Page 1 of 24

Application for 

Approval of Suspension of Benefits 

for the 

Western States Office and Professional 

Employees Pension Fund 

Dated: February 15, 2017
Page 2 of 24

TABLE OF CONTENTS 

Page 

Section 1. Background and Purpose ................................................................................. 3

Section 2. Application Procedures ..................................................................................... 4

Section 3. Demonstration that the Plan is Eligible for Suspension ................................. 5

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements ..................................................................................10

Section 5. Plan Sponsor's Determination Relating to Reasonable Measures 

Taken to Avoid Insolvency ..............................................................................19

Section 6. Other Required Information ............................................................................20

Section 7. Identification and Background Information on the Plan ...............................22
Western States Office and Professional Employees Pension Fund 

Page 3 of 24

Section 1. Background and Purpose 

Pursuant to Internal Revenue Service Revenue Procedure 2016-27 and the Department of the Treasury's 

Proposed and Temporary regulations issued under Section 432(e)(9) of the Internal Revenue Code of 

1986 (the "Code") and published in the Federal Register on June 19, 2015 (collectively, the 

"Regulations"), the Board of Trustees (“Trustees”) of the Western States Office and Professional 

Employees Pension Fund (the "Plan") submits this application, and the accompanying Exhibits, to the 

Secretary of the Treasury for approval of suspension of benefits. 

Section 432(e)(9)(G) of the Code provides that the Secretary of the Treasury shall approve an application 

for the approval of suspension of benefits upon finding that the plan is eligible for the benefits suspension 

and has satisfied the criteria set forth in subparagraphs (C), (D), (E), and (F) of Section 432(e)(9) of the 

Code. As explained below, the Plan is eligible to suspend benefits and has satisfied each of the 

enumerated criteria under the Regulations. Therefore, the Plan respectfully requests that the Secretary 

approve this application to suspend benefits. 
Western States Office and Professional Employees Pension Fund 

Page 4 of 24

Section 2. Application Procedures 

.01 Plan Sponsor Submission 

The Board of Trustees of the Plan submits this application for approval of a proposed benefit 

suspension under Section 432(e)(9). This application is signed and dated by both a Union and an 

Employer Trustee, who are both authorized to sign and are current members of the Board of 

Trustees. 

.02 Terms of Plan's Proposed Benefit Suspension 

(1) Effective Date 

The Trustees propose an effective date for the benefit suspension which is as soon as is 

administratively practicable and when the Secretary issues final approval of the 

suspension (the "Effective Date"). The Trustees recognize that the Regulations require 

the proposed effective date of the suspension to be at least nine months after the date on 

which the application is submitted. For the purposes of the actuarial calculations, 

demonstrations and illustrations set forth in this application, the effective date for the 

Plan's proposed benefit suspensions has been set at December 1, 2017. 

(2) Expiration Date 

The proposed benefit suspension will remain in effect indefinitely and will not expire by its 

own terms. 

(3) The Proposed Suspension 

The Plan's proposed benefit suspension reduces all participants' benefits by 29% taking 

into account the limitations on benefit suspensions under the rules of Sections 

432(e)(9)(D)(i), (ii) and (iii). The proposed suspension will not treat categories or groups 

of participants and beneficiaries under the Plan differently from one another. 

In addition, the Board proposes to increase the future accrual rate for active participants 

from 0.75% to 1.0% of contributions effective January 1, 2018, contingent upon the 

approval of the proposed benefit suspensions. This increase in the accrual rate is 

intended to counteract the significant drop in the Plan’s benefit accrual rates over the 

past years and the increase will help level the burden of improving the Plan’s funding 

between current actives and inactive participants. The increase may also help retain 

employers and recruit new participants. 

.03 Penalties of Perjury Statement 

See Exhibit 1. 

.04 Public Disclosure Statement 

See Exhibit 1. 
Western States Office and Professional Employees Pension Fund 

Page 5 of 24

Section 3. Demonstration that the Plan is Eligible for Suspension 

.01 Plan Actuary's Certification of Critical and Declining Status 

See Exhibit 2 for a certification from the Plan's actuary required under Section 432(b)(3)(B)(iv) 

that the Plan is in critical and declining status for the Plan Year commencing January 1, 2016. 

Included with this certification is documentation supporting the actuarial certification of status, 

including a year-by-year projection of the Plan's available resources and the benefits under the 

Plan, demonstrating that the Plan is projected to become insolvent during the 2035 Plan Year. 

The documentation includes a description of each of the assumptions used, including the total 

contribution base units and average contribution rates. The year-by-year projection separately 

identifies the market value of assets as of the beginning and end of the 2016 Plan Year and the 

2035 Insolvency Year, and the following cash-flow items for those years: (1) contributions; (2) 

withdrawal liability payments; (3) benefit payments; (4) administrative expenses; and (5) 

investment returns. 

