CARPENTERS PENSIO TRUST Fu D, DETROIT & V ICINITY 

PE ALTY OF PERJURY STATEMENT/PUBLIC DISCLOS RE STATEMENT 

Pursuant to Sections 2.03 and 2.04 of IRS Revenue Procedure 2017-43, each of the 

undersigned authorized Trustees makes the following two statements: 

Under penalties of perjury I declare that I have examined this application, including 

the accompanying docwnents, and, to the best of my knowledge and belief, the application 

contains all of the relevant facts relating to this request, and such facts are true, correct and 

complete. 

I acknowledge that, pursuant to Section 432(e)(9)(G)(ii) of the Internal Revenue 

Code, the application for approval of the proposed suspension of benefits, and the 

application's supporting material, will be publicly disclosed through publication to the 

Treasury Department's website. 

Signed: September 20, 20 I 9 

... ~..;F..a~~,s 

CPTF-D\1Cf00033 

1400 
11590 North Meridian Street, Suite 610  Carmel, Indiana 46032-4529  (317) 580-8670  Fax (317) 580-8651

July 29, 2019 

Board of Trustees

Carpenters Pension Trust Fund - Detroit and Vicinity Pension Plan

700 Tower Drive, Suite 300 

Troy, MI 48098-2808 

Re: 2019 Actuarial Certification Under the Pension Protection Act

Dear Trustees:

The following information is intended to comply with the annual certification requirements of IRC 

section 432, with respect to the funded status of the Carpenters Pension Trust Fund - Detroit and 

Vicinity Pension Plan. 

Identifying Information 

Plan Name: Carpenters Pension Trust Fund - Detroit and Vicinity Pension Plan

EIN/Plan #: 38-6242188/001 

Plan year of Certification: year beginning May 1, 2019 

Plan Sponsor: Board of Trustees of Carpenters Pension Trust Fund – Detroit and Vicinity Pension 

Plan

Sponsor Address: 700 Tower Drive, Suite 300, Troy, MI 48098-2808 

Sponsor Telephone: 1-800-572-2525 

Enrolled Actuary Name: Angela L. Jeffries

Enrollment Number: 17-08511 

Actuary Address: 11590 N. Meridian St., Suite 610, Carmel, IN 46032 

Actuary Telephone: (317) 580-8668 

Certification of Plan Status 

I certify that the above-named Plan is in the following status as of May 1, 2019 (all that apply are 

checked):

Safe--Neither Endangered nor Critical Status

Safe--Neither Endangered nor Critical Status 

Due to Special Rule

Endangered Status 

Seriously Endangered Status

Projected to be in Critical Status within 5 years

Critical Status

Critical and Declining Status X

CPTF-DV000034

United Actuarial 

Services, Inc. 

Actuaries and Consultants 
Board of Trustees -2- July 29, 2019 

This certification is based on the following results:

• Projected funded ratio as of May 1, 2019: 34.5%

• Previously emerged from critical status using 

IRC Section 432(e)(4)(B)(ii)(I) special 

emergence rule?: No

• First projected deficiency (with extension): Existing deficiency, FSA projected 

to remain negative as of April 30, 

2019

• At least 8 years of benefit payments in plan 

assets?: Yes

• Plan year of projected insolvency: 2034-35 plan year

• Ratio of inactive to active participants: 2.38

Certification of Scheduled Progress 

I certify that the above-named Plan has made scheduled progress as of May 1, 2019 as outlined in 

the 2014 updated rehabilitation plan. The Plan is not projected to emerge from Critical status by 

the end of the rehabilitation plan period as specified in the updated rehabilitation plan. This 

rehabilitation plan, however, includes the use of the “exhaustion of all reasonable measures” clause 

of IRC 432(e)(3)(A)(ii). Therefore, we interpret scheduled progress for this Plan to mean 

continued use of all reasonable measures to emerge at the earliest date possible or to forestall 

insolvency. 

Basis for Result

The certifications utilize the assumptions, methods, plan provisions and demographic data as 

disclosed in the May 1, 2018 actuarial valuation report with the following exceptions: 

• Based on the April 30, 2019 unaudited financial statements provided by the plan 

administrator, the asset return for the 2018-19 plan year is assumed to be 6.26%. We also 

updated the contributions, benefit payments, and expenses for the 2018-19 plan year based 

on these financial statements.

• For the period May 1, 2019 through April 30, 2028, plan assets were assumed to return 

6.40% per year, with 7.50% per year assumed thereafter. 

• No adjustments were made to the contribution rate assumption. 

CPTF-DV000035

United Actuarial Services, Inc. 
Board of Trustees -3- July 29, 2019 

• Based on information provided by the Trustees regarding projection of future industry 

activity, the following hours were assumed: 8,200,000 for the plan year beginning in 2019; 

8,000,000 for the plan year beginning in 2020; 7,800,000 for the plan year beginning in 

2021, and 7,000,000 for each plan year thereafter. For the 2018-2019 plan year, our 

projections used actual hours of 7,953,779. 

I am a member of the American Academy of Actuaries and meet the Qualification Standards of 

the American Academy of Actuaries to render the actuarial opinion contained herein. These 

certifications are intended to be in good faith compliance with the necessary disclosures for 

certification and represent my best estimate of the Plan’s funded position. We are available to 

answer questions regarding these certifications.

Angela L. Jeffries, EA, MAAA 

Consulting Actuary 

Enrollment Number: 17-08511 

Date of Signature: 07-29-2019 

cc: Secretary of the Treasury

 Mr. Andrew Smith, UAS 

 Ms. Joan Janks, Plan Manager 

 Ms. Linda Olsson, Plan Associate 

 Mr. John Tesija, Fund Counsel 

 Mr. Christopher Scott, Auditor 

m:\docs\det carp\db 28369\valuations\20190501\ppa\20190501 ppa certification.docx

CPTF-DV000036

United Actuarial Services, Inc. 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #5 – 3.01 Plan Actuary’s Certification of Critical and Declining Status as of May 1, 2019

5.5 

Document 5.2

Supplemental Reports

Exhibit I – Solvency Projection

The projected Market Value of Assets and Solvency Ratio for the Plan Years ending April 30, 2019 through April 30, 2035

Plan Year

Ending 1. Beginning

Assets

2. Employer

Contributions

3. EWL

Payments

4. Benefit 

Payments

5. 

Expenses

6. 

Investment

Income

7. Ending

Assets

8. Resources

(1)+(2)+(3)-

(5)+(6)

Solvency

Ratio

(8)/(4)

4/30/2019 $761,729,009 $114,263,735 $0 $151,030,775 $4,950,677 $46,364,177 $766,375,469 $824,677,890 5.4603

4/30/2020 $766,375,469 $120,791,093 $0 $160,110,511 $4,000,000 $47,666,435 $770,722,486 $835,500,126 5.2183

4/30/2021 $770,722,486 $117,844,968 $0 $163,592,005 $4,000,000 $47,738,960 $768,714,409 $836,828,494 5.1153

4/30/2022 $768,714,409 $114,898,844 $0 $167,704,323 $4,000,000 $47,384,573 $759,293,504 $832,228,680 4.9625

4/30/2023 $759,293,504 $103,114,347 $0 $172,117,418 $4,000,000 $46,263,312 $732,553,746 $812,144,539 4.7185

4/30/2024 $732,553,746 $103,114,347 $0 $176,470,780 $4,000,000 $44,412,660 $699,609,974 $787,255,433 4.4611

4/30/2025 $699,609,974 $103,114,347 $0 $180,688,928 $4,000,000 $42,169,278 $660,204,672 $756,555,043 4.1871

4/30/2026 $660,204,672 $103,114,347 $0 $184,753,441 $4,000,000 $39,517,274 $614,082,852 $719,801,744 3.8960

4/30/2027 $614,082,852 $103,114,347 $0 $188,594,635 $4,000,000 $36,442,560 $561,045,125 $676,754,640 3.5884

4/30/2028 $561,045,125 $103,114,347 $0 $191,598,542 $4,000,000 $32,952,020 $501,512,951 $627,207,452 3.2736

4/30/2029 $501,512,951 $103,114,347 $0 $194,424,269 $4,000,000 $34,044,771 $440,247,800 $566,582,527 2.9142

4/30/2030 $440,247,800 $103,114,347 $0 $197,031,148 $4,000,000 $29,352,127 $371,683,126 $510,010,021 2.5885

4/30/2031 $371,683,126 $103,114,347 $0 $198,902,781 $4,000,000 $24,139,590 $296,034,282 $446,657,884 2.2456

4/30/2032 $296,034,282 $103,114,347 $0 $200,262,076 $4,000,000 $18,414,953 $213,301,507 $376,733,677 1.8812

4/30/2033 $213,301,507 $103,114,347 $0 $200,854,975 $4,000,000 $12,187,761 $123,748,640 $300,228,093 1.4948

4/30/2034 $123,748,640 $103,114,347 $0 $201,292,863 $4,000,000 $5,454,875 $27,024,999 $217,408,112 1.0801

4/30/2035 $27,024,999 $103,114,347 $0 $201,008,163 $4,000,000 -$1,788,721 insolvent $127,928,068 0.6364

CPTF-DV000037
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #5 – 3.01 Plan Actuary’s Certification of Critical and Declining Status as of May 1, 2019

5.6 

 

EXHIBIT II - Breakdown of Benefit Payouts for Exhibit I 

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2019 $1,580,345 $6,306,580 $143,143,850 $0

4/30/2020 $5,221,031 $8,156,094 $146,733,386 $0

4/30/2021 $9,240,875 $9,875,835 $144,475,295 $0

4/30/2022 $13,667,341 $11,849,054 $142,187,928 $0

4/30/2023 $18,333,818 $13,926,032 $139,857,568 $0

4/30/2024 $23,139,968 $16,019,098 $137,311,049 $665

4/30/2025 $27,966,861 $18,042,537 $134,677,864 $1,666

4/30/2026 $32,851,575 $20,165,607 $131,733,038 $3,221

4/30/2027 $37,714,057 $22,264,505 $128,606,706 $9,367

4/30/2028 $42,502,830 $23,740,901 $125,333,008 $21,803

4/30/2029 $47,072,856 $25,242,121 $122,070,780 $38,512

4/30/2030 $51,514,128 $26,929,517 $118,509,311 $78,192

4/30/2031 $55,668,747 $28,274,352 $114,837,825 $121,857

4/30/2032 $59,503,514 $29,529,440 $111,045,679 $183,443

4/30/2033 $63,003,159 $30,508,404 $107,089,786 $253,626

4/30/2034 $66,113,384 $31,808,214 $103,030,170 $341,095

4/30/2035 $68,884,771 $32,802,047 $98,867,094 $454,251

CPTF-DV000038
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #5 – 3.01 Plan Actuary’s Certification of Critical and Declining Status as of May 1, 2019

5.7 

Exhibit III – Projected Total Contribution Base Units and Average Contribution Rates

Plan Year

Ending

Total 

Contribution 

Base Units

Contribution 

Rate

Plan Year

Ending

Total 

Contribution 

Base Units

Contribution 

Rate

4/30/2019 7,953,779 $13.98 4/30/2028 7,000,000 $14.73

4/30/2020 8,200,000 $14.73 4/30/2029 7,000,000 $14.73

4/30/2021 8,000,000 $14.73 4/30/2030 7,000,000 $14.73

4/30/2022 7,800,000 $14.73 4/30/2031 7,000,000 $14.73

4/30/2023 7,000,000 $14.73 4/30/2032 7,000,000 $14.73

4/30/2024 7,000,000 $14.73 4/30/2033 7,000,000 $14.73

4/30/2025 7,000,000 $14.73 4/30/2034 7,000,000 $14.73

4/30/2026 7,000,000 $14.73 4/30/2035 7,000,000 $14.73

4/30/2027 7,000,000 $14.73

CPTF-DV000039
Plan Actuary’s Certification that the Plan Is Projected to Avoid Insolvency

This letter and the attached exhibits have been prepared by United Actuarial Services, Inc. at the 

request of the Board of Trustees of the Carpenters Pension Trust Fund – Detroit and Vicinity. 

