absorb additional contribution 

rate increases; accordingly, in November 2010, the Trustees approved an amendment to the 

rehabilitation plan that froze the top NMFA and NMATA rates indicated above. For other 

Employers, the $342 per week rate became the maximum rate necessary to be in compliance 

with the Primary Schedule without the need for additional rate increases. A copy of the SRR 

report from 2010 is attached as Tab A. 

2. On average, since 2010, approximately 8,200 active participants of the Fund have 

worked under the NMFA or NMATA (or agreements that follow the pension’s rates established 

under those agreements) or approximately 15% of total actives. The average non-frozen rate paid 

during the 2010-2014 period was approximately $ 220 per week (exclusive of the Distress 

Employer Contribution rate paid by YRC). 

3. In July 2015, SRR provided an update to its 2010 study and was asked its opinion 

concerning the reasonableness of the following proposed contribution rates increases for the 

employers listed below:

19.8.1
[*] An NMFA Employer currently subject to the “cap” of $342 per week placed on NMFA 

contribution rate increases. 

[**] An Employer currently subject to the Distress Employer Schedule (which does not require 

contribution increases). 

4. In its July 2015 report SRR concluded, on the basis of information available 

concerning the Employers listed above, that it is reasonable to expect those entities to sustain the 

indicated contribution rate increases, with the exception of the increases shown for YRC 

beginning in 2019. However, with respect to YRC, SRR also noted that -- because SRR based its 

conclusion solely upon the financial statements of the publically traded Employers it was asked 

to analyze its July 2015 report -- its report did not take account of any potential ability of YRC to 

absorb the proposed pension contribution rate increases by means of reducing other costs (e.g.,

Proposed Change in Contribution Rates

Employer Name 2015 2016 2017 2018 2019 

ArcBest Corporation [*] 0.0% 0.0% 0.0% 2.5% 2.5% 

YRC Worldwide, Inc. [**] 0.0% 0.0% 0.0% 0.0% 2.5% 

Grupo Bimbo, S.A.B. de C.V, 4.0% 4.0% 4.0% 4.0% 4.0% 

The Kroger Co. 4.0% 4.0% 4.0% 4.0% 4.0% 

SpartanNash Company 4.0% 4.0% 4.0% 4.0% 4.0% 

Dean Foods Company 4.0% 4.0% 4.0% 4.0% 4.0% 

Deutsche Post AG

 Air Express International USA Inc. 4.0% 4.0% 4.0% 4.0% 4.0% 

 DHL Express, Inc. 0.0% 0.0% 0.0% 2.5% 2.5% 

 Standard Forwarding LLC 8.0% 8.0% 8.0% 6.0% 4.0% 

SuperValu, Inc. 4.0% 4.0% 4.0% 4.0% 4.0% 

Roundy’s, Inc. 4.0% 4.0% 4.0% 4.0% 4.0% 

Kellogg Company 4.0% 4.0% 4.0% 4.0% 4.0% 

Associated Wholesale Grocers, Inc. 6.0% 4.0% 4.0% 4.0% 3.5% 

19.8.2
health coverage costs) in the collective bargaining process or through other negotiations. A copy 

of the SRR report from 2015 is attached as Tab B. 

5. Accordingly, the Trustees have determined to accept the recommendations and 

conclusions of SRR, except that the Trustees concluded that YRC will likely have the ability to 

absorb the rate increase shown above by means of reducing other costs in collective bargaining 

or through other negotiations. Therefore the Trustees have determined, on the basis of 

information currently available, that the future rate increases referenced above, including the 

increase in 2019 of 2.5% for YRC, are reasonable. Further, the Trustees have determined that for 

Employers currently subject to the $342 and $348 weekly rates and YRC (whose contribution 

rates are presently frozen), the proposed suspension plan will contain additional compounded 

annual contribution rate increases of 2.5% subsequent to 2018 (2019 in the case of YRC) until 

2028, at which point those employers whose contribution rates are currently frozen will increase 

their contributions at the compounded annual rate of 3.0%indefinitely. In addition, the Trustees 

have determined that under the suspension plan, these same “capped” rate increases will apply to 

those Employers whose rates are currently below the rehabilitation plan maximum rates of $342 

and $348 per week. 