.02 Plan Actuary’s Certification that the Plan is Projected to Avoid Insolvency 

See Exhibit 3 for a certification from the Plan's actuary under Section 432(e)(9)(C)(i) that the 

Plan is projected to avoid insolvency within the meaning of Section 418E taking into account the 

proposed benefit suspension, and assuming that the proposed suspension continues indefinitely. 

Included with this certification is documentation supporting the certification, including a list of 

assumptions, year-by-year projection of the available resources of the Plan within the meaning of 

Section 418E(b)(3) and the benefits under the Plan demonstrating the avoidance of insolvency of 

the Plan through the extended period of 40 Plan Years, which would be the 2055 Plan Year. The 

documentation includes a description of each of the assumptions used, including the total 

contribution base units (hours) and average contribution rates. Also included with this certification 

is the Plan's year-by-year projection that separately identifies the market value of assets as of the 

beginning and end of each year in the extended period and the following cash-flow items for each 

of those years: (1) contributions; (2) withdrawal liability payments; (3) benefit payments; (4) 

administrative expenses; and (5) investment returns. 

.03 Plan Sponsor's Determination of Projected Insolvency 

It is the Trustees' determination under Section 432(e)(9)(C)(ii) that the Plan is projected to 

become insolvent, unless benefits are suspended as proposed in this application, even though all 

reasonable measures to avoid insolvency have been taken. The Plan has included 

documentation and Exhibits with this application illustrating the Trustees' determination of 

projected insolvency. 

 All measures taken to avoid insolvency over the past 10 years 

The Trustees' determination includes consideration of all measures taken to avoid 

insolvency over the past 10 plan years. These measures included reductions in accruals, 

various amendments to the Plan to modify or eliminate certain benefits and the adoption 

of a Rehabilitation Plan following passage of the Pension Protection Act of 2006. On 

March 31, 2009, the Plan was first certified by its actuary to be in "critical status," and the 

Trustees adopted a Rehabilitation Plan on October 16, 2009, effective January 1, 2010, 

which was amended and incorporated into the Plan document. 
Western States Office and Professional Employees Pension Fund 

Section 3. Demonstration that the Plan is Eligible for Suspension (Continued) 

Page 6 of 24

The initial Rehabilitation Plan made the following changes to the Plan effective January 1, 

2010: 

1. The benefit accrual level was reduced from 1.80% to 0.75% of contributions. 

2. The Normal Retirement Age was increased from age 62 to 65 for benefits earned 

on or after January 1, 2010. 

3. The Rule of 80 Retirement option was eliminated. 

4. Early Retirement subsidies for participants not yet in pay status were eliminated. 

5. Replaced the existing Disability Benefit and Alternative Disability Benefit not yet 

in pay status with a benefit equal to 50% of earned benefits payable to age 55. 

6. Optional forms of benefit were limited to a straight life annuity, joint and 50% 

survivor annuity and actuarially equivalent annuities. 

7. Pre-retirement Death Benefit for single participants changed from a 60-month 

guarantee to a lump sum benefit equal to $500 per year of service up to a 

maximum of $5,000. 

The Trustees, each year in consultation with the Plan's actuary, reviewed and updated

the Rehabilitation Plan to reflect the worsening condition of the Plan due in large part to 

employer withdrawals despite initially strong investment returns. After consideration, the 

Trustees updated the Rehabilitation Plan in 2010 to reflect a higher than assumed 

investment return and to extend the Rehabilitation Period from 13 years to 25 years. This 

change significantly lowered the annual growth rate and ultimate level of supplemental 

contributions needed to satisfy the requirements of a Rehabilitation Plan. 

The Trustees updated the Rehabilitation Plan again in 2012 to adopt a “forestall 

insolvency” Rehabilitation Plan and cap supplemental contributions at 80%. It was 

determined that the significant supplemental contributions were driving away current and 

potential new employers due to the financial hardship. The Trustees were also 

concerned about a potential mass withdrawal. 

Finally, the Trustees made changes to the Plan's withdrawal liability policy (moving from 

the Rolling-five allocation method to the Presumptive allocation method). This change 

was made to insulate potential new employers from legacy Unfunded Vested Benefit 

liability, thus reducing the risk / exposure that potential new employers would bear by 

joining an underfunded Plan under the prior withdrawal liability allocation method. 
Western States Office and Professional Employees Pension Fund 

Section 3. Demonstration that the Plan is Eligible for Suspension (Continued) 

Page 7 of 24

 Consideration of specific Plan factors 

The Trustees' determination under Section 432(e)(9)(C)(ii) also includes consideration of 

the following specified Plan factors over the past 10 years: 

o Contribution levels 

In developing the Rehabilitation Plan, the Trustees considered contribution 

levels, and the fact that additional contribution increases beyond those required 

likely would drive more contributing employers from the Plan, either through 

business failure or withdrawal. The Plan’s past 10 years of contributions are 

summarized in the chart below.