United Actuarial Services, Inc. certifies under IRC §432(e)(9)(C)(i) that the Plan is projected to 

avoid insolvency within the meaning of IRC §418E, taking into account the proposed benefit 

suspension effective July 1, 2020 and assuming such suspension continues indefinitely. This 

certification is also intended to comply with regulation §1.432(e)(9)-1 and Revenue Procedure 

2017-43. A summary of the proposed benefit suspension can be found in Document 2.1. 

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3).

This certification is based on the May 1, 2018 actuarial valuation report dated February 4, 2019

(see Document 41.1) and the May 1, 2019 actuarial certification dated July 29, 2019 (see 

Document 5.1). The Market Value of assets as of June 30, 2019 (the start of the “initial period” 

as defined in Revenue Procedure 2017-43, Section 3.02, as required under regulation 

§1.432(e)(9)-1(d)(5)(iv)(C)(1)) was furnished by BeneSys, Inc. and certified by Bultynck and Co.,

PLLC.

This certification is intended to demonstrate, as required under IRC §432(e)(9) and regulation 

§1.432(e)(9)-1, that the proposed benefit suspensions are reasonably projected to avoid

insolvency as described in IRC §418E. The results may not be appropriate for any other purpose.

Future actuarial measurements may differ significantly from the current measurements 

presented in this certification due to factorssuch as the following: plan experience differing from 

that anticipated by the economic or demographic assumptions, changes in economic or 

demographic assumptions, or changes in plan provisions. 

The results are based on my best interpretation of existing laws and regulations and are subject 

to revision based on future regulatory or other guidance.

United Actuarial Services, Inc. does not provide, nor charge for, investment, tax or legal advice. 

None of the comments made herein should be construed as constituting such advice. We are 

not aware of any direct or material indirect financial interest or relationship that could create a 

conflict of interest that would impair the objectivity of our work. 

I am a member of the American Academy of Actuaries and meet the Qualification Standards of 

the American Academy of Actuaries to render the actuarial opinion contained herein. To the best 

of my knowledge, the information supplied is complete and accurate. As required by IRC 

§432(b)(3)(B)(iii), the projected industry activity is based on information provided by the plan

sponsor. In my opinion, the projections are based on reasonable actuarial estimates,

assumptions and methods that (other than projected industry activity) offer my best estimate of

anticipated experience under the Plan.

CPTF-DV000040
- • - I I 

Andrew T. Smith, ASA, EA, MAAA 

Enrollment Number: 17-05374 

11590 N. Meridian St., Suite 610 

Carmel, IN 46032 

Phone: 317-580-8675 

CPTF-DV000041 
Actuarial Solvency Certification Supporting Exhibits

EXHIBIT I Value of Plan Assets at Beginning and End of the “Initial Period”

EXHIBIT II Deterministic Projection of Current Plan without Proposed Suspension

EXHIBIT III Deterministic Projection with Proposed Suspension

EXHIBIT IV Breakdown of Benefit Payouts for Exhibit II

EXHIBIT V Breakdown of Benefit Payouts for Exhibit III

CPTF-DV000042
Exhibit I – Value of Plan Assets at Beginning and End of the “Initial Period”

The projected change in Market Value of Assets from July 1, 2019 through April 30, 2020 (the 

“initial period” as defined in Revenue Procedure 2017-43, Section 3.02) is shown below. The 

Market Value of assets as of July 1, 2019 was furnished by BeneSys, Inc. and certified by Bultynck 

and Co., PLLC. The actuarial assumptions used are described in Checklist Item #25. 

From July 1, 2019

through April 30, 2020

1. Market Value at beginning of period $ 768,948,402

2. Employer contributions 102,500,000

3. Withdrawal liability payments 1,333,196

4. Other income -

5. Benefit payments 129,272,109

6. Administrative expenses 5,000,000 

7. Investment earnings/(loss) 40,852,109

8. Projected Market Value at end of period

= (1)+(2)+(3)+(4)-(5)-(6)+(7) $ 779,361,598

CPTF-DV000043
Exhibit II – Deterministic Projection of Current Plan without Proposed Suspension

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2020 through April 30, 2036 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2020 $770,972,113 $120,850,224 $1,333,196 $0 $154,780,950 $6,101,734 $47,088,749 $779,361,598 $934,142,548 6.04

4/30/2021 $779,361,598 $120,000,000 $36,159 $963,841 $158,222,727 $4,090,000 $49,315,840 $787,364,711 $945,587,438 5.98

4/30/2022 $787,364,711 $117,000,000 $36,159 $963,841 $162,095,202 $4,182,025 $49,609,696 $788,697,180 $950,792,382 5.87

4/30/2023 $788,697,180 $105,000,000 $36,159 $963,841 $166,315,986 $4,276,121 $49,166,073 $773,271,146 $939,587,132 5.65

4/30/2024 $773,271,146 $105,000,000 $36,159 $763,841 $170,859,355 $4,372,334 $48,006,095 $751,845,552 $922,704,907 5.40

4/30/2025 $751,845,552 $105,000,000 $36,159 $613,841 $175,602,267 $4,470,712 $46,451,214 $723,873,787 $899,476,054 5.12

4/30/2026 $723,873,787 $105,000,000 $36,159 $613,841 $180,090,672 $4,571,303 $44,483,907 $689,345,719 $869,436,391 4.83

4/30/2027 $689,345,719 $105,000,000 $36,159 $613,841 $184,273,315 $4,674,157 $42,100,304 $648,148,551 $832,421,866 4.52

4/30/2028 $648,148,551 $105,000,000 $36,159 $613,841 $188,448,362 $4,779,326 $39,283,381 $599,854,244 $788,302,606 4.18

4/30/2029 $599,854,244 $105,000,000 $36,159 $613,841 $192,381,485 $4,886,861 $36,012,930 $544,248,828 $736,630,313 3.83

4/30/2030 $544,248,828 $105,000,000 $36,159 $613,841 $195,860,615 $4,996,815 $37,248,383 $486,289,781 $682,150,396 3.48

4/30/2031 $486,289,781 $105,000,000 $36,159 $613,841 $198,809,966 $5,109,243 $32,786,638 $420,807,210 $619,617,176 3.12

4/30/2032 $420,807,210 $105,000,000 $36,159 $613,841 $201,150,335 $5,224,201 $27,783,371 $347,866,045 $549,016,380 2.73

4/30/2033 $347,866,045 $105,000,000 $36,159 $613,841 $202,890,339 $5,341,746 $22,243,125 $267,527,085 $470,417,424 2.32

4/30/2034 $267,527,085 $105,000,000 $12,056 $637,944 $204,157,674 $5,461,935 $16,165,671 $179,723,147 $383,880,821 1.88

4/30/2035 $179,723,147 $105,000,000 $7,236 $642,764 $204,727,442 $5,584,829 $9,554,401 $84,615,277 $289,342,719 1.41

4/30/2036 $84,615,277 $105,000,000 $7,236 $642,764 $204,747,870 $5,710,488 $2,415,832 Insolvent $186,970,621 0.91

CPTF-DV000044
Exhibit III – Deterministic Projection with Proposed Suspension

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2020 through April 30, 2065 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)

-(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2020 $770,972,113 $120,850,224 $1,333,196 $0 $154,780,950 $6,101,734 $47,088,749 $779,361,598 $934,142,548 6.04

4/30/2021 $779,361,598 $120,000,000 $36,159 $963,841 $143,894,673 $4,090,000 $49,781,502 $802,158,427 $946,053,100 6.57

4/30/2022 $802,158,427 $117,000,000 $36,159 $963,841 $143,994,631 $4,182,025 $51,159,556 $823,141,327 $967,135,958 6.72

4/30/2023 $823,141,327 $105,000,000 $36,159 $963,841 $147,266,205 $4,276,121 $52,024,061 $829,623,062 $976,889,267 6.63

4/30/2024 $829,623,062 $105,000,000 $36,159 $763,841 $150,817,500 $4,372,334 $52,320,329 $832,553,557 $983,371,057 6.52

4/30/2025 $832,553,557 $105,000,000 $36,159 $613,841 $154,549,465 $4,470,712 $52,381,450 $831,564,830 $986,114,295 6.38

4/30/2026 $831,564,830 $105,000,000 $36,159 $613,841 $158,109,270 $4,571,303 $52,198,220 $826,732,477 $984,841,747 6.23

4/30/2027 $826,732,477 $105,000,000 $36,159 $613,841 $161,466,157 $4,674,157 $51,771,676 $818,013,839 $979,479,996 6.07

4/30/2028 $818,013,839 $105,000,000 $36,159 $613,841 $164,796,000 $4,779,326 $51,093,326 $805,181,839 $969,977,839 5.89

4/30/2029 $805,181,839 $105,000,000 $36,159 $613,841 $167,932,887 $4,886,861 $50,153,803 $788,165,894 $956,098,781 5.69

4/30/2030 $788,165,894 $105,000,000 $36,159 $613,841 $170,726,967 $4,996,815 $56,484,675 $774,576,787 $945,303,754 5.54

4/30/2031 $774,576,787 $105,000,000 $36,159 $613,841 $173,081,923 $5,109,243 $55,372,965 $757,408,586 $930,490,509 5.38

4/30/2032 $757,408,586 $105,000,000 $36,159 $613,841 $174,950,557 $5,224,201 $54,010,966 $736,894,794 $911,845,351 5.21

4/30/2033 $736,894,794 $105,000,000 $36,159 $613,841 $176,333,890 $5,341,746 $52,416,148 $713,285,306 $889,619,196 5.05

4/30/2034 $713,285,306 $105,000,000 $12,056 $637,944 $177,313,332 $5,461,935 $50,604,200 $686,764,239 $864,077,571 4.87

4/30/2035 $686,764,239 $105,000,000 $7,236 $642,764 $177,725,931 $5,584,829 $48,595,039 $657,698,518 $835,424,449 4.70

4/30/2036 $657,698,518 $105,000,000 $7,236 $642,764 $177,706,404 $5,710,488 $46,411,130 $626,342,756 $804,049,160 4.52

4/30/2037 $626,342,756 $105,000,000 $7,236 $642,764 $177,204,527 $5,838,974 $44,073,450 $593,022,705 $770,227,232 4.35

4/30/2038 $593,022,705 $105,000,000 $3,618 $646,382 $176,248,098 $5,970,351 $41,605,386 $558,059,642 $734,307,740 4.17

4/30/2039 $558,059,642 $105,000,000 $0 $650,000 $174,668,716 $6,104,684 $39,037,346 $521,973,588 $696,642,304 3.99

4/30/2040 $521,973,588 $105,000,000 $0 $650,000 $172,948,591 $6,242,039 $36,390,245 $484,823,203 $657,771,794 3.80

4/30/2041 $484,823,203 $105,000,000 $0 $650,000 $170,586,543 $6,382,485 $33,687,277 $447,191,452 $617,777,995 3.62

Exhibit III – Deterministic Projection with Proposed Suspension (Cont.)