6. Further, the Trustees have been mindful that if they set contribution requirements 

at a level that is too high for the Fund’s Contributing Employers to sustain, irreparable harm to

the Employers could result (e.g., business failures, liquidations and bankruptcies). This would, in 

turn, cause a permanent disruption of the stream of contribution revenue on which the Fund 

relies.

19.8.3
7. Although the SRR studies have focused on relatively large, publicly traded 

Contributing Employers, the Fund’s smaller Contributing Employers do not appear to be any 

more capable of absorbing unstrained contribution rate increases. 

8. For example, between 2010 and 2014 the Fund experienced a total of 

approximately 260 involuntary withdrawals resulting from Contributing Employer bankruptcies. 

Ninety-eight percent of the 2010 – 2014 Employer bankruptcies involved Employers with fewer 

than 50 active Pension Fund participants on a full-time equivalent (“FTE”) basis prior to the 

contribution withdrawals, while 92% of the Fund’s total Employer population employed on 

average 50 or fewer active participants during the same period. 

9. These figures indicate that the Funds’ smaller Contributing Employers are under 

the same level of financial stress as the larger Employers (and perhaps a slightly higher level of 

stress given that the small Employers experienced 98% of the Employer bankruptcies between 

2010 and 2014, but comprised only 92% of the total Employer population). 

10. Nevertheless, the Trustees have mandated substantial contribution increases in the 

past, and they have concluded that it would be reasonable to expect Employers to be able to 

sustain certain additional future contribution rate increases, and included those increases in their 

proposed suspension plan. 

11. It should be noted in 1980 there were approximately 12,000 Employers that 

contributed to the Fund but in July 2015 there were approximately 1,800 Contributing 

Employers.

12. The Trustees believe that contribution rate increases required of Contributing 

Employers in the past have was a factor in the loss of Contributing Employers. 

19.8.4
13. For example, Hostess Brands, Inc., a former Contributing Employer that 

employed approximately 2,800 Fund participants prior to its shutdown in 2012, failed to pay any 

of the pension contribution obligations it had accrued during July 2011. This created a 

delinquency of approximately $1.9 million owed by Hostess to the Pension Fund, and the 

company informed the Fund in August of 2011 that it was experiencing severe financial 

difficulties and would not be making any further contributions to the Pension Fund until it 

implemented a planned overall debt restructuring. Hostess claimed that one of the principal 

causes of its financial distress was the amount of pension contributions it owed each month to 

various multiemployer pension plans, with the Pension Fund at or near the top of the list of plans 

that Hostess believed was dragging it down. Hostess incurred a total contribution delinquency of 

approximately $6 million to the Pension Fund in 2011 before the Trustees determined that 

Hostess’ participation in the Fund should be terminated in November 2011. In early 2012, 

Hostess then filed bankruptcy, and subsequently ceased all operations and began liquidating its 

assets. 

14. Similarly, Allied Automotive Group (“Allied”), another Contributing Employer, 

entered bankruptcy in 2012, and claimed that its pension contribution obligations contributed 

significantly to its financial problems. Allied employed approximately 600 active participants 

prior to its bankruptcy. Like Hostess, Allied is undergoing a liquidation of its assets, and in both 

these bankruptcies the liquidations are expected to yield little or no payment on the Fund’s 

claims for withdrawal liability (withdraw liability assessments of approximately $584 million in 

the case of Hostess and approximately $968 million in the case of Allied). 

15. More broadly, deregulation of the trucking industry, which began in 1980, 

prompted a sharp decline in all segments of the unionized trucking industry, and exposed 

19.8.5
trucking Employers to intense rate and route competition. This enabled non-union trucking 

Employers that pay lower wages and have lower pension and health costs to flourish at the 

expense of the unionized trucking industry. 

16. As noted in IRS publication entitled “Trucking Industry Overview” (MSB 04-

1107-075) (www.irs.gov/Business/Trucking-industry-overview-history-of-trucking):

In the decade after deregulation [resulting from the Motor 

Carrier Act of 1980] the competition in trucking was fierce. 

There were not only hundreds of new companies, but also the 

formerly gentlemanly manner in which the big players dealt 

with each other became a battle to the death. Ten years after 

trucking was deregulated, one third of the 100 largest trucking 

companies were out of business, casualties of the fierce 

competition.