Contributions

Year Ending 

12/31

Base 

Contributions

Supplemental 

and Surcharge 

Contributions

Withdrawal 

Liability 

Payments

2006 $7,399,605 N/A N/A

2007 $7,678,247 N/A N/A

2008 $8,277,807 N/A N/A

2009 $7,842,903 $161,882 N/A

2010 $7,676,687 $812,322 N/A

2011 $7,297,989 $1,318,385 $6,012 

2012 $6,980,563 $1,879,073 $937,412 

2013 $6,485,023 $2,884,983 $1,674,335 

2014 $5,064,945 $3,776,471 $1,570,022 

2015 $4,883,040 $3,591,720 $3,337,192 

o Benefit accrual levels, including any prior reductions in the rate of benefit 

accruals 

The Plan drastically reduced benefit accrual levels from 3.65% of contributions 

prior to January 1, 1997 to 0.75% of contributions beginning January 1, 2010. 

The Trustees concluded, in consultation with the Plan's actuary, that any further 

reduction in the accrual rate beyond those contained in the Rehabilitation Plan 

would have had a detrimental effect on the Plan by undermining contributing 

employer's ability to attract and retain qualified employees. 

o Prior reductions of adjustable benefits under Section 432(e)(8) 

As noted above, under the Rehabilitation Plan the Rule of 80 Retirement option 

(early retirement) was eliminated, Early Retirement subsidies for participants not 

yet in pay status were eliminated, and optional forms of benefit were limited to a 

straight life annuity, joint and 50% survivor annuity and actuarial equivalent 

annuities. 
Western States Office and Professional Employees Pension Fund 

Section 3. Demonstration that the Plan is Eligible for Suspension (Continued) 

Page 8 of 24

o Prior benefit suspensions under Section 432(e)(9) 

The Plan has not implemented prior benefit suspensions under Section 

432(e)(9). 

o Measures taken to retain or attract contributing employers 

After the 2008 recession, many employers withdrew from the Plan due to a slow 

recovery in business. The Trustees received feedback from employers 

concerning the financial burden the significant supplemental contributions under 

the Rehabilitation Plan placed on them. In an effort to retain employers, the 

Board reduced the required supplemental contributions by reflecting higher than 

expected investment returns and extending the Rehabilitation period from 13 to 

25 years. Although this lowered the required contributions, the level of 

contributions was still too high for most employers, causing some of them to 

withdraw from the Plan. The Trustees ultimately capped the supplemental 

contributions at 80%. Over this time, the Trustees, with the assistance of the 

Plan's actuary, studied and implemented what they determined to be appropriate 

contribution level increases and benefit reductions in an effort to retain the 

contributing employers already in the Plan. 

The local unions and Trustees made a concerted effort to attract new employers. 

Together, they also worked to encourage current employers to remain in the 

Plan. To aid in that end, the Trustees changed the withdrawal liability allocation 

method from the Rolling–five method to the Presumptive method. This change 

insulates new employers from inheriting costs from legacy employers. Despite 

these efforts, the local unions participating in the Plan have not been successful 

in negotiating new employers into the Plan. 

o Impact on plan solvency of the subsidies and ancillary benefits, if any, available 

to active participants 

As noted, the Rehabilitation Plan eliminated all subsidies and ancillary benefits 

available to non-retired participants of the Plan. The Plan's solvency has been 

impacted almost entirely by the legacy costs of participants receiving accrued 

benefits or that retired prior to the Plan falling into critical status. 

o Compensation levels of active participants relative to employees in the 

Participant's same industry 

Not applicable to this Plan. 
Western States Office and Professional Employees Pension Fund 

Section 3. Demonstration that the Plan is Eligible for Suspension (Continued) 

Page 9 of 24

o Competitive and other economic factors facing contributing employers 

A variety of competitive and economic factors over the past 25-30 years have 

affected the Plan's contributing employers and directly impacted the Plan's 

finances. The Plan had over 500 contributing employers in the mid-1980’s which 

decreased to just over 400 employers by the late 1980’s and has been 

decreasing from approximately 350 employers since the late 1990’s. 

Consolidated Freightways was a significant contributing employer in the Plan 

until it went bankrupt in late 2002. This resulted in a substantial decrease in 

employer contributions to the Plan. 