CPTF-DV000045
Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments 6. Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2042 $447,191,452 $105,000,000 $0 $650,000 $167,975,233 $6,526,091 $30,957,434 $409,297,562 $577,272,795 3.44

4/30/2043 $409,297,562 $105,000,000 $0 $650,000 $164,888,742 $6,672,928 $28,225,630 $371,611,522 $536,500,264 3.25

4/30/2044 $371,611,522 $105,000,000 $0 $650,000 $161,317,987 $6,823,069 $24,846,718 $333,967,184 $495,285,171 3.07

4/30/2045 $333,967,184 $105,000,000 $0 $650,000 $157,557,857 $6,976,588 $22,230,322 $297,313,061 $454,870,918 2.89

4/30/2046 $297,313,061 $105,000,000 $0 $650,000 $153,578,849 $7,133,561 $19,694,075 $261,944,726 $415,523,575 2.71

4/30/2047 $261,944,726 $105,000,000 $0 $650,000 $149,245,028 $7,294,066 $17,264,513 $228,320,145 $377,565,173 2.53

4/30/2048 $228,320,145 $105,000,000 $0 $650,000 $144,625,327 $7,458,182 $14,972,548 $196,859,184 $341,484,511 2.36

4/30/2049 $196,859,184 $105,000,000 $0 $650,000 $140,052,802 $7,625,991 $12,660,825 $167,491,216 $307,544,018 2.20

4/30/2050 $167,491,216 $105,000,000 $0 $650,000 $135,240,426 $7,797,576 $10,713,399 $140,816,613 $276,057,039 2.04

4/30/2051 $140,816,613 $105,000,000 $0 $650,000 $130,385,529 $7,973,021 $8,961,288 $117,069,351 $247,454,880 1.90

4/30/2052 $117,069,351 $105,000,000 $0 $650,000 $125,394,762 $8,152,414 $7,424,695 $96,596,870 $221,991,632 1.77

4/30/2053 $96,596,870 $105,000,000 $0 $650,000 $120,379,652 $8,335,843 $6,124,617 $79,655,992 $200,035,644 1.66

4/30/2054 $79,655,992 $105,000,000 $0 $650,000 $115,646,780 $8,523,399 $5,279,693 $66,415,506 $182,062,286 1.54

4/30/2055 $66,415,506 $105,000,000 $0 $650,000 $110,813,023 $8,715,175 $4,460,731 $56,998,039 $167,811,062 1.51

4/30/2056 $56,998,039 $105,000,000 $0 $650,000 $106,208,722 $8,911,266 $3,919,728 $51,447,779 $157,656,501 1.48

4/30/2057 $51,447,779 $105,000,000 $0 $650,000 $101,730,529 $9,111,769 $3,663,872 $49,919,353 $151,649,882 1.49

4/30/2058 $49,919,353 $105,000,000 $0 $650,000 $97,396,864 $9,316,784 $3,704,065 $52,559,770 $149,956,634 1.54

4/30/2059 $52,559,770 $105,000,000 $0 $650,000 $93,640,369 $9,526,412 $4,035,103 $59,078,092 $152,718,461 1.63

4/30/2060 $59,078,092 $105,000,000 $0 $650,000 $89,908,710 $9,740,756 $4,655,877 $69,734,503 $159,643,213 1.78

4/30/2061 $69,734,503 $105,000,000 $0 $650,000 $86,530,378 $9,959,923 $5,573,576 $84,467,778 $170,998,156 1.98

4/30/2062 $84,467,778 $105,000,000 $0 $650,000 $83,328,377 $10,184,021 $6,790,243 $103,395,623 $186,724,000 2.24

4/30/2063 $103,395,623 $105,000,000 $0 $650,000 $80,396,100 $10,413,161 $8,311,199 $126,547,561 $206,943,661 2.57

4/30/2064 $126,547,561 $105,000,000 $0 $650,000 $77,681,306 $10,647,457 $10,140,613 $154,009,411 $231,690,717 2.98

4/30/2065 $154,009,411 $105,000,000 $0 $650,000 $75,204,190 $10,887,025 $12,284,160 $185,852,356 $261,056,546 3.47

CPTF-DV000046
EXHIBIT IV – Breakdown of Benefit Payouts for Exhibit II

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2020 $5,257,832 $2,555,487 $146,967,631 $0

4/30/2021 $9,321,879 $4,106,716 $144,794,132 $0

4/30/2022 $13,826,369 $5,767,133 $142,501,700 $0

4/30/2023 $18,567,951 $7,631,574 $140,116,461 $0

4/30/2024 $23,459,170 $9,835,688 $137,563,843 $654

4/30/2025 $28,376,851 $12,255,774 $134,968,003 $1,639

4/30/2026 $33,359,802 $14,716,308 $132,011,394 $3,168

4/30/2027 $38,323,875 $17,079,870 $128,860,360 $9,210

4/30/2028 $43,205,066 $19,613,518 $125,608,342 $21,436

4/30/2029 $47,819,224 $22,174,062 $122,350,339 $37,860

4/30/2030 $52,262,617 $24,734,618 $118,786,519 $76,861

4/30/2031 $56,379,550 $27,196,829 $115,113,812 $119,775

4/30/2032 $60,144,194 $29,494,488 $111,331,354 $180,299

4/30/2033 $63,576,184 $31,690,557 $107,374,326 $249,272

4/30/2034 $66,627,897 $33,880,037 $103,314,507 $335,233

4/30/2035 $69,346,310 $35,782,787 $99,151,900 $446,445

4/30/2036 $71,806,771 $37,513,797 $94,858,576 $568,726

CPTF-DV000047
EXHIBIT V – Breakdown of Benefit Payouts for Exhibit III

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2020 $5,257,832 $2,555,487 $146,967,631 $0

4/30/2021 $8,451,914 $3,418,201 $132,024,558 $0

4/30/2022 $12,297,541 $4,572,742 $127,124,348 $0

4/30/2023 $16,548,110 $6,018,951 $124,699,144 $0

4/30/2024 $20,949,414 $7,738,359 $122,129,073 $654

4/30/2025 $25,394,686 $9,612,735 $119,540,405 $1,639

4/30/2026 $29,921,078 $11,496,217 $116,688,807 $3,168

4/30/2027 $34,445,957 $13,309,856 $113,701,134 $9,210

4/30/2028 $38,916,599 $15,250,121 $110,607,844 $21,436

4/30/2029 $43,161,754 $17,209,981 $107,523,292 $37,860

4/30/2030 $47,271,598 $19,164,836 $104,213,672 $76,861

4/30/2031 $51,097,595 $21,045,418 $100,819,135 $119,775

4/30/2032 $54,614,296 $22,805,449 $97,350,513 $180,299

4/30/2033 $57,835,958 $24,487,407 $93,761,253 $249,272

4/30/2034 $60,721,780 $26,167,498 $90,088,821 $335,233

4/30/2035 $63,302,717 $27,630,757 $86,346,012 $446,445

4/30/2036 $65,657,725 $28,963,139 $82,516,814 $568,726

4/30/2037 $67,702,702 $30,164,979 $78,623,199 $713,647

4/30/2038 $69,386,973 $31,338,799 $74,650,395 $871,931

4/30/2039 $70,740,628 $32,217,287 $70,638,693 $1,072,108

4/30/2040 $72,019,527 $33,031,166 $66,600,379 $1,297,519

4/30/2041 $72,862,540 $33,663,064 $62,510,290 $1,550,649

CPTF-DV000048
EXHIBIT V – Breakdown of Benefit Payouts for Exhibit III (Cont.)

Plan Year

Ending Actives

Vested 

Terminations Retired

New 

Entrants

4/30/2042 $73,451,244 $34,261,761 $58,426,815 $1,835,413

4/30/2043 $73,731,597 $34,675,719 $54,335,654 $2,145,772

4/30/2044 $73,683,498 $34,791,598 $50,272,473 $2,570,418

4/30/2045 $73,429,176 $34,858,925 $46,263,070 $3,006,686

4/30/2046 $73,010,475 $34,747,630 $42,317,893 $3,502,851

4/30/2047 $72,288,107 $34,453,988 $38,469,386 $4,033,547

4/30/2048 $71,357,308 $33,913,812 $34,734,894 $4,619,313

4/30/2049 $70,208,173 $33,289,704 $31,140,104 $5,414,821

4/30/2050 $68,823,871 $32,500,596 $27,709,363 $6,206,596

4/30/2051 $67,244,886 $31,573,059 $24,464,424 $7,103,160

4/30/2052 $65,483,533 $30,452,788 $21,424,539 $8,033,902

4/30/2053 $63,492,934 $29,259,752 $18,605,227 $9,021,739

4/30/2054 $61,362,488 $27,936,908 $16,017,676 $10,329,708

4/30/2055 $59,061,398 $26,523,242 $13,668,054 $11,560,329

4/30/2056 $56,632,253 $25,090,759 $11,557,494 $12,928,216

4/30/2057 $54,104,059 $23,645,721 $9,682,865 $14,297,884

4/30/2058 $51,463,424 $22,172,858 $8,035,876 $15,724,706

4/30/2059 $48,769,627 $20,695,396 $6,605,985 $17,569,361

4/30/2060 $46,038,910 $19,241,500 $5,379,336 $19,248,964

4/30/2061 $43,306,477 $17,809,990 $4,339,905 $21,074,006

4/30/2062 $40,592,204 $16,411,963 $3,469,975 $22,854,235

4/30/2063 $37,914,299 $15,055,610 $2,750,823 $24,675,368

4/30/2064 $35,288,019 $13,746,285 $2,163,500 $26,483,502

4/30/2065 $32,729,083 $12,491,189 $1,689,507 $28,294,411

CPTF-DV000049
Demonstration that the Limitations on

Individual Suspensions Are Satisfied

This document illustrates how the proposed suspension satisfies the guarantee-based

limitation, the age-based limitation, and the disability-based limitation, as established under 

IRC Section 432(e)(9)(D)(i), (ii), and (iii), respectively. 

