o

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ab

c Steven

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. 

Secretary of the Treasuw

Departrlent of flre 'l'r'easury

1.500 Pennsyh,ania Ave., NW

Washington, D.C.20220

Re: Ap¡rlicafion for Approval of the Suspension of ßeneäts uneler the Westem Sfates

Oflìce and P¡'ofessio¡ral Ðurployees llension Fund

Dear Secretary Mnuchin:

As anthorized Trustees of tùe Roard of Trustees tbr the Westenr States OfÏce ancl Protèssional

Employees Pension Fund ("Plar"), the Plan sponsor. we respectlìrily submrt this application for

approval of a proposed suspensiol of benefits pursuarf to Section 432(eX9) ol ihe IntemalRevenue Co<te of 1986, as arnended, antl Secrtiou 305{eXq) of the Employee Retirerirent income

Securíty Act of 1974, as amenclecl.Respectfully Submitted.

l\'fich.ael I'armelee. Suz¿nne Nlode, Co-Chair

Authorized Trustee on behalf of the Board of Authorized 1'rustee on behalf of the lloard of

Truste€s fi¡r the Westem States Office ancl Trustees ibr the Weslern States Ofïice andProfessional Ernployees Pension Fund Profçssional Employees Pensiou Fund

Administoretl by BeneSys, Inc.

12ã) SW Momlçon St. SuÍte 3()o. Portland OR W2$5-2222

$aq222:7694 {8tr) 413-492E Fax (503} 22&lJT49

httpl/www.wsp.aibpa.com

Redacted by the U.S. Department of the Treasury
The Honorable Steven T. Mnuchin

Secretary of the Treasury

Department of the Treasury

1500 Pennsylvania Ave., N'W

Washington, D.C. 24220Re: Application for Approval of the Suspension of Benefüts under the Western States

Office and Professional Employees Pension Fund

Dear Secretary Mnuchin:As authorized Trustees of the Board of Trustees for the Western States Office and ProfessionalEmployees Pension Fund ("Plan"), the Plan sponsor, we respectfully submit this application forapproval of a proposed suspension of benefits pursuant to Section 432@)(9) of the Internal

Revenue Code of 1986, as amended, and Section 305(eX9) of the Employee Retirement Income

Security Act of 1974, as amended.

Respectfully Submitted:Michael Parmelee, Co-ChairAuthorized Trustee on behalf of the Board of

Trustees for the Western States Office andProfessional Employees Pension Fund

the Western States Ofhce and

Employees Pension Fund

Suzanne

AuthorizedTrustees for

Professional

Administered by BeneSys, Inc.

L220 SW Morrison St, Suite 30O Portland.OR 87205-2222

(503)222-76e4 (800)413-4928 Fax (503) 228-0149

http //www.wsp.aibpa. com

Redacted by the U.S. Department of the Treasury
Appendix A: Page 1 of 6

WESTERN STATES OFFICE AND 

PROFESSIONAL EMPLOYEES PENSION FUND

SECOND SUSPENSION APPLICATION

Appendix A
Appendix A: Page 2 of 6

SECOND APPLICATION FOR APPROVAL OF BENEFIT

SUSPENSION FOR THE 

WESTERN STATES OFFICE AND PROFESSIONAL 

EMPLOYEES PENSION FUND

CHECKLIST

Response

Item 

number Description of item

Page number

in application

Yes

No

N/A

1. Does the application include an original signature of the plan sponsor or

an authorized representative of the plan sponsor? See section 2.01.

Cover Letter

Yes

No

N/A

2. Does the application include a description of the proposed benefit

suspension - calculated as if no other limitations apply - that includes:

 the suspension’s effective date (and its expiration date, if

applicable),

 whether the suspension provides for different treatment of

participants and beneficiaries,

 a description of the different categories or groups of individuals

affected, and

 how the suspension affects these individuals differently?

See section 2.02.

4

Yes

No

N/A

3. Does the application include a penalties-of-perjury statement signed by

an authorized trustee on behalf of the board of trustees? See Section

2.03.

4 and

Exhibit 1

Yes

No

N/A

4. Does the application include a statement, signed by an authorized trustee

on behalf of the board of trustees, acknowledging that the application and

the application’s supporting material will be publicly disclosed on the

Treasury Department’s website? See section 2.04.

4 and

Exhibit 1

Yes

No

N/A

5. Does the application include the plan actuary’s certification of critical and

declining status and the supporting illustrations, including:

 the plan-year-by-plan-year projections demonstrating projected

insolvency during the relevant period, and

 separately identifying the available resources (and the market value

of assets and changes in cash flow) during each of those years?

See section 3.01.

6 and

Exhibit 2

Yes

No

N/A

6. Does the application describe the assumptions used, including the new

entrant profile, the total contribution base units, and the average

contribution rates? See section 3.01.

6 and

Exhibit 2

Yes

No

N/A

7. Does the application include the plan actuary’s certification that the plan

is projected to avoid insolvency if the suspension takes effect and the

supporting illustrations, including:

 the plan-year-by-plan-year projections demonstrating projected

solvency during the relevant period,

 a description of the assumptions used, including the new entrant

profile, the total contribution base units, and the average contribution

rates, and

 separately identifying the available resources (and the market value

of assets and changes in cash flow) during each of those years?