Another significant employer, Northwest Natural Gas, joined the Plan in 2005 at a 

low contribution rate. The intent of bringing them into the Plan at a low rate was 

that their contribution rate would increase over time. Due to the market crash in 

2008, their contribution rate was never increased (other than the 5% and 10% 

surcharge) and they withdrew from the Plan at the end of 2013. 

There has been a steady decline in the number of the Plan's contributing 

employers and the Plan's financial condition since falling into critical status. Many 

of the Plan’s participants are office staff working for local unions. With the 

continued decline in union jobs, the need for office staff working at the local union 

offices has declined, resulting in job loss, consolidation/merger of unions, and 

other cost cutting. 

o Impact of benefit and contribution levels on retaining active participants and 

bargaining groups under the Plan 

As noted, decreases in benefit levels under the Plan would have drastically 

reduced employee and participant retention. The Plan's contributing employers 

have been unable to financially support or sustain any additional increase in 

contribution levels. 

o Impact of past and anticipated contribution increases under the Plan on employer 

attrition and retention levels 

As described above, the impact of past and anticipated contribution increases 

under the Plan have had a detrimental impact on employer attrition and retention 

levels. 
Western States Office and Professional Employees Pension Fund 

Page 10 of 24

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements 

.01 Demonstration that Limitations on Individual Suspensions are Satisfied 

See Exhibit 4 for a demonstration of how the proposed suspension satisfies the limitations 

described in Sections 432(e)(9)(D)(i), (ii) and (iii). The attached exhibit includes six separate 

illustrations required under this Section 4.01 of the Revenue Procedure including: (1) a sample 

calculation applying the 110 percent limitation under Section 432(e)(9)(D)(i) for the Plan's 

participants; (2) a sample calculation applying the age-based limitations of Section 

432(e)(9)(D)(ii); and (3) a sample calculation applying the disability limitation under Section 

432(e)(9)(D)(iii). 

.02 Demonstration that the Proposed Suspension is Reasonably Estimated to Enable the Plan to 

Avoid Insolvency 

See Exhibit 5 for a demonstration that, in accordance with Section 432(e)(9)(D)(iv), the proposed 

benefit suspension is reasonably estimated to enable the Plan to avoid insolvency. Please note 

that the Plan is not a plan described in Section 432(e)(9)(B)(v)(I) so it is not required to use 

stochastic projections in its illustrations demonstrating that it will avoid insolvency. 

.03 Demonstration that the Proposed Suspension is Reasonably Estimated to not Materially Exceed 

the Level Necessary to Avoid Insolvency 

See Exhibit 6 for a demonstration that, in accordance with Section 432(e)(9)(D)(iv), the proposed 

benefit suspension is reasonably estimated to not materially exceed the level necessary to enable 

the Plan to avoid insolvency. Specifically, the demonstration includes an illustration showing that, 

if the dollar amount of the Plan's proposed suspension for each participant and beneficiary were 

reduced by 2%, then the proposed suspension would not reasonably be estimated to enable the 

Plan to avoid insolvency. Since all participant benefits are reduced by 29%, subject to disability, 

age limitations and 110% of the PBGC guarantee, we reduced the proposed suspension by 2%, 

resulting in a 27% reduction (2% is greater than 5% of the proposed reduction). The available 

resources continue to decrease in the last five years of the extended projection period. 

.04 Demonstration that the Proposed Benefit Suspension is Distributed Equitably 

In accordance with Section 432(e)(9)(D)(vi), the proposed benefit suspension is distributed in an 

equitable manner across the Plan's participant and beneficiary population. As described in 

Section 2.02(3) of this application, the Plan's proposed benefit suspension is to reduce all 

participants' benefits by 29%. As such, this distributes the proposed benefit suspension equally 

across the Plan's population, and there is no category or group that is treated differently within 

the Plan's participant and beneficiary population. Although all of the factors listed in Section 

432(e)(9)(D)(vi)(I) through (XI) were considered, ultimately the Trustees decided to treat all 

participants equally in designing the Plan's proposed suspension. 
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 11 of 24

.05 Notice 

The following describes the Trustees' method for satisfying the notice requirements of Section 

432(e)(9)(F): 

 Individual Notices. 

See Appendix B for a copy of the sample Individual Notices that will be sent to all 

participants, beneficiaries and alternate payees under the Plan via USPS mail on 

February 15, 2017, the same day the Application is filed. A copy of the Notice will also 

be mailed to all contributing employers and employee organizations representing Plan 

participants but without the personalized estimate. 