Guarantee-based Limitation

The proposed suspension does not reduce the benefit of any participant or beneficiary to an 

amount that is less than 110% of the PBGC guarantee. 

If a participant’s benefit is split with an alternate payee under the terms of a qualified domestic 

relations order (QDRO), then the determination of the guaranteed level for both parties is 

based on the terms of the QDRO. Generally, if the QDRO provides the alternate payee a shared 

interest with the participant, then the participant’s total benefit is used for purposes of 

determining the guaranteed amount for both parties. If the QDRO provides a separate interest 

for the alternate payee, then the alternate payee’s separate benefit level is used to determine 

the guaranteed amount. If there are multiple QDROs with multiple alternate payees, this 

determination is made separately with respect to each applicable QDRO.

Age-Based Limitation

The proposed suspension does not affect any participant or beneficiary who will be age 80 or 

older as of July 31, 2020 (the end of the month in which the July 1, 2020 effective date of the 

proposed suspension occurs). The proposed suspension only partially affects any participant or 

beneficiary who will be age 75-79 as of July 31, 2020 (with proportionally more of the current 

benefit being protected the closer the participant or beneficiary is to age 80). 

In the event that the age-based limitation applies to a participant that has a QDRO, then the 

type of QDRO will determine whether the Pension Plan uses the participant’s or alternate 

payee’s age. If the QDRO provides the alternate payee a shared interest with the participant, 

then the participant’s age is used for purposes of applying the age-based limitation as of the 

proposed suspension’s effective date. Alternatively, if the QDRO provides a separate interest 

for the alternate payee, then the alternate payee’s age is used to determine the application of 

the age-based limitation. If there are multiple QDROs with multiple alternate payees, the 

determination of whose age to use is determined separately for each applicable QDRO.

The application of the age-based limitation for a participant who elected a joint and survivor 

benefit is based on the age of the participant as of July 31, 2020, unless he or she is deceased, 

in which case the surviving spouse’s age is used to determine the application of the age-based 

limitation.

Section 4.01(3) of revenue procedure 2017-43 requires submission of sample calculations for 

each group defined in Checklist Item #2 that includes an individual who is over age 75 (as of July 

CPTF-DV000050
31, 2020). Note that no calculations are included for groups that have a sub-group designation 

of “2” as these the individuals in these groups have only post-5/1/2007 accruals and will not be 

affected by the suspension.

Section 4.01(3)(c) of revenue procedure 2017-43 requests submission of sample calculations on 

individuals who are between age 75 and 79 but have not commenced benefits. However, all 

plan participants satisfying the preceding criteria are past their IRC section 401(a)(9) required 

beginning date and ARE treated as being in pay status retroactive to such date. Therefore, no 

such calculations are included for the “A” and “B” groups.

The “C groups” and “D groups” do not contain anyone over the age of 75, so no calculations are 

included for these groups.

Based on the preceding, sample age-based limitation calculations are submitted on the 

following groups:

• E1

• E3

Disability-based Limitation

The proposed suspension does not affect any disability benefit that is in pay status as of July 1, 

2020. Furthermore, if a disabled participant has converted to a retirement benefit on or prior 

to July 1, 2020, such participant’s benefit will not be reduced below the amount of his or her 

disability benefit.

There are currently 3 types of disability benefits paid to an individual under the plan. 

1. Basic Disability Benefit – In order to be eligible for this benefit, the participant must be 

under age 62, have at least 5 credit years, and have a disability award from the Social 

Security Administration (SSA). The benefit is paid in the form of a temporary life annuity 

generally ending at age 62. The benefit amount is equal to the greater of: (a) 75% of 

the vested accrued benefit, or (b) $280, but is subject to a cap pursuant to the following 

table:

Number of 

Credit Years

Cap on Disability 

Benefit

5-9 $525

10-15 $625

16-19 $725

20-24 $1,050

25+ $1,350

CPTF-DV000051
2. Lump Sum Disability Benefit – If a participant is disabled with an SSA award but has less 

than 5 credit years (the plan uses 3-7 year graded vesting), then he or she is eligible for a 

lump sum cash-out equal to the actuarial present value of his or her vested accrued 

benefit.

3. Lawsuit-related Disability Benefit – As the result of a settlement of a class action lawsuit 

in October 2016, most disabled participants who were in pay status as of 8/1/2013 and 

had taken a cut due to the 2013 rule change implementing the service-based cap 

described above, were restored to 95% of their pre-amendment disability benefit 

amount. After these people retire, the disability-based limitation will be applied based 

on the 95% of pre-amendment disability amount.

The following special rules apply to the application of the disability-based limitation:

• When the disability rules were changed in 2013 to require a disability award from the 

SSA, disabled retirees without such an award were allowed one year to obtain one. As a 

result of this change, some previously disabled participants ceased to qualify under the 

plan rules. These people will not receive any special protection under the disabilitybased limitation.

• As the result of the 2016 class action settlement, affected disabled participants who 

were:

a. In pay status on 8/1/2013, and

b. Converted to early retirement prior to October 2016, and

c. Had an early retirement benefit that was less than 95% of their prior disability 

benefit,

were granted a benefit increase to 95% of their pre-amendment disability amounts 

payable until age 62, at which time their benefit will increase to an unreduced, early

retirement benefit. For purposes of the disability-based limitation, the benefit payable 

until normal retirement age for these participants will be treated as a disability benefit.

If a participant’s benefit is split with an alternate payee under the terms of a QDRO, then the 

determination of the amount of the disability-based limitation for both parties is based on the 

terms of the QDRO. In the case of a separate interest QDRO, the alternate payee will generally 

not receive any portion of the disability-based limitation. The exception to this is in the case of 

an alternate payee who was assigned a portion of the participant’s disability benefit. In this 

case, such alternate payee will receive a disability-based limitation based on the portion of 

disability benefit assigned and the participant will not receive a disability-based limitation based 

on such portion.

In the case of a shared interest QDRO, any disability-based limitation will be shared in the same 

manner as the benefit itself.

CPTF-DV000052
Surviving spouses and beneficiaries will not receive any disability-based limitation.

Sample Calculations

The sample calculations required by Section 4.01 of revenue procedure 2017-43 are attached to 

this the document as exhibits. Note that:

• There are no ERISA 4022A(a) forfeitable benefits,

• There are no ERISA 4022A(b)(1)(A) benefit increases that have been in effect for less 

than 60 months,

• The limitations contained in ERISA 4022A(c)(2) have been reflected in the guaranteebased calculations,

• There have been no ERISA 4022A(d) benefit reductions made pursuant to IRC section 

411(a)(3)(E) (related to service with an employer rendered prior to such employer’s 

obligation to contribute to the plan where such employer subsequently ceases to have 

an obligation to contribute), and

• The ERISA 4022A(e) exclusion does not apply as the Secretary of the Treasury has not

determined that the plan fails to satisfy the requirements of IRC sections 401(a) or 

404(a)(2).

A listing of the attached exhibits appears below:

Exhibit #

Relevant 

Section of Rev. 

Proc. 2017-43 Description

I 4.01(1) Guarantee-based limitation for an individual currently receiving 

benefits

II 4.01(1) Guarantee-based limitation for the contingent beneficiary of an 

individual currently receiving benefits

III 4.01(1) Guarantee-based limitation for a future retiree

IV 4.01(2) Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability benefit)

V 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit)

VI 4.01(2) Disability-based limitation for a future retiree who is currently 

receiving a temporary annuity disability benefit

VII 4.01(2)

Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability benefit 

that was equal to 95% of his or her pre-8/1/2013 disability 

benefit due to the October 2016 settlement)

CPTF-DV000053
Exhibit #

Relevant 

Section of Rev. 

Proc. 2017-43 Description

VIII 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit that was equal to 95% of 

his or her pre-8/1/2013 disability benefit due to the October 

2016 settlement)

IX 4.01(2)

Disability-based limitation for a future retiree who is currently 

receiving a disability benefit equal to 95% of his or her pre8/1/2013 disability benefit due to the October 2016 settlement

X 4.01(2)

Disability-based limitation for an individual who had previously 

received a retirement benefit that is treated like a disability 

benefit due to the October 2016 settlement

XI 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual who had previously received a retirement benefit that 

is treated like a disability benefit due to the October 2016 

settlement

XII 4.01(2)

Disability-based limitation for an individual who is currently 

receiving a retirement benefit that is treated like a disability 

benefit due to the October 2016 settlement

XIII 4.01(3) Group E1 retiree who is between age 75 and 79 as of 7/31/2020

XIV 4.01(3) Beneficiary of a group E1 retiree who is between age 75 and 79 

as of 7/31/2020

XV 4.01(3) Group E3 retiree who is between age 75 and 79 as of 7/31/2020

XVI 4.01(3) Beneficiary of a group E3 retiree who is between age 75 and 79 

as of 7/31/2020

CPTF-DV000054
Exhibit I - Guarantee-based limitation for an individual currently receiving benefits

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 12/4/1952

Date of retirement (DOR) 1/1/2018

Age at retirement date 65 years, 0 months

Age at suspension date 67 years, 7 months

Disabled? No

Current monthly benefit $ 117.35 

Amount of current monthly benefit earned prior to 5/1/2007 $ 117.35 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 5

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 117.35 

PBGC accrual rate $ 23.47 

PBGC guaranteed accrual rate $ 20.35 

PBGC guaranteed benefit (no greater than current benefit) $ 101.76 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 111.94 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 117.35 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 18.78 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 98.57 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 98.57 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 111.94 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 111.94 

Final Monthly Benefit under Proposed Suspension $ 111.94 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes

Disability limit? No

Age-based limit? No

CPTF-DV000055
Exhibit II - Guarantee-based limitation for the contingent beneficiary of an individual 

currently receiving benefits

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 8/2/1945

Date of retirement (DOR) 9/1/2000

Age at retirement date 55 years, 0 months

Age at suspension date 74 years, 11 months

Disabled? No

Current monthly benefit $ 502.25 

Amount of current monthly benefit earned prior to 5/1/2007 $ 502.25 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 17

Form of pension Joint and 100% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 502.25 $ 502.25 

PBGC accrual rate $ 29.54 $ 29.54 

PBGC guaranteed accrual rate $ 24.91 $ 24.91 

PBGC guaranteed benefit (no greater than current benefit) $ 423.44 $ 423.44 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 465.78 $ 465.78 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 502.25 $ 502.25

MPRA Reduction for benefit earned prior to 5/1/2007 $ 80.36 $ 80.36 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 421.89 $ 421.89 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 421.89 $ 421.89 