See section 3.02.

6 and

Exhibit 3

Yes

No

N/A

8. Does the application include the plan sponsor’s determination of 

projected insolvency that includes the documentation set forth in section

5 of the revenue procedure? See section 3.03.

6-10
Western States Office and Professional Employees Pension Fund

Appendix A: Page 3 of 6

Response

Item 

number Description of item

Page number

in application

Yes

No

N/A

9. Does the application include a demonstration that the limitations on

individual suspensions are satisfied, including calculations regarding:

 the guarantee-based limitation,

 the disability-based limitation, and

 the age-based limitation?

See section 4.01.

11 and 

Exhibit 4

Yes

No

N/A

10. Does the application include a demonstration that the proposed

suspension is reasonably estimated to achieve the level necessary to

avoid insolvency for the extended period, including illustrations regarding

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

11 and

Exhibit 5

Yes

No

N/A

11. Does the application include the required illustration utilizing stochastic

projections? (This illustration is not required if the plan is not required to

appoint a retiree representative under § 432(e)(9)(B)(v)(I) and stochastic

projections were not used in making the required determination.) See

section 4.02(2).

N/A

Yes

No

N/A

12. Does the application include a demonstration that the proposed

suspension is not projected to materially exceed the level necessary to

avoid insolvency, including illustrations regarding the plan’s solvency ratio

and available resources? See section 4.03.

11 and

Exhibit 6

Yes

No

N/A

13. Does the application include a demonstration that the proposed

suspension is equitably distributed, including:

 information on the effect of the suspension on the plan in the

aggregate,

 information on the effect of the suspension for different categories or

groups,

 a list of the factors taken into account,

 an explanation of why none of the factors listed in § 432(e)(9)(D)(vi) 

were taken into account (if applicable),

 for each factor taken into account that is not one of the factors listed 

in § 432(e)(9)(D)(vi), an explanation why the factor is relevant, and

 how any difference in treatment among categories or groups of

individuals results from a reasonable application of the relevant 

factors?

See section 4.04.

11-12

Yes

No

N/A

14. Does the application include a copy of the notices (excluding personally

identifiable information) that meet the requirements under § 432(e)(9)(F)?

See section 4.05(1).

12-13 and

Appendix B

Yes

No

N/A

15. Does the application include a description of the efforts that are being

taken to contact participants, beneficiaries in pay status, and alternate

payees? See section 4.05(2).

13

Yes

No

N/A

16. Does the application describe the steps the plan sponsor has taken to

ensure that notices delivered electronically are reasonably accessible to

the recipients? See section 4.05(3) 

The Pension Plan will only be mailing the Notice of Application and 

Individual Benefit Estimates via USPS First Class Mail.

N/A

Yes

No

N/A

17. Does the application include a list of each employer who has an

obligation to contribute under the Plan and each employee organization

representing participants under the Plan? See section 4.05(4).

14-19

Yes

No

N/A

18. Does the application include information on past and current measures

taken to avoid insolvency? See section 5.01.

6-10, 20
Western States Office and Professional Employees Pension Fund

Appendix A: Page 4 of 6

Response

Item 

number Description of item

Page number

in application

Yes

No

N/A

19. Does the application include the plan information required by section

5.02?

6-10, 20

Yes

No

N/A

20. Does the application describe how the plan sponsor took into account –

or did not take into account – the factors listed in section 5.02 in the

determination that all reasonable measures were taken to avoid

insolvency? See section 5.03.

6-10, 20

Yes

No

N/A

21. Does the application describe how the plan sponsor took into account - or

did not take into account - in the determination that all reasonable

measures have been taken to avoid insolvency the impact of:

 benefit and contribution levels on retaining active participants and

bargaining groups under the plan, and

 past and anticipated contribution increases under the plan on 

employer attrition and retention levels?

See section 5.03.

6-10, 20

Yes

No

N/A

22. Does the application include a discussion of any other factors the plan

sponsor took into account including how and why those factors were

taken into account? See section 5.04.

6-10, 20

Yes

No

N/A

23. Does the application include a copy of the proposed ballot, excluding the

information regarding the statement in opposition, the individualized

estimate, and the voting procedures? See section 6.01.

21 and

Exhibit 7

Yes

No

N/A

24. Does the application indicate whether the plan sponsor is requesting

approval from PBGC of a proposed partition under section 4233 of

ERISA? See section 6.02.

21

Yes

No

N/A

25. If the answer to item 24 is yes, does the application specify the effective

date of the proposed partition and include a plan-year-by-plan-year

projection of the amount of the reduction in benefit payments attributable

to the partition? See section 6.02.

The Plan is not requesting a partition.

N/A

Yes

No

N/A

26. Does the application describe the plan’s experience with certain critical

assumptions, including a disclosure for each of the 10 plan years

immediately preceding the application that separately identifies:

 total contributions,

 total contribution base units,

 average contribution rates,

 withdrawal liability payments, and

 the rate of return on plan assets?