The Notice of Application was prepared based on the Model Notice provided in Revenue 

Procedure 2016-27. In addition, the Trustees have prepared 12 separate Individual 

Estimate formats covering the following groups of participants: 

1. Individual in pay status who is age 75 or younger and has a proposed 

suspension 

2. Individual in pay status who is older than age 75 but younger than 80 and has a 

proposed suspension 

3. Individual with a proposed suspension who is not yet in pay status is below 

normal retirement age 

4. Individual with a proposed suspension who is not yet in pay status is above 

normal retirement age

5. Individual with a proposed suspension that is lower than 110% of the PBGC 

guarantee and is in pay status 

6. Individual with a proposed suspension that is lower than 110% of the PBGC 

guarantee who is not yet in pay status and is below normal retirement age 

7. Individual with a proposed suspension that is lower than 110% of the PBGC 

guarantee who is not yet in pay status and is above normal retirement age 

8. Individual in pay status whose benefits are not proposed to be suspended due to 

disability 

9. Individual in pay status whose benefits are not proposed to be suspended due to 

age

10. Individual in pay status whose benefits are not proposed to be suspended due to 

reduction falling below 110% of the PBGC guarantee 
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 12 of 24

11. Individual not yet in pay status, and below normal retirement age, whose benefits 

are not proposed to be suspended due to reduction falling below 110% of the 

PBGC guarantee 

12. Individual not yet in pay status, and above normal retirement age, whose benefits 

are not proposed to be suspended due to reduction falling below 110% of the 

PBGC guarantee 

 Efforts Made to contact Participants, Beneficiaries and Alternate Payees. 

The Trustees will make all reasonable efforts to contact all participants, beneficiaries of 

deceased participants, and alternate payees of the Plan (regardless of whether their 

benefits are proposed to be suspended) pursuant to the Treasury's Proposed and 

Temporary Regulations and in satisfaction of their fiduciary duties under ERISA. The 

Trustees will provide notice to the last known address of the participant, beneficiary or 

alternate payee on file with the Plan, using the same address the Trustees used to 

distribute the Plan's most recent annual funding notice. If that notice is returned as 

undeliverable, the Trustees will use the Plan’s missing participant procedures to attempt 

to locate those missing individuals for whom the notice was returned as undeliverable. 

Those procedures include contacting the applicable Union local for location 

information. For individuals that cannot be located with updated information provided by 

the Union, the procedures include using electronic and on-line searches, and the use of 

professional locator services like Pension Benefit Information and Accurint. The Trustees 

will mail notices to individuals within five days of locating them. Notices will not be 

delivered electronically. 

 List of Contributing Employers. 

The following is a list of the contributing employers that have an obligation to contribute to 

the Plan within the meaning of Section 4212(a) of ERISA: 

 ABF FREIGHT SYSTEM

 AFT WASHINGTON, AFL-CIO

 AMALGAMATED TRAN DIV 587

 AMALGAMATED TRANSIT 1555

 AMALGAMATED TRANSIT 192

 AMERICAN POSTAL WRKRS 

 ARCHDIOCESE OF PDX

 ASBESTOS WORKERS #28

 ASBESTOS WORKERS #36

 AWPPW

 BAC PACIFIC NW ADC

 BAKERS LOCAL 114

 BAKERS UNION LOCAL 125

 BAKERY & CONF WRKRS #9
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 13 of 24

 BAY AREA LONGSHOREMEN'S

 BERKELY FARMS/DEAN FOODS

 BLDG & CONSTR TRADES CNCL

 BOILERMAKERS #101

 BOILERMAKERS LOCAL 242

 BOILERMAKERS LOCAL 500

 BREMERTON METAL TRADES

 BRICKLAYERS & AC LOCAL #7

 BRICKLAYERS & ALLIED

 BRICKLAYERS JATC/SN RAMON

 BROAD & GUSMAN LLP

 BUESCHER,GOLDMANN,KELMAN

 CALIF FED OF TEACHERS

 CARPENTERS INDUST COUNCIL, UBC

 CARPENTERS LOCAL 81

 CEMENT MASONS LOCAL 555

 CHABOT FED CREDIT UNION

 CNTL LABOR COUN. ALAMEDA CTY ALF-CIO

 COAST LONGSHORE DIVISION

 COLO BLDG & CONST TRADES

 COLUMBIA PAC BLDG TRADES

 CONST. & GEN LABORERS LOCAL 185

 CWA #7777

 CWA LOCAL 7800

 CWA LOCAL 7901

 CWA LOCAL 9415

 CWA LOCAL 9423

 DAVID B CONDON PLC

 DAVID C CHVATAL, CPA

 DAVIS COWELL & BOWE LLP

 DENVER FIREFIGHTERS #858

 DENVER PLUMBERS JT

 DENVER THEATER STG EES #7

 DISTRIC LODGE W-24 IAMW

 DMC INSURANCE ADMIN, INC

 ELEVATORS CONSTRUCTORS

 FOUNDATION FOR FAIR CONTR

 GEORGE BIANCHI CONSTRUCTION
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 14 of 24