Step 3 or 110% of PBGC guaranteed benefit if greater $ 465.78 $ 465.78 

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 465.78 $ 465.78 

Final Monthly Benefit under Proposed Suspension $ 465.78 $ 465.78 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes

Disability limit? No

Age-based limit? No

 

CPTF-DV000056
Exhibit III - Guarantee-based limitation for a future retiree

Suspension Limitation: 110% of PBGC Guarantee Benefit

Date of birth 8/9/1977

Age at suspension date 42 years, 11 months

Disabled? No

Accrued monthly benefit $ 132.00 

Amount of accrued monthly benefit earned prior to 5/1/2007 $ 63.27 

Amount of accrued monthly benefit earned on and after 5/1/2007 $ 68.73 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 7

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Accrued monthly benefit, without regard to LRF $ 132.00 

PBGC accrual rate $ 18.86 

PBGC guaranteed accrual rate $ 16.89 

PBGC guaranteed benefit (no greater than current benefit) $ 118.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 130.08 

Calculation of Monthly Benefit under Proposed Suspension

Accrued monthly benefit $ 132.00 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 115.55 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 46.82 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 68.73 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 115.55 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 130.08 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 130.08 

Final Monthly Benefit under Proposed Suspension $ 130.08 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? Yes

Disability limit? No

Age-based limit? No

CPTF-DV000057
Exhibit IV - Disability-based limitation for an individual currently receiving retirement benefits 

(who previously received a disability benefit)

Suspension Limitation: Disability Benefit

Date of birth 3/2/1947

Date of retirement (DOR) 4/1/2009

Age at retirement date 62 years, 0 months

Age at suspension date 73 years, 4 months

Disabled? Yes

Current monthly benefit $ 1,937.06 

Protected disability benefit $ 1,652.81 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,937.06 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 15

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,937.06 

PBGC accrual rate $ 129.14 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 536.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 589.88 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,937.06 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 309.93 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 1,627.13 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,627.13 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,627.13 

Step 5: Step 4 or disability benefit if greater $ 1,652.81 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 1,652.81 

Final Monthly Benefit under Proposed Suspension $ 1,652.81 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF-DV000058
Exhibit V - Disability-based limitation for the contingent beneficiary of an individual currently 

receiving retirement benefits (who previously received a disability benefit)

Suspension Limitation: Disability Benefit

Date of birth 5/31/1950

Date of retirement (DOR) 6/1/2005

Age at retirement date 55 years, 0 months

Age at suspension date 70 years, 2 months

Disabled? Yes

Current monthly benefit $ 1,440.59 

Protected disability benefit $ 1,399.38 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,440.59 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 25

Form of pension Joint and 50% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 1,440.59 $ 720.30 

PBGC accrual rate $ 57.62 $ 28.81 

PBGC guaranteed accrual rate $ 35.75 $ 24.36 

PBGC guaranteed benefit (no greater than current benefit) $ 893.75 $ 608.98 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 983.13 $ 669.88 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 1,440.59 $ 720.30 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 230.49 $ 115.25 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 1,210.10 $ 605.05 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,210.10 $ 605.05 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,210.10 $ 669.88 

Step 5: Step 4 or disability benefit if greater $ 1,399.38 $ 669.88 

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 1,399.38 $ 669.88 

Final Monthly Benefit under Proposed Suspension $ 1,399.38 $ 669.88 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF-DV000059
Exhibit VI - Disability-based limitation for a future retiree who is currently receiving a 

temporary annuity disability benefit

Suspension Limitation: Disability Benefit

Date of birth 5/5/1961

Date of Disability retirement (DOR) 10/1/2009

Age at Disability retirement date 48 years, 4 months

Age at suspension date 59 years, 2 months

Disabled? Yes

Current monthly disability benefit $ 423.65 

Accrued monthly benefit $ 564.86 

Amount of accrued benefit earned prior to 5/1/2007 $ 564.86 

Amount of accrued benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 9

Form of pension Disability

Calculation of 110% of PBGC Guarantee

Accrued benefit, without regard to LRF $ 564.86 

PBGC accrual rate $ 62.76 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 321.75 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 353.93 

Calculation of Monthly Benefit under Proposed Suspension

Accrued Monthly benefit $ 564.86 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 90.38 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 474.48 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 474.48 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 474.48 

Step 5: Step 4 or disability benefit if greater $ 474.48 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 474.48 

Final Monthly Benefit under Proposed Suspension $ 474.48 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? No

CPTF-DV000060
Exhibit VII - Disability-based limitation for an individual currently receiving retirement 

benefits (who previously received a disability benefit that was equal to 95% of his or her pre8/1/2013 disability benefit due to the October 2016 settlement)

Suspension Limitation: Disability Benefit

Date of birth 3/16/1953

Date of retirement (DOR) 4/1/2011

Age at retirement date 58 years, 0 months

Age at suspension date 67 years, 4 months

Disabled? Yes

Current monthly benefit $ 2,996.70 

Protected disability benefit $ 2,694.55 

Amount of current monthly benefit earned prior to 5/1/2007 $ 2,996.70 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 22

Form of pension Joint and 75% Survivor

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 2,996.70 

PBGC accrual rate $ 136.21 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 786.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 865.15 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 2,996.70 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 346.99 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,649.71 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 2,649.71 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 2,649.71 

Step 5: Step 4 or disability benefit if greater $ 2,694.55 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 2,694.55 

Final Monthly Benefit under Proposed Suspension $ 2,694.55 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

CPTF-DV000061
Exhibit VIII - Disability-based limitation for the contingent beneficiary of an individual 

currently receiving retirement benefits (who previously received a disability benefit that was 

equal to 95% of his or her pre-8/1/2013 disability benefit due to the October 2016 

settlement)

Suspension Limitation: Disability Benefit

Date of birth 1/14/1949

Date of retirement (DOR) 2/1/2010

Age at retirement date 61 years, 0 months

Age at suspension date 71 years, 6 months

Disabled? Yes

Current monthly benefit $ 4,367.07 

Protected disability benefit $ 4,078.36 

Amount of current monthly benefit earned prior to 5/1/2007 $ 4,367.07 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 19

Form of pension Joint and 75% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 4,367.07 $ 3,275.30 

PBGC accrual rate $ 229.85 $ 172.38 

PBGC guaranteed accrual rate $ 35.75 $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 679.25 $ 679.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 747.18 $ 747.18 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 4,367.07 $ 3,275.30 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 585.28 $ 438.96 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 3,781.79 $ 2,836.34 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 3,781.79 $ 2,836.34 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 3,781.79 $ 2,836.34 

Step 5: Step 4 or disability benefit if greater $ 4,078.36 $ 2,836.34 

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 4,078.36 $ 2,836.34 

Final Monthly Benefit under Proposed Suspension $ 4,078.36 $ 2,836.34 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

Exhibit IX - Disability-based limitation for a future retiree who is currently receiving a 

disability benefit equal to 95% of his or her pre-8/1/2013 disability benefit due to the October 

2016 settlement

CPTF-DV000062
Suspension Limitation: Disability Benefit

Date of birth 11/23/1960

Date of Disability retirement (DOR) 6/1/2012

Age at Disability retirement date 51 years, 6 months

Age at suspension date 59 years, 8 months

Disabled? Yes

Current monthly disability benefit $ 1,959.60 

Accrued monthly benefit $ 2,750.32 

Amount of accrued benefit earned prior to 5/1/2007 $ 2,750.32 

Amount of accrued benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 18

Form of pension Disability

Calculation of 110% of PBGC Guarantee

Accrued benefit, without regard to LRF $ 2,750.32 

PBGC accrual rate $ 152.80 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 643.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 707.85 

Calculation of Monthly Benefit under Proposed Suspension

Accrued Monthly benefit $ 2,750.32 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 440.05 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,310.27 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Accrued monthly benefit reduced for MPRA (Step 1 + Step 2) $ 2,310.27 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 2,310.27 

Step 5: Step 4 or disability benefit if greater $ 2,310.27 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 2,310.27 

Final Monthly Benefit under Proposed Suspension $ 2,310.27 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? No

Exhibit X - Disability-based limitation for an individual who had previously received a 

retirement benefit that is treated like a disability benefit due to the October 2016 settlement

Suspension Limitation: Disability Benefit

CPTF-DV000063
Date of birth 9/11/1959

Date of retirement (DOR) 6/1/2009

Age at retirement date 52 years, 8 months

Age at suspension date 63 years, 10 months

Disabled? Yes

Current monthly benefit $ 1,061.76 

Protected disability benefit $ 917.18 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,005.80 

Amount of current monthly benefit earned on and after 5/1/2007 $ 55.96 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 14

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,061.76 

PBGC accrual rate $ 75.84 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 500.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 550.55 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,061.76 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 160.93 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 844.87 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 55.96 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 900.83 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 900.83 

Step 5: Step 4 or disability benefit if greater $ 917.18 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 917.18 

Final Monthly Benefit under Proposed Suspension $ 917.18 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

 

CPTF-DV000064
Exhibit XI - Disability-based limitation for the contingent beneficiary of an individual who had 

previously received a retirement benefit that is treated like a disability benefit due to the 

October 2016 settlement

Suspension Limitation: Disability Benefit

Date of birth 8/30/1957

Date of retirement (DOR) 8/1/2013

Age at retirement date 55 years, 11 months

Age at suspension date 62 years, 11 months

Disabled? Yes

Current monthly benefit $ 4,487.78 

Protected disability benefit $ 3,890.44 

Amount of current monthly benefit earned prior to 5/1/2007 $ 4,032.42 

Amount of current monthly benefit earned on and after 5/1/2007 $ 455.36 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 23

Form of pension Joint and 50% Survivor

Calculation of 110% of PBGC Guarantee

Current Benefit Survivor Benefit

Current monthly benefit, without regard to LRF $ 4,487.78 $ 2,243.89 

PBGC accrual rate $ 195.12 $ 97.56 

PBGC guaranteed accrual rate $ 35.75 $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 822.25 $ 822.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 904.48 $ 904.48 

Calculation of Monthly Benefit under Proposed Suspension

Current Benefit Survivor Benefit

Current monthly benefit $ 4,487.78 $ 2,243.89 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 645.19 $ 322.59 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 3,387.23 $ 1,693.62 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 455.36 $ 227.68 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 3,842.59 $ 1,921.30 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 3,842.59 $ 1,921.30 

Step 5: Step 4 or disability benefit if greater $ 3,890.44 $ 1,921.30 

Months from age 80 (at suspension date, max 60 mos) 60 60

Monthly benefit after age-based limitation $ 3,890.44 $ 1,921.30 

Final Monthly Benefit under Proposed Suspension $ 3,890.44 $ 1,921.30 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

Exhibit XII - Disability-based limitation for an individual is currently receiving a retirement 

benefit that is treated like a disability benefit due to the October 2016 settlement