See section 6.03.

21 and

Exhibit 8

Yes

No

N/A

27. Does the application include deterministic projections of the sensitivity of

the plan’s solvency ratio throughout the extended period by taking into

account the more conservative assumptions of investment experience

and future contribution base units than assumed elsewhere in the

application? See section 6.04.

21 and 

Exhibit 9

Yes

No

N/A

28. Does the plan include deterministic projections for each year in the

extended period of:

 the value of plan assets,

 the plan’s accrued liability, and

 the plan’s funded percentage? 

See section 6.05.

21 and 

Exhibit 10
Western States Office and Professional Employees Pension Fund

Appendix A: Page 5 of 6

Response

Item 

number Description of item

Page number

in application

Yes

No

N/A

29. Does the application include the plan sponsor’s representation that, if it

receives the Treasury Department’s final authorization to suspend and

then chooses to implement the suspension, it will also amend the plan:

 to indicate that the suspension will cease upon the plan sponsor’s 

failure to determine that both all reasonable measures continue to 

be taken to avoid insolvency and that the plan would not be 

projected to avoid insolvency without a suspension,

 to require that any future benefit improvements must satisfy §

432(e)(9)(E), and

 to specify that the plan sponsor will not modify these amendments,

notwithstanding any other provision of the plan document?

See section 6.06.

21 and

Exhibit 11

Yes

No

N/A

30. Does the application indicate whether the plan is a plan described in

§ 432(e)(9)(D)(vii) and, if so, how is that fact reflected in the proposed

benefit suspension? See section 6.07.

22

Yes

No

N/A

31. Does the application include the required plan sponsor information,

including

 name

 address

 telephone number

 email address

 fax number

 employer identification number (EIN) and

 3-digit plan number (PN)? 

See section 7.01.

23

Yes

No

N/A

32. Does the application include the required plan identification information?

See section 7.02.

23

Yes

No

N/A

33. Does the application include the required retiree representative

information (if applicable)? See section 7.03.

The Plan is not required to have a retiree representative.

23

Yes

No

N/A

34. Does the application include the required enrolled actuary information?

See section 7.04.

23 and

Exhibit 12

Yes

No

N/A

35. Does the application include a designation of power of attorney for each

authorized representative who will represent the plan sponsor in

connection with the application? See section 7.05 and Appendix B.

23 and 

Exhibit 13

Yes

No

N/A

36. Does the application include:

 the required plan documents,

 any recent amendments,

 the summary plan description (SPD),

 the summary of material modifications, and

 the most recent determination letter?

See section 7.06.

23 and 

Exhibit 14

Yes

No

N/A

37. Does the application include the required excerpts from the relevant

collective bargaining agreements and side agreements? See section

7.07.

23 and

Exhibit 15

Yes

No

N/A

38. Does the application include the required excerpts from the most recently

filed Form 5500? See section 7.08.

23 and

Exhibit 16
MichãêÌ Pafmelee, Co-Chair Suzanne Mode, Co-Chair

Authorized Trustee on behalf of the Board of Authorized Truslse on bel'ìaif of the Board of

Trustees for the We$tern State$ Otfice and Trusteos for the We$tern States Off¡ce and

Professional Employees Pension Fund Profess¡onål Ëmployees Pension Fund

-f-a*-?:{ry Dûte ftat€

Àppendix A; Page 6 of6

rfl

l!¿a

reports for the pfân? See seclion 7.'10

[xhibil 18

.',. \ Yes jirlö**

N/A

UUeS Ule dpfl,lldil9fl ll¡ÇlUuts lllls ClìcLÁ¡151, UU'lìplcreu dllu pl4WU Ull ¡Up

of the ãpplication? See section 7.1 1 .

zc a|Q

Appendix A

Yes

ÀÂ* wn)

42 lf the applicâtion ¡s being submitted for resubmission rcview, does the

applicat¡qn ¡nclude,. I statement ihat the Ëpptication ¡s bEing Bubm¡tted for resubmission

rev¡ew. and

¡ the date on which the Tressury DèpartÍlent gâve approva{ to submil

an application for resubmission review?

See secl¡on 8^ïhis is an orig¡nál subm¡s3ion (Second Appl¡çation).

N/A
N/A

p

p

tr2

NiA

41. Does the application include this checklist, completed and placed on top

of the application? See section 7.11.

23 and

Appendix A

Yes b 42. lf the application is being submitted for resubmission review, does the application include: ¡ a statement that the application is being submitted for resubmission review, and

r the date on which the Treasury Department gave approval to submit

an applicalion for resubmission review?

See section L

This is an original submission (Second Application).

NIA

Michael Parmelee, Go-Chair

Authorized Trustee on behalf of the Board of

Trustees for the Western States Office and

Professional Employees Pension Fund

Date

Suzanne

Authorized T on behalf of Board of

Trustees for the Western States

Professional Employees Pension Fund

Office and

Appendix A: Page 6 of 6 Redacted by the U.S. Department of the Treasury