 GLAZIERS #188

 GREATER SEATTLE AREA

 HEALTHNET SERVICES

 HOD CARRIERS & GEN LABORERS #242

 HORIZON LINES

 IAM & AEROSPACE LODGE 933

 IAM 751

 IAM DISTRICT LODGE 776

 IAMAW LOCAL LODGE 1886

 IBEW & UNITED WORKERS FCU

 IBEW JATC

 IBEW LOCAL 1116

 IBEW LOCAL 180

 IBEW LOCAL 266

 IBEW LOCAL 302

 IBEW LOCAL 332

 IBEW LOCAL 340

 IBEW LOCAL 387

 IBEW LOCAL 46

 IBEW LOCAL 48

 IBEW LOCAL 483

 IBEW LOCAL 570

 IBEW LOCAL 574

 IBEW LOCAL 595

 IBEW LOCAL 640

 IBEW LOCAL 68

 IBEW LOCAL 76

 IBEW LOCAL 76 FCU

 IBEW LOCAL 89

 ILWU INTERNATIONAL

 ILWU LOCAL 10

 ILWU LOCAL 19

 ILWU LOCAL 40

 ILWU LOCAL 52

 ILWU LOCAL 6

 ILWU LOCAL UNION 8

 ILWU/WAREHOUSE UNION 34

 ILWU-PMA WALFARE PLAN
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 15 of 24

 INTL ALLIANCE OF THEATRICAL STAGE #15

 INTL ASSC OF HEAT & FROST

 INTL TRANSPORT WRKRS FED

 INTL UNION OF PAINTER DIST COUN 15

 INTL UNION OPRTNG ENG LU9

 INTNL UNION OF ELEV. CONST. #25

 IRIONWORKERS #24

 IRON WORKERS OCAL 75

 IRONWORKERS LOCAL 118

 IRONWORKERS LOCAL 155

 IRONWORKERS LOCAL 29

 IRONWORKERS LOCAL 378

 IRONWORKERS LOCAL 516

 IUPAT DIST COUNCIL #5

 JOURNEYMEN PLUMBERS & GASFITTERS #3

 LABORERS 483 MUNICIPAY EE

 LABORERS COMMUNITY SERV AGENCE

 LABORERS' LOCAL 440

 LABORERS LOCAL 73

 LEONARD CARDER, LLP 

 LINOLEUM/CRPT LAYERS 1236

 LOS RIOS COLLEGE

 LOWER COLUMBIA LONGSHORE

 LUMBER/SAWMILL WRKRS 2949

 MACHINISTS LODGE 190

 MACHINISTS/BOILERMKRS FCU

 MANOR MGMT SERVICES

 MARIN LUTHER KING JR CTY LABR COUNCIL

 N CA DIST CNCL LABORERS

 N CAL CEMENT MASONS JATC

 NAT ASSOC OF LTR CARRIES

 NECA-IBEW TRAINING TRUST

 NO CAL TILE INDUSTRY JATC

 NORTHWEST LABOR PRES

 NW OREGON LABOR COUNCIL

 OP ENGRS LU 3-MULTI SVCS

 OPEIU LOCAL 11

 OPEIU LOCAL 277
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 16 of 24

 OPEIU LOCAL 29

 OPEIU LOCAL 30

 OPEIU LOCAL 8

 OPERATING ENGINEERS 428

 OPERATING ENGINEERS JATC

 OR & SW WA PAINTERS

 OR FEDERATION OF NURSES

 OR ST BUILD & CNST TRD CO

 OREGON AFL-CIO

 P & P TRAINING

 P & S CREDIT UNION

 PAC NW IRONWORKERS FCU

 PAC. NW.REGIONAL COUNC.