CPTF-DV000065
Suspension Limitation: Disability Benefit

Date of birth 2/14/1958

Date of retirement (DOR) 9/1/2013

Age at retirement date 55 years, 6 months

Age at suspension date 62 years, 5 months

Disabled? Yes

Current monthly benefit $ 2,720.67 

Protected disability benefit $ 2,720.67 

Amount of current monthly benefit earned prior to 5/1/2007 $ 2,720.67 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 19

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 2,720.67 

PBGC accrual rate $ 143.19 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 679.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 747.18 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 2,720.67 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 435.31 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 2,285.36 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 2,285.36 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 2,285.36 

Step 5: Step 4 or disability benefit if greater $ 2,720.67 

Months from age 80 (at suspension date, max 60 mos) 60

Monthly benefit after age-based limitation $ 2,720.67 

Final Monthly Benefit under Proposed Suspension $ 2,720.67 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? Yes

Age-based limit? No

Exhibit XIII - Group E1 retiree who is between age 75 and 79 as of 7/31/2020

Suspension Limitation: Age-based Limitation

CPTF-DV000066
Date of birth 5/31/1944

Date of retirement (DOR) 8/1/2012

Age at retirement date 68 years 2 months

Age at suspension date 76 years 2 months

Disabled? No

Current monthly benefit $ 672.42 

Amount of current monthly benefit earned prior to 5/1/2007 $ 672.42 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.4464

Total years of service as of April 30, 2019 10

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 464.89 

PBGC accrual rate $ 46.49 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 357.50 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 393.25 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 672.42 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 107.59 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 564.83 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 564.83 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 564.83 

Months from age 80 (at suspension date, max 60 mos) 46

Monthly benefit after age-based limitation $ 589.93 

Final Monthly Benefit under Proposed Suspension $ 589.93 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

 

CPTF-DV000067
Exhibit XIV - Beneficiary of a group E1 retiree who is between age 75 and 79 as of 7/31/2020

Suspension Limitation: Age-based Limitation

Participant date of birth 3/23/1943

Beneficiary date of birth 2/27/1943

Date of retirement (DOR) 4/1/2005

Participant Age at retirement date 62 years, 0 months

Spouse Age at suspension date 77 years, 5 months

Disabled? No

Current monthly benefit $ 640.35 

Amount of current monthly benefit earned prior to 5/1/2007 $ 640.35 

Amount of current monthly benefit earned on and after 5/1/2007 $ - 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 7

Form of pension Survivor Benefit (50% Joint & Survivor)

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 640.35 

PBGC accrual rate $ 91.48 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 250.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 275.28 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 640.35 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 102.46 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 537.89 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ - 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 537.89 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 537.89 

Months from age 80 (at suspension date, max 60 mos) 31

Monthly benefit after age-based limitation $ 587.41 

Final Monthly Benefit under Proposed Suspension $ 587.41 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

 

CPTF-DV000068
Exhibit XV - Group E3 retiree who is between age 75 and 79 as of 7/31/2020

Suspension Limitation: Age-based Limitation

Date of birth 2/14/1942

Date of retirement (DOR) 5/1/2008

Age at retirement date 66 years, 2 months

Age at suspension date 78 years, 5 months

Disabled? No

Current monthly benefit $ 1,212.58 

Amount of current monthly benefit earned prior to 5/1/2007 $ 1,093.01 

Amount of current monthly benefit earned on and after 5/1/2007 $ 119.57 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 7

Form of pension Single Life

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 1,212.58 

PBGC accrual rate $ 173.23 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 250.25 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 275.28 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 1,212.58 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 174.88 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 918.13 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 119.57 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 1,037.70 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 1,037.70 

Months from age 80 (at suspension date, max 60 mos) 19

Monthly benefit after age-based limitation $ 1,157.20 

Final Monthly Benefit under Proposed Suspension $ 1,157.20 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

 

CPTF-DV000069
Exhibit XVI - Beneficiary of a group E3 retiree who is between age 75 and 79 as of 7/31/2020 

Suspension Limitation: Age-based Limitation

Beneficiary date of birth 8/23/1940

Date of retirement (DOR) 7/1/2004

Age at retirement date 63 years, 10 months

Age at suspension date 79 years, 11 months

Disabled? No

Current monthly 

benefit $ 952.66 

Amount of current monthly benefit earned prior to 5/1/2007 $ 933.39 

Amount of current monthly benefit earned on and after 5/1/2007 $ 19.27 

Late retirement factor (LRD) applied to current benefit 1.0000

Total years of service as of April 30, 2019 8

Form of pension Beneficiary

Calculation of 110% of PBGC Guarantee

Current monthly benefit, without regard to LRF $ 952.66 

PBGC accrual rate $ 119.08 

PBGC guaranteed accrual rate $ 35.75 

PBGC guaranteed benefit (no greater than current benefit) $ 286.00 

110% of PBGC guaranteed benefit (no greater than current benefit) $ 314.60 

Calculation of Monthly Benefit under Proposed Suspension

Current monthly benefit $ 952.66 

MPRA Reduction for benefit earned prior to 5/1/2007 $ 149.34 

Step 1: Benefit earned prior to 5/1/2007 reduced for MPRA $ 784.05 

Step 2: Benefit earned after 5/1/2007 (not reduced for MPRA) $ 19.27 

Step 3: Current monthly benefit reduced for MPRA (Step 1 + Step 2) $ 803.32 

Step 4: Step 3 or 110% of PBGC guaranteed benefit if greater $ 803.32 

Months from age 80 (at suspension date, max 60 mos) 1

Monthly benefit after age-based limitation $ 950.17 

Final Monthly Benefit under Proposed Suspension $ 950.17 

Summary of Applicable Federal Limitations

110% of PBGC guaranteed limit? No

Disability limit? No

Age-based limit? Yes

CPTF-DV000070
Proposed Suspension Is Reasonably Estimated to

Enable the Pension Plan to Avoid Insolvency Utilizing Stochastic Projections

This Document 10.1 summarizes the results of 2,000 stochastic trials. Each trial consists of a 

projection of the market value of Plan assets for the plan years ending April 30, 2020 through 

2065.

The probability of maintaining solvency over the extended period is: 51.7%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are shown 

below in graphical format in Exhibit I and in tabular format in Exhibit II. 

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

CPTF-DV000071
Exhibit I – Graphical Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Utilizing Stochastic Projections

CPTF-DV000072

"' C: 

.Q 

·-c:o 

$3.0 

$2.5 

$2.0 

$1.5 

$1.0 

$0.5 

$0.0 

-$0.5 

-$1.0 

-$1.5 

-$2.0 

Projected Market Value of Plan Assets - 2,000 Trials 

m M m ~ ~ m M m ~ ~ m M m ~ ~ m M m ~ ~ m M m ~ ~ 

M N N N N N m m m M M ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N N 

- 5th%-ile - 25th%-ile - 50th%-ile - 75th%-ile - 95th%-ile 
Exhibit II – Tabular Presentation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Utilizing Stochastic Projections

Plan Year 

Ending

Market Value of Plan Assets – 2,000 Trials

5th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2020 $779,361,598 $779,361,598 $779,361,598 $779,361,598 $779,361,598 

4/30/2021 $669,264,529 $746,868,272 $805,044,495 $868,552,013 $972,688,294 

4/30/2022 $637,349,852 $741,475,868 $828,642,275 $924,905,761 $1,091,481,207 

4/30/2023 $592,822,868 $728,567,924 $835,193,763 $963,316,983 $1,188,239,522 

4/30/2024 $560,572,658 $715,297,410 $840,750,574 $992,196,012 $1,268,790,507 

4/30/2025 $521,873,016 $695,043,848 $848,354,307 $1,018,035,025 $1,353,497,507 

4/30/2026 $484,830,324 $681,798,299 $834,153,892 $1,044,953,442 $1,443,399,657 

4/30/2027 $436,547,388 $655,254,535 $827,100,029 $1,056,660,343 $1,525,092,901 

4/30/2028 $384,895,464 $619,279,895 $828,251,906 $1,068,730,372 $1,613,968,125 

4/30/2029 $342,484,522 $590,007,455 $812,982,268 $1,074,706,000 $1,686,107,711 

4/30/2030 $286,121,067 $548,858,474 $796,469,784 $1,102,644,294 $1,745,181,564 

4/30/2031 $228,629,750 $509,594,853 $780,854,823 $1,118,720,542 $1,880,764,996 

4/30/2032 $164,503,952 $471,138,015 $766,845,098 $1,132,921,282 $2,001,286,413 

4/30/2033 $94,244,776 $430,501,387 $739,752,515 $1,148,467,332 $2,116,554,979 

4/30/2034 $20,094,738 $380,992,973 $724,560,429 $1,150,607,733 $2,226,219,088 

4/30/2035 insolvent $335,271,477 $690,657,808 $1,168,344,226 $2,392,290,072 

4/30/2036 $277,080,727 $655,552,804 $1,203,235,159 $2,543,429,820 

4/30/2037 $220,331,839 $618,521,722 $1,203,518,474 $2,619,821,085 

4/30/2038 $150,780,093 $588,267,081 $1,221,733,157 $2,784,596,349 

4/30/2039 $83,819,678 $553,936,652 $1,226,120,862 $3,029,603,458 

4/30/2040 $12,447,449 $521,153,060 $1,269,244,842 $3,225,321,367 

4/30/2041 insolvent $487,084,172 $1,274,975,825 $3,285,971,181 

4/30/2042 $458,937,541 $1,297,851,980 $3,437,038,729 

4/30/2043 $414,245,022 $1,344,704,221 $3,697,674,818 

4/30/2044 $379,012,636 $1,395,298,679 $3,990,429,491 

4/30/2045 $345,427,306 $1,441,520,493 $4,093,285,728 

4/30/2046 $324,579,581 $1,454,241,373 $4,340,728,392 

4/30/2047 $279,367,590 $1,524,726,131 $4,725,488,874 

4/30/2048 $251,410,829 $1,593,393,704 $5,140,370,177 

4/30/2049 $231,686,968 $1,673,843,807 $5,294,872,190 

4/30/2050 $214,407,338 $1,736,441,853 $5,978,197,380 

4/30/2051 $183,828,332 $1,850,433,328 $6,758,963,735 

4/30/2052 $172,552,178 $1,963,084,882 $7,109,354,315 

CPTF-DV000073
Exhibit II – Tabular Presentation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Utilizing Stochastic Projections (Cont.)

