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DEPARTMENT OF THE TREASURY 

WASHINGTON, D.C. 

March 21, 2019 

Mr. Steve Schramm 

Board of Trustees of the Southwest Ohio 

Regional Council of Carpenters Pension Plan 

33 Fitch Blvd. 

Austintown, OH 44515 

Re: Southwest Ohio Regional Council of Carpenters Pension Plan (Fund) Application for 

Reduction of Benefits 

Dear Mr. Schramm: 

On February 8, 2019, you were notified that the Secretary of the Treasury (Treasury), in 

consultation with the Secretary of Labor (DOL) and the Pension Benefit Guaranty Corporation 

(PBGC), had reviewed your application (Application) for a reduction in benefits, which was 

submitted on June 29, 2018, and determined that the Application satisfied the requirements of 

subparagraphs (C), (D), (E), and (F) of section 432(e)(9) of the Internal Revenue Code (Code), 

which were added to the Code by the Multiemployer Pension Reform Act of 2014 (MPRA). The 

notification explained that, as required under MPRA, before any benefit reduction could go into 

effect, Treasury would administer a vote of eligible participants and beneficiaries to approve or 

reject the proposed benefit reduction. 

The voting period began on February 22, 2019, and ended on March 15, 2019. The Fund identified 

5,527 participants and beneficiaries as eligible to vote. Of the voters identified by the Fund who 

received a ballot, 1,196 (or 22.23 percent of all eligible voters) voted to reject the benefit reduction, 

677 voted to approve the benefit reduction, and 3,506 did not return a ballot. Because a majority 

of voters identified as eligible by the Fund did not vote to reject the benefit reduction, the benefit 

reduction is permitted to go into effect. Treasury, in consultation with DOL and PBGC, has issued 

a final authorization to reduce benefits under the Fund as described in the Application, effective 

April 1, 2019, subject to the conditions described below. 

Under MPRA, the Fund's ability to reduce benefits is conditioned on the Fund's compliance with 

subparagraphs (C) and "(E) ofsection 432(e)(9). Under subparagraph (C), after the benefit 

reduction goes into effect, the Fund's plan sponsor must make an annual determination that, 

despite all reasonable measures to avoid insolvency, the Fund is projected to become insolvent 

unless a benefit reduction continues. The Fund's plan sponsor must maintain a written record of 

these annual determinations, and this record must include a description of the factors considered to 

determine whether all reasonable measures have been taken to avoid insolvency. The written 

record must be made available to participants and beneficiaries. If the Fund's plan sponsor fails to 

satisfy the annual plan sponsor determination requirement for a plan year (including maintaining 

the written record), then the reduction of benefits will expire as of the first day of the following 

plan year.

1 

1 26 C.F.R. § 1.432(c)(9)-l(c)(5). 
Mr. Steve Schramm 

Board ofTrustees of the Southwest Ohio Regional Council ofCarpenters Pension Plan 

March 21, 2019 

Page 2 

Subparagraph (E) of section 432(e)(9) establishes rules that apply to any benefit improvements that 

are made under the Fund during the period that the benefit reduction remains in effect. 

A copy of this letter will be posted on the Treasury Department website. Please contact Treasury 

staff if you have any questions or need any additional information. 

Sincerely, 

Danielle Norris 

MPRA Director 

cc: Scott Newsom 

Jason Birkle