 PAINTERS LOCAL 10

 PHOENIX SHEET METAL JATC

 PIEDMONT GROCERY CO

 PIERCE CO CENT LBR CNCL

 PILE DRIVERS 196

 PIPEFITTERS JATC

 PLUMBER & STEAMFITTERS LOCAL 44

 PLUMBERS & PIPEFTRS #525

 PLUMBERS & PIPEFTRS 442

 PLUMBERS & PIPEFTRS JAC LOCAL $447

 PLUMBERS & PIPEFTS 447

 PLUMBERS LOCAL 393

 PORTLAND LOCAL 8 FCU

 PREFERRED MECHANICAL

 PUGET SOUND ELEC APPR TRAINING TRUST

 RICHMOND SANITARY SVC

 ROADWAY EXPRESS

 S CLARA/S BENITO COUNTIES

 SACRAMENTO CTRL LBR CNCL

 SAN JOAQ CALAVERAS

 SANTA CLARA CTY ELEC JATC

 SEATTLE AREA PLUMBING

 SEATTLE BLDG CONST TRADES

 SEATTLE LABOR TEMPLE ASSOC

 SHEET METAL JATC
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 17 of 24

 SHEET METAL WORKERS #16

 SHEET METAL WORKERS #312

 SHEET METAL WORKERS 259

 SOUTH BAY CENTRAL LBR CNC

 SPRINKLER FTRS & APPR 699

 SW REGIONAL COUNCIL

 SW WA ELECTRICAL JATC

 U.A. LOCAL #290

 U.A. LOCAL #290 TRAINING

 UA #447 PIPE TRADES

 UAW LOCAL 276

 UFCW LOCAL 555

 UNITE HERE LOCAL 483

 UNITE HERE LOCAL 49

 UNITED ADVANTAGE NW FCU

 UNITED ASSOC LOCAL 140

 UNTED ASSOC OF PIPEFITTERS 208

 UTAH STATE AFL-CIO

 W.W. CEMENT MASONS JATC

 WA STATE BLDG & CON TRADES COUN

 WA STATE LBR COUNCIL

 WOODWORKERS IAM & AW LODGE W38
Western States Office and Professional Employees Pension Fund 

Section 4. Demonstration that the Plan's Proposed Suspension Satisfies the 

Statutory Requirements (Continued) 

Page 18 of 24

 List of employee organizations representing participants under the Plan. 

The following is a list of the employee organizations representing participants under the 

Plan: 

 OPEIU LOCAL 11

 OPEIU LOCAL 277

 OPEIU LOCAL 29

 OPEIU LOCAL 30

 OPEIU LOCAL 8

 OPEIU Local 251

 OPEIU Local 3

 OPEIU Local 381

 OPEIU Local 537
Western States Office and Professional Employees Pension Fund 

Page 19 of 24

Section 5. Plan Sponsor's Determination Relating to Reasonable Measures 

Taken to Avoid Insolvency 

.01 Measures Taken to Avoid Insolvency 

See Discussion in Section 3.03, above. 

.02 Plan Factors 

See Discussion in Section 3.03, above. 

.03 How Plan Factors were Taken into Account 

See Discussion in Section 3.03, above. 

.04 Other Factors Considered 

See Discussion in Section 3.03, above. 
Western States Office and Professional Employees Pension Fund 

Page 20 of 24

Section 6. Other Required Information 

.01 Ballot 

See Exhibit 7 for a proposed ballot intended to satisfy the requirements of Section 

432(e)(9)(H)(iii) (without the statement in opposition to the proposed benefit suspension 

described in Section 432(e)(9)(H)(iii)(II) or the individualized estimate that was provided as part of 

the notice described in Section 432(e)(9)(F)). 

.02 Partition 

The Trustees are not requesting approval of a proposed partition from the PBGC. We have had 

conversations with representatives from the PBGC and a partition is not a viable option for the 

Plan at this time. 

.03 Ten-Year Experience for Certain Critical Assumptions 

See Exhibit 8 for a disclosure of the Plan's experience for certain critical assumptions for each of 

the 10 Plan Years immediately preceding the Plan Year in which the Plan's application is 

submitted for the proposed benefit suspension. 

.04 Demonstration of Sensitivity of Projections 

See Exhibit 9 for the following separate projections: (1) a reduction of 1% in the Plan's assumed 

rate of return on assets; (2) a reduction of 2% in the Plan 's assumed rate of return on assets; (3) 

a change in the assumed future contribution base units from a 0% change year over year to a 

10.6% annual reduction for the next ten years; and (4) a change in the assumed future 

contribution base units from a 0% change year over year to a 11.6% annual reduction for the next 

ten years. 

.05 Projection of Funded Percentage 

See Exhibit 10 for the Trustees' illustration, prepared on a deterministic basis, of the projected 

value of Plan assets, the accrued liability of the Plan (calculated using the unit credit funding 

method) and the funded percentage for each year in the Plan's extended period, which ends with 

the 2055 Plan Year. 