Plan Year 

Ending

Market Value of Plan Assets – 2,000 Trials

5th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2053 $161,974,988 $2,093,538,571 $7,764,070,926 

4/30/2054 $149,048,056 $2,337,622,083 $8,422,667,085 

4/30/2055 $140,450,782 $2,473,042,886 $8,801,732,145 

4/30/2056 $138,399,698 $2,613,493,598 $9,508,114,222 

4/30/2057 $150,390,788 $2,790,241,562 $10,326,055,659 

4/30/2058 $149,317,709 $2,909,488,046 $11,443,132,631 

4/30/2059 $169,462,281 $3,169,403,501 $11,823,481,678 

4/30/2060 $200,732,059 $3,459,923,600 $13,112,273,784 

4/30/2061 $222,712,665 $3,776,339,323 $14,760,534,122 

4/30/2062 $249,213,026 $4,108,726,999 $15,959,668,373 

4/30/2063 $283,174,386 $4,330,784,247 $17,623,103,133 

4/30/2064 $313,186,409 $4,729,366,071 $19,161,176,308 

4/30/2065 $351,155,351 $5,244,356,006 $21,370,183,900 

CPTF-DV000074
Demonstration That the Proposed Suspension Is Not Projected To Materially Exceed the Level 

Necessary to Avoid Insolvency Based On a Deterministic Projection

As required by Revenue Procedure 2017-43, Section 4.03, the application must include a 

deterministic projection demonstrating that, if the dollar amount of the proposed suspension for 

each participant and beneficiary was reduced by the greater of: 

• 5% of the reduction in payment proposed for that participant or beneficiary, or

• 2% of that participant’s or beneficiary’s payment determined without regard to the

proposed reduction,

then the Plan would not be reasonably estimated to avoid insolvency. 

Exhibit I provides plan-year-by-plan-year projections demonstrating projected insolvency and 

identification of the available resources during each of those years.

The illustration is based on the actuary’s interpretation of the requirements under Revenue 

Procedure 2017-43, Section 4.03. 

Checklist Item #25 describes each of the assumptions used, as required under Revenue 

Procedure 2017-43, Section 4.02(3).

CPTF-DV000075
Exhibit I – Deterministic Projection Based on Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03

The projected Market Value of Assets and Solvency Ratio for Plan Years ending April 30, 2020 through April 30, 2047 are shown 

below:

Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2020 $770,972,113 $120,850,224 $1,333,196 $0 $154,780,950 $6,101,734 $47,088,749 $779,361,598 $934,142,548 6.04

4/30/2021 $779,361,598 $120,000,000 $36,159 $963,841 $146,055,136 $4,090,000 $49,711,287 $799,927,749 $945,982,885 6.48

4/30/2022 $799,927,749 $117,000,000 $36,159 $963,841 $146,709,647 $4,182,025 $50,926,324 $817,962,401 $964,672,048 6.58

4/30/2023 $817,962,401 $105,000,000 $36,159 $963,841 $150,107,715 $4,276,121 $51,595,081 $821,173,646 $971,281,361 6.47

4/30/2024 $821,173,646 $105,000,000 $36,159 $763,841 $153,788,981 $4,372,334 $51,674,544 $820,486,875 $974,275,856 6.34

4/30/2025 $820,486,875 $105,000,000 $36,159 $613,841 $157,649,695 $4,470,712 $51,496,359 $815,512,827 $973,162,522 6.17

4/30/2026 $815,512,827 $105,000,000 $36,159 $613,841 $161,323,359 $4,571,303 $51,050,382 $806,318,547 $967,641,906 6.00

4/30/2027 $806,318,547 $105,000,000 $36,159 $613,841 $164,781,620 $4,674,157 $50,337,018 $792,849,788 $957,631,408 5.81

4/30/2028 $792,849,788 $105,000,000 $36,159 $613,841 $168,212,307 $4,779,326 $49,346,633 $774,854,788 $943,067,095 5.61

4/30/2029 $774,854,788 $105,000,000 $36,159 $613,841 $171,441,739 $4,886,861 $48,068,507 $752,244,695 $923,686,434 5.39

4/30/2030 $752,244,695 $105,000,000 $36,159 $613,841 $174,311,352 $4,996,815 $53,656,171 $732,242,699 $906,554,051 5.20

4/30/2031 $732,242,699 $105,000,000 $36,159 $613,841 $176,729,580 $5,109,243 $52,061,122 $708,114,998 $884,844,578 5.01

4/30/2032 $708,114,998 $105,000,000 $36,159 $613,841 $178,646,190 $5,224,201 $50,175,360 $680,069,967 $858,716,157 4.81

4/30/2033 $680,069,967 $105,000,000 $36,159 $613,841 $180,061,400 $5,341,746 $48,014,505 $648,331,326 $828,392,726 4.60

4/30/2034 $648,331,326 $105,000,000 $12,056 $637,944 $181,062,279 $5,461,935 $45,592,066 $613,049,178 $794,111,457 4.39

4/30/2035 $613,049,178 $105,000,000 $7,236 $642,764 $181,480,132 $5,584,829 $42,925,627 $574,559,844 $756,039,976 4.17

4/30/2036 $574,559,844 $105,000,000 $7,236 $642,764 $181,451,391 $5,710,488 $40,035,293 $533,083,258 $714,534,649 3.94

4/30/2037 $533,083,258 $105,000,000 $7,236 $642,764 $180,927,529 $5,838,974 $36,939,375 $488,906,130 $669,833,659 3.70

4/30/2038 $488,906,130 $105,000,000 $3,618 $646,382 $179,935,456 $5,970,351 $33,658,367 $442,308,690 $622,244,146 3.46

4/30/2039 $442,308,690 $105,000,000 $0 $650,000 $178,304,466 $6,104,684 $30,219,684 $393,769,224 $572,073,690 3.21

4/30/2040 $393,769,224 $105,000,000 $0 $650,000 $176,525,701 $6,242,039 $26,640,777 $343,292,261 $519,817,962 2.94

4/30/2041 $343,292,261 $105,000,000 $0 $650,000 $174,089,312 $6,382,485 $22,941,102 $291,411,566 $465,500,878 2.67

Exhibit I – Deterministic Projection Based on Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03

(cont.)

CPTF-DV000076
Plan Year

Ending

1. Beginning

Assets

2. Employer

Contributions

3. EWL 

Payments

Prior 

Wthdrwls

4. EWL 

Payments 

Future 

Wthdrwls

5. Benefit 

Payments

6. 

Expenses

7. 

Investment

Income

8. Ending

Assets

9. Resources

(1)+(2)+(3)+(4)-

(6)+(7)

Solvency

Ratio

(9)/(5)

4/30/2042 $291,411,566 $105,000,000 $0 $650,000 $171,396,987 $6,526,091 $19,145,627 $238,284,115 $409,681,102 2.39

4/30/2043 $238,284,115 $105,000,000 $0 $650,000 $168,217,951 $6,672,928 $15,274,776 $184,318,012 $352,535,963 2.10

4/30/2044 $184,318,012 $105,000,000 $0 $650,000 $164,541,804 $6,823,069 $11,056,622 $129,659,761 $294,201,565 1.79

4/30/2045 $129,659,761 $105,000,000 $0 $650,000 $160,672,096 $6,976,588 $7,202,211 $74,863,288 $235,535,384 1.47

4/30/2046 $74,863,288 $105,000,000 $0 $650,000 $156,576,203 $7,133,561 $3,345,839 $20,149,363 $176,725,566 1.13

4/30/2047 $20,149,363 $105,000,000 $0 $650,000 $152,118,905 $7,294,066 -$491,445 insolvent $118,013,852 0.78

CPTF-DV000077
Demonstration That the Proposed Suspension Is Not Projected To Materially Exceed the Level 

Necessary to Avoid Insolvency Based On a Stochastic Projection

As required by Revenue Procedure 2017-43, Section 4.03, the application must include a 

demonstration utilizing stochastic projections that, if the dollar amount of the proposed 

suspension for each participant and beneficiary was reduced by the greater of:

• 5% of the reduction in payment proposed for that participant or beneficiary, or 

• 2% of that participant’s or beneficiary’s payment determined without regard to the 

proposed reduction, 

then the Plan would not be reasonably estimated to avoid insolvency.

This Document 11.2 summarizes the results of 2,000 stochastic trials. Each trial consists of a 

projection of the market value of Plan assets for the plan years ending April 30, 2020 through 

2065 assuming implementation of the hypothetical reduced suspension as outlined above.

The probability of maintaining solvency over the extended period is: 44.7%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are shown 

below in graphical format in Exhibit I and in tabular format in Exhibit II. 

Checklist Item #25 describes the actuarial assumptions and methodology used in the reports filed 

with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

CPTF-DV000078
Exhibit I – Graphical Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03 Utilizing 

Stochastic Projections

CPTF-DV000079

"' C: 

.Q 

-

co 

$3.0 

$2.5 

$2.0 

$1.S 

$1.0 

$0.5 

$0.0 

-$05 

-$1.0 

-$1.S 

-$2.0 

Projected Market Value of Plan Assets - 2,000 Trials 

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N N 

- 5th %-ile - 25th %-ile - S0th %-ile 75th %-ile - 95th %-ile 
Exhibit II – Tabular Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03 Utilizing 

Stochastic Projections

Plan Year 

Ending

Market Value of Plan Assets – 2,000 Trials

5th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2020 $779,361,598 $779,361,598 $779,361,598 $779,361,598 $779,361,598

4/30/2021 $667,221,293 $744,715,580 $802,809,746 $866,227,689 $970,217,090

4/30/2022 $632,641,472 $736,376,575 $823,406,205 $919,427,703 $1,085,662,605

4/30/2023 $585,002,088 $720,495,893 $826,699,083 $954,508,717 $1,178,083,420

4/30/2024 $550,198,182 $704,357,664 $828,415,889 $979,408,335 $1,253,992,837

4/30/2025 $507,755,048 $679,790,216 $831,714,291 $1,000,701,662 $1,334,304,495

4/30/2026 $468,669,428 $661,720,973 $814,072,698 $1,020,642,190 $1,419,105,878

4/30/2027 $415,873,275 $632,200,856 $801,976,862 $1,029,710,263 $1,493,739,166

4/30/2028 $360,836,916 $591,764,498 $797,077,292 $1,034,322,303 $1,576,390,147

4/30/2029 $312,523,112 $557,985,109 $775,151,642 $1,032,215,181 $1,637,835,605

4/30/2030 $256,018,462 $508,116,715 $753,790,843 $1,055,817,607 $1,688,928,137

4/30/2031 $190,475,901 $464,144,744 $730,918,708 $1,058,451,312 $1,816,663,049

4/30/2032 $119,707,730 $421,051,807 $708,415,585 $1,069,570,717 $1,932,630,611

4/30/2033 $38,396,284 $373,703,893 $673,879,421 $1,068,308,000 $2,027,686,895

4/30/2034 insolvent $313,114,218 $646,033,169 $1,059,638,053 $2,116,811,425

4/30/2035 $258,328,148 $604,110,161 $1,072,442,740 $2,268,534,185

4/30/2036 $191,556,039 $558,487,175 $1,089,323,638 $2,401,729,525

4/30/2037 $125,240,654 $518,162,104 $1,084,101,192 $2,477,020,331

4/30/2038 $47,696,830 $475,182,616 $1,085,406,056 $2,619,529,787

4/30/2039 insolvent $422,135,857 $1,075,720,092 $2,827,070,316

4/30/2040 $377,616,454 $1,081,005,881 $3,018,760,316

4/30/2041 $339,382,435 $1,069,017,082 $3,068,552,285

4/30/2042 $289,304,017 $1,100,939,875 $3,206,065,480

4/30/2043 $232,957,646 $1,130,586,803 $3,395,248,129

4/30/2044 $168,993,527 $1,151,102,570 $3,680,964,567

4/30/2045 $113,258,794 $1,157,092,776 $3,786,503,007

4/30/2046 $60,194,817 $1,172,258,405 $3,998,977,775

4/30/2047 $7,936,183 $1,199,233,635 $4,353,475,524

4/30/2048 insolvent $1,231,612,371 $4,664,224,114

4/30/2049 $1,264,818,745 $4,740,007,575

4/30/2050 $1,329,156,297 $5,321,288,629

4/30/2051 $1,397,492,609 $5,975,233,759

4/30/2052 $1,460,803,923 $6,323,552,555

CPTF-DV000080
Exhibit II – Tabular Representation of Projected Market Value of Plan Assets Recognizing 

Proposed Suspension Reduced Pursuant to Revenue Procedure 2017-43, Section 4.03 Utilizing 

Stochastic Projections (Cont.)