It became increasingly difficult for the trucking companies to 

operate with union drivers. Their compensation is usually 35 

percent more than non-union drivers. To reduce operating costs, 

new corporations were formed to operate with non-union 

drivers or independent contractors. 

19 Further, deregulation has intensified competition for qualified drivers, with many 

drivers (particularly those who are younger) attracted to non-union carriers where -- even if the 

total compensation is less than in the unionized sector -- they can receive a larger percentage of 

their total compensation in the form of cash wages. At the same time, as explained above, the 

Fund’s participants have seen increasing percentages of their total compensation devoted to 

pension contributions, while at the same time their actual pension accruals, measured on a 

percentage of contributions basis, have decreased significantly. 

20 Therefore, although growth in the Fund’s contribution requirements has been a 

factor in the loss of some Contributing Employers, more broadly deregulation has exposed 

Contributing Employers to competition from employers with lower pension costs. This has been 

significant cause of the decline in the number of Contributing Employers. As indicated above, 

19.8.6
the Trustees have employed expert financial advisors to help assure that the mandated 

contribution rate increases are at the highest level that is reasonable and sustainable. 

19.8.7
Tab A 

19.8.8
19.8.9
19.8.10
19.8.11
19.8.12
19.8.13
19.8.14
19.8.15
19.8.16
19.8.17
19.8.18
19.8.19
19.8.20
19.8.21
19.8.22
19.8.23
19.8.24
19.8.25
19.8.26
19.8.27
19.8.28
19.8.29
19.8.30
19.8.31
19.8.32
19.8.33
19.8.34
19.8.35
19.8.36
19.8.37
19.8.38
19.8.39
19 8.40
19.8.41
19.8.42
19.8.43
19.8.44
19.8.45
19.8.46
19.8.47
19.8.48
19.8.49
19.8.50
19.8.51
19.8.52
19.8.53
19.8.54
19.8.55
19.8.56
19.8.57
19.8.58
19.8.59
19.8.60
19.8.61
19.8.62
19.8.63
19.8.64
19.8.65
19.8.66
19.8.67
19.8.68
19.8.69
19.8 70
19.8.71
19.8.72
19.8.73
19.8.74
19.8.75
19.8.76
19.8.77
19.8.78
19.8.79
19.8.80
19.8.81
19.8.82
19.8.83
19.8.84
19.8.85
19.8.86
19.8.87
19.8.88
19.8.89
19.8.90
19.8.91
19.8.92
19.8.93
19.8.94
19.8.95
19.8.96
19.8.97
19.8.98
19.8.99
19.8.100
19.8.101
19.8.102
19.8.103
19.8.104
19.8.105
19.8.106
19.8.107
19.8.108
19.8.109
19.8.110
19.8.111
19.8.112
19.8.113
19.8.114
19.8.115
19.8.116
19.8.117
19.8.118
19.8.119
19.8.120
19.8.121
19.8.122
19.8.123
19.8.124
19.8.125
19.8.126
19.8.127
19.8.128
19.8.129
19.8.130
19.8.131
19.8.132
19.8.133
19.8.134
19.8.135
19.8.136
19.8.137
19.8.138
19.8.139
19.8.140
19.8.141
19 8.142
19.8.143
19.8.144
19.8.145
19.8.146
19.8.147
19 8.148
19.8.149
19.8.150
19.8.151
19.8.152
19.8.153
19 8 154
19.8.155
19.8.156
19.8.157

19.8.159
19.8.160
19.8.161
19.8.162
19.8.163
Tab B 

19.8.164
 

PRESENTATION TO 

THE CENTRAL STATES PENSION FUND

Issued: July 7, 2015

19.8.165
[This page is intentionally left blank.]

19.8.166
For more information, please contact one of the following members of the engagement team: 

 Scott D. Levine, CPA/ABV, CFA 

Managing Director 

(703) 848-4948 

slevine@srr.com 

Joseph D. Demetrius, CFA 

Vice President 

(703) 848-4956 

jdemetrius@srr.com 

Cara M. Davis 

Analyst 

(703) 891-4313 

cdavis@srr.com 

Atlanta | Baltimore | Chicago | Cleveland | Dallas | Denver | Detroit | Houston | Los Angeles | New York | Washington, D.C.

www.srr.com 

19.8.167
























































































































































Redacted by U.S. Treasury Department