.06 Plan Sponsor Certifications Relating to Plan Amendments 

See Exhibit 11 for the Trustees' certification that if they receive final authorization to implement 

the proposed suspension of benefits as described in Section 432(e)(9)(H)(vi), and choose to 

implement the authorized suspension, then, in addition to the plan amendment implementing the 

suspension, the following plan amendments will be timely adopted and not modified at any time 

thereafter before the suspension of benefits expires: (1) a plan amendment providing that, in 

accordance with Section 432(e)(9)(C)(ii), the benefit suspension will cease as of the first day of 

the first Plan Year following the Plan Year in which the Trustees fail to determine that both: all 

reasonable measures to avoid insolvency continue to be taken during the period of the benefit 

suspension; and the Plan is projected to become insolvent unless benefits continue to be 

suspended; and (2) a plan amendment providing that any future benefit improvements must 

satisfy the requirements of Section 432(e)(9)(E). 
Western States Office and Professional Employees Pension Fund 

Section 6. Other Required Information (Continued) 

Page 21 of 24

.07 Whether a Plan is Described in Section 432(e)(9)(D)(vii)(III) 

No, the Plan is not a plan described in Section 432(e)(9)(D)(vii)(Ill). 

.08 Optional Additional Information 

None. 
Western States Office and Professional Employees Pension Fund 

Page 22 of 24

Section 7. Identification and Background Information on the Plan 

.01 Plan Sponsor 

The Plan Sponsor is the Board of Trustees of the Western States Office and Professional 

Employees Pension Fund. The address of the Board is 1220 S.W. Morrison St., Suite 300, 

Portland, Oregon 97205-2222. The Trustees' telephone number is (503) 222-7694 or (800) 413-

4928. Its email address is wsope@aibpa.com and its fax number is (503) 228-0149. The Board 

does not have a separate employer identification number. 

.02 Plan Identification 

The name of the Plan is the Western States Office and Professional Employees Pension Fund. 

The Plan has been assigned the Plan Number 001. Its Employer Identification Number (EIN) is 

94-6076144. The Plan is a multiemployer pension plan within the meaning of Code Section 414(f) 

and ERISA Section 3(37). 

.03 Retiree Representative 

The Plan is not required to appoint a Retiree Representative under the Regulations as it is not a 

plan with 10,000 or more participants. The Trustees have not elected to appoint a Retiree 

Representative though one member of the Board of Trustees is a retiree currently receiving a 

benefit from the Plan. 

.04 Plan's Enrolled Actuary 

See Exhibit 12 for the Plan’s Enrolled Actuary information. 

.05 Power of Attorney 

See Exhibit 13. The Plan's representatives are Joseph L. Reinhart of Joseph L. Reinhart, P.C. 

and Paul L. Graf, A.S.A., E.A., F.C.A., M.A.A.A. of Rael & Letson. 

.06 Plan Documents 

See Exhibit 14 for the Plan's most recently restated Plan Document, the most recent summary 

plan description as defined under section 102 of ERISA and any subsequent summaries of 

material modification, and the Plan's most recent determination letter. The Plan has not been 

amended since May 31, 2016. 

.07 Collective Bargaining and Side Agreements 

See Exhibit 15 for excerpts from the collective bargaining agreements and side agreements 

pursuant to which the Plan is maintained, including language from any portions of a collective 

bargaining agreement or side agreement that are relevant to the Plan or proposed suspension. 

.08 Annual Return 

See Exhibit 16 for the following sections of the Plan's most recently filed Form 5500: (1) pages 1 

and 2 of the Form 5500, (2) the Schedule MB, including attachments, and (3) the Schedule R with 

attachments. 
Western States Office and Professional Employees Pension Fund 

Section 7. Identification and Background Information on the Plan (Continued) 

Page 23 of 24

.09 Rehabilitation Plan 

See Exhibit 17 for a copy of the Plan's most recently updated Rehabilitation Plan. 

.10 Valuation Report 

See Exhibit 18 for a copy of the Plan's two most recent actuarial valuation reports. 

.11 Completed Checklist 

See Appendix A for the completed checklist of information required to be included in the Plan's 

application. 

.12 Request for a Meeting 

We respectfully request an in-person meeting to discuss the issues involved if the Secretary is 

not inclined to approve the Plan's application. 
Redacted by the U.S. Department of the 

Treasury

Redacted by the U.S. Department of the Treasury

Western States Office and Professional Employees Pension Fund 

The Trustees very much appreciate the Treasury's willingness to review this important matter and 

application for the Plan. Should you have any questions or require any additional information, please 

contact the undersigned Trustees at (503) 222-7694 or (800) 413-4928. 

Very truly yours, 

Michael Parmelee, Co-Chair 

Authorized Trustee on behalf of the Board of 

Trustees for the Western States Office and 

Professional Employees Pension Fund 

Date 

of the Board of 

Trustees for the Western States Office and 

Professional Employees Pension Fund 

Date 

1 f 

Page 24 of 24