Plan Year 

Ending

Market Value of Plan Assets – 2,000 Trials

5th %-ile 25th %-ile 50th %-ile 75th %-ile 95th %-ile

4/30/2053 $1,560,341,743 $6,918,272,776

4/30/2054 $1,686,010,917 $7,341,272,004

4/30/2055 $1,843,742,789 $7,868,883,618

4/30/2056 $1,921,231,805 $8,438,496,928

4/30/2057 $2,048,151,508 $9,274,204,517

4/30/2058 $2,176,923,683 $10,010,024,674

4/30/2059 $2,376,745,863 $10,502,519,389

4/30/2060 $2,536,986,910 $11,803,045,885

4/30/2061 $2,798,297,334 $12,940,112,049

4/30/2062 $3,038,100,262 $14,158,770,842

4/30/2063 $3,230,055,620 $15,402,914,550

4/30/2064 $3,421,001,780 $17,010,926,566

4/30/2065 $3,679,321,669 $18,952,717,554

CPTF-DV000081
The Pension Plan’s Demonstration

of Equitable Distribution

Effect of Proposed Suspension on the Plan in the Aggregate

Exhibit I provides the information on the effect of the suspension required by sub-section 

4.04(1)(a) of Revenue Procedure 2017-43 on an aggregate basis. 

Exhibit II provides the distribution of participants by benefit reduction percentage on an 

aggregate basis as required by sub-section 4.04(1)(b) of Revenue Procedure 2017-43.

Effect of Proposed Suspension on the Plan on a Group-by-group Basis

Exhibit III provides the information on the effect of the suspension described in sub-section 

4.04(1)(a) of Revenue Procedure 2017-43 broken out according to the groupings described in 

Checklist Item #2, as required by sub-section 4.04(2)(a) of Revenue Procedure 2017-43. 

Exhibits IV through XV provide the distribution of participants by benefit reduction percentage

described in sub-section 4.04(1)(b) of Revenue Procedure 2017-43 on a group-by-group basis, as 

required by sub-section 4.04(2)(a) of Revenue Procedure 2017-43. Note that groups A1, C2 and 

D2 do not include any participants, so there are no exhibits included for these groups. 

Please refer to the following table: 

Group Description Exhibit

A1 Active, pre-5/1/2007 accruals only n/a

A2 Active, post-5/1/2007 accruals only IV

A3 Active, pre- and post-5/1/2007 accruals V

B1 Deferred vested, pre-5/1/2007 accruals only VI

B2 Deferred vested, post-5/1/2007 accruals only VII

B3 Deferred vested, pre- and post-5/1/2007 accruals VIII

C1 Retiree with benefit reduction effective 8/1/2013, pre-5/1/2007 accruals 

only IX

C2 Retiree with benefit reduction effective 8/1/2013, post-5/1/2007 

accruals only n/a

C3 Retiree with benefit reduction effective 8/1/2013, pre- and post5/1/2007 accruals X 

D1 Beneficiary of the October 2016 disability lawsuit settlement, pre5/1/2007 accruals only XI

D2 Beneficiary of the October 2016 disability lawsuit settlement, post5/1/2007 accruals only n/a

D3 Beneficiary of the October 2016 disability lawsuit settlement, pre- and 

post-5/1/2007 accruals XII

E1 Retiree not included in a C or D group, pre-5/1/2007 accruals only XIII

E2 Retiree not included in a C or D group, post-5/1/2007 accruals only XIV

CPTF-DV000082
Group Description Exhibit

E3 Retiree not included in a C or D group, pre- and post-5/1/2007 accruals XV

Handling of Non-Participants

Employees who have not yet satisfied the Plan’s initial participation requirements have been 

excluded from this analysis. There were 945 non-participants included in the valuation runs. 

None of these people had accruals before 5/1/2007 and therefore they are not impacted by the 

proposed suspension. 

Identification of Factors Taken Into Account

See Application at Section 4.04

Explanation as to Why No Factors Listed in IRC Section 432(e)(9)(D)(vi)(I) through (XI) Were 

Taken Into Account

See Application at Section 4.04

Relevance of Factors Not Listed in IRC Section 432(e)(9)(D)(vi)(I) through (XI)

See Application at Section 4.04

Differences in Treatment Among Groups Result from Reasonable Application of Relevant 

Factors

See Application at Section 4.04

CPTF-DV000083
Exhibit I –Effect of Suspension – Aggregate Basis

Group Count

Average Monthly

Benefit Before 

Suspension

Average Monthly

Benefit After 

Suspension

PV Reduction in 

Benefits1

All 18,392 $ 1,465.71 $ 1,273.31 $ 279,427,436

 

1 Estimated using a “blended form” of expected benefit election

CPTF-DV000084

I I I 
Exhibit II – Distribution of Participants by Benefit Reduction Percentage – Aggregate Basis

Benefit Reduction

Percentage Count

Percentage

of Total

None 5,033 27.37%

0.001% to 10% 3,541 19.25%

10.001% to 20% 6,132 33.34%

20.001% to 30% 3,686 20.04%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000085
Exhibit III – Effect of Suspension – Group-by-group Basis

Group Count

Average Monthly

Benefit Before 

Suspension

Average Monthly

Benefit After 

Suspension

PV Reduction in 

Benefits2

A1 0 $ 0.00 $ 0.00 $ 0

A2 2,077 270.03 270.03 0

A3 2,829 2,794.48 2,500.17 46,047,084

B1 3,603 612.36 462.23 30,992,826

B2 274 145.36 145.36 0

B3 2,217 1,505.65 1,179.66 28,512,599

C1 44 1,563.85 1,401.42 939,537

C2 0 0.00 0.00 0

C3 499 3,909.41 3,495.61 27,571,953

D1 23 1,986.98 1,676.31 689,509

D2 0 0.00 0.00 0

D3 277 2,646.37 2,272.70 9,633,888

E1 5,401 1,319.78 1,189.70 82,162,578

E2 6 126.49 126.49 0

E3 1,142 2,608.97 2,245.11 52,877,462

 

2 Estimated using a “blended form” of expected benefit election

CPTF-DV000086
Exhibit IV – Distribution of Participants by Benefit Reduction Percentage – Group A2

Benefit Reduction

Percentage Count

Percentage

of Total

None 2,077 100.00%

0.001% to 10% 0 0.00%

10.001% to 20% 0 0.00%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000087
Exhibit V – Distribution of Participants by Benefit Reduction Percentage – Group A3

Benefit Reduction

Percentage Count

Percentage

of Total

None 5 0.18%

0.001% to 10% 1,249 44.15%

10.001% to 20% 1,575 55.67%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000088
Exhibit VI – Distribution of Participants by Benefit Reduction Percentage – Group B1

Benefit Reduction

Percentage Count

Percentage

of Total

None 246 6.83%

0.001% to 10% 748 20.76%

10.001% to 20% 316 8.77%

20.001% to 30% 2,293 63.64%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000089
Exhibit VII – Distribution of Participants by Benefit Reduction Percentage – Group B2

Benefit Reduction

Percentage Count

Percentage

of Total

None 274 100.00%

0.001% to 10% 0 0.00%

10.001% to 20% 0 0.00%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000090
Exhibit VIII – Distribution of Participants by Benefit Reduction Percentage – Group B3

Benefit Reduction

Percentage Count

Percentage

of Total

None 89 4.01%

0.001% to 10% 283 12.77%

10.001% to 20% 452 20.39%

20.001% to 30% 1,393 62.83%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000091
Exhibit IX – Distribution of Participants by Benefit Reduction Percentage – Group C1

Benefit Reduction

Percentage Count

Percentage

of Total

None 1 2.27%

0.001% to 10% 5 11.36%

10.001% to 20% 38 86.37%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000092
Exhibit X – Distribution of Participants by Benefit Reduction Percentage – Group C3

Benefit Reduction

Percentage Count

Percentage

of Total

None 1 0.20%

0.001% to 10% 77 15.43%

10.001% to 20% 421 84.37%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000093
Exhibit XI – Distribution of Participants by Benefit Reduction Percentage – Group D1

Benefit Reduction

Percentage Count

Percentage

of Total

None 1 4.35%

0.001% to 10% 0 0.00%

10.001% to 20% 22 95.65%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000094
Exhibit XII – Distribution of Participants by Benefit Reduction Percentage – Group D3

Benefit Reduction

Percentage Count

Percentage

of Total

None 12 4.33%

0.001% to 10% 6 2.17%

10.001% to 20% 259 93.50%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000095
Exhibit XIII – Distribution of Participants by Benefit Reduction Percentage – Group E1

Benefit Reduction

Percentage Count

Percentage

of Total

None 2,306 42.70%

0.001% to 10% 1,069 19.79%

10.001% to 20% 2,026 37.51%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000096
Exhibit XIV – Distribution of Participants by Benefit Reduction Percentage – Group E2

Benefit Reduction

Percentage Count

Percentage

of Total

None 6 100.00%

0.001% to 10% 0 0.00%

10.001% to 20% 0 0.00%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000097
Exhibit XV – Distribution of Participants by Benefit Reduction Percentage – Group E3

Benefit Reduction

Percentage Count

Percentage

of Total

None 15 1.31%

0.001% to 10% 104 9.11%

10.001% to 20% 1,023 89.58%

20.001% to 30% 0 0.00%

30.001% to 40% 0 0.00%

40.001% to 50% 0 0.00%

50.001% to 60% 0 0.00%

60.001% to 70% 0 0.00%

70.001% to 80% 0 0.00%

80.001% to 90% 0 0.00%

90.001% to 100% 0 0.00%

CPTF-DV000098