Central States, Southeast and Southwest Areas Pension Plan

Items #20-22 

Item #20 

Does the application describe how the plan sponsor took into account – or did not take into 

account – the factors listed in section 5.02 in the determination that all reasonable measures were 

taken to avoid insolvency. 

See section 5.03. 

The required description is contained in the attached document number 20. 

Item #21 

Does the application describe how the plan sponsor took into account – or did not take into 

account – in the determination that all reasonable measures have been taken to avoid insolvency 

the impact of

• benefit and contribution levels on retaining active participants and bargaining groups under

the plan, and 

• past and anticipated contribution increases under the plan on employer attrition and

retention levels.

See section 5.03. 

The required description is contained in the attached document number 20. 

Item #22 

Does the application include a discussion of any other factors the plan sponsor took into account 

including how and why those factors were taken into account. 

See section 5.04. 

The required discussion is contained in the attached document number 20. 

20.0
SECTION 5

.03 How plan factors were taken into account. For each of the factors listed under 

section 5.02 of this revenue procedure and the factors described in 

§ 432(e)(9)(C)(ii)(VIII) (the impact of benefit and contribution levels on retaining

active participants and bargaining groups under the plan) and § 432(e)(9)(C)(ii)(IX) 

(the impact of past and anticipated contribution increases under the plan on 

employer attrition and retention levels), the application must describe how that 

factor was taken into account (or why that factor was not taken into account) in the 

plan sponsor’s determination that all reasonable measures have been taken to avoid 

insolvency. 

(1) For the past 10 plan years immediately preceding the plan year in which the application 

is submitted:

(a) Contribution levels. 

As explained in the discussion required by Rev. Proc. 5.01 (document number 18), the 

Board of Trustees has, over the 10 years immediately preceding the year of this application, 

taken all reasonable measures with respect to contribution levels. The Board of Trustees 

increased contribution levels as much as their research, analysis, and experience indicated 

Contributing Employers could bear without going out of business or withdrawing from the Plan. 

From 2005 to 2014, the average rate at which Contributing Employers contributed to the 

Fund increased 83.2% (a 57.9% increase after adjustment for inflation), from a rate of $120.42 

per week in January 2005 to a rate of $220.63 per week in December 2014.1 Since 2004, 

pension contribution rates under the National Master Freight Agreement (“NMFA”) and the 

National Master Auto Transport Agreement (“NMATA”) have increased by 100% (70% after 

adjustment for inflation). Active participants under the NMFA and NMATA currently have 

contributions made to the Fund on their behalf at the maximum contribution rate currently 

required under the Fund’s rehabilitation plan—$342 per week for participants covered by NMFA 

and $348 per week for those covered by NMATA.2 

As discussed in the response to Rev. Proc. 5.01 (document number 18), the Fund in 2010 

engaged consulting firm SRR to study the ability of the Fund’s Contributing Employers to 

continue to absorb contribution rate increases. SRR concluded that a number of the Fund’s 

larger, publicly-traded Employers could not reasonably be expected to absorb additional 

contribution rate increases. On this basis, in November 2010, the Board of Trustees froze the top 

NMFA and NMATA contribution levels at the rates indicated above. For other Employers, the 

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

rehabilitation plan’s Primary Schedule without the need for additional rate increases.

1 These figures exclude the special case of YRC, discussed in detail below.

2 Some of these participants are covered by local agreements that mirror the contribution rates 

under NMFA or NMATA.

20.1
As of May 2015, just 26 bargaining units representing 259 active participants (out of a 

total active participant population of approximately 65,000) operated under the Default 

Schedule. All other actives, except for those employed by YRC, Inc. and its affiliates,

3 operated

under the Primary Schedule.

Attached as Tab A is a schedule showing the following data relating to the Fund for each 

of the 10 years from 2005 to 2014: 

a) total Employer contributions;

b) total contribution base units;

c) average contributions;

d) withdrawal liability payments; and

e) rate of return or assets.

When designing the benefit suspension plan, the Board of Trustees re-examined 

contribution levels over the past 10 plan years and considered whether, when applied in 

conjunction with the benefit suspensions, contribution increases that previously had been 

unreasonable became reasonable when applied over a longer time horizon. See Chart of Effect

of Time Horizon on Plan Changes, document number 18, page 18.11 (“Time Horizon Chart”). 

This could happen because contribution rate increases improve funding levels gradually over 

many years. Increases that provide minimal value when a plan is unable to avoid insolvency 

over a short time horizon can provide considerable value once the plan implements benefit 

suspensions, and the duration of the increases is not limited by a projected insolvency date. 

The Board of Trustees obtained the views of SRR in 2015 regarding whether the Fund’s 

Contributing Employers could, at this time, withstand contribution rate increases in light of the 

improving economy. As explained below in the section titled “The impact of past and 

anticipated contribution increases under the plan on employer attrition and retention levels,” the 

Board of Trustees determined that additional contribution increases, when made in conjunction 

with the plan of benefit suspensions, would now constitute reasonable measures to enable the 

Plan to avoid insolvency. 

(b) Levels of benefit accruals, including any prior reductions in the rate of benefit 

accruals.

The adjustments to the levels of benefit accruals that the Board of Trustees has made in 

response to declining funding levels are discussed in detail in the response to Rev. Proc. 5.01, 

document number 18. As explained therein, those measures, which included a reduction in the 

rate of benefit accrual from 2% of contributions to 1% of contributions, the freezing of early 

retirement / “and-out” pensions, increasing the plan’s minimum retirement age, and eliminating 

the possibility of bargaining up or making self-contributions, constituted reasonable measures 

with respect to reductions of benefits. 

3

 YRC, Inc. and its affiliates operate under the Distressed Employer Schedule, discussed in detail 

in the response to Rev. Proc. Section 5.01(document number 18).

20.2
When re-examining the levels of benefit accruals in conjunction with the formulation of 

the plan of benefit suspensions, the Board of Trustees considered whether additional reductions 

in benefit levels, which previously had been determined to be both counterproductive and to 

have an immaterial effect on the solvency of the Plan, would now be productive and effective

when applied in conjunction with the plan of benefit suspensions. Previously, when developing 

the rehabilitation plan, the Board of Trustees had determined, based in part on the views of the 

IBT (discussed in the response to Rev. Proc. 5.01), that reductions in the rate of benefit accrual 

below 1% would severely undermine the support of active participants for the Plan. In addition, 

in light of the Plan’s projected insolvency in the near future, there would be insufficient time for 

such a reduction in accrual rate to have a significant impact on the Plan’s solvency. 

Now, when made in conjunction with the plan of benefit suspensions, which allows the 

Plan to continue indefinitely, a reduction in the rate of future benefit accruals would have a 

significant impact on the Plan’s actuarial soundness. Although reductions in the rate of future 

benefit accruals still present the possibility of reducing support from active participants, the 

Board of Trustees determined that a reduction in future benefit accruals is necessary to avoid a 

projected insolvency while lessening the benefit suspensions applied to all participant groups. In 

doing so, the Board of Trustees considered the fact that the reduction in the accrual rate from 

1.0% to 0.75% is somewhat offset by the contribution rate increases, including rate increases for 

employers whose rates are presently frozen, that are anticipated under the proposed suspension 

plan. The Board of Trustees determined, with specific input from the Employee Trustees, that 

these accrual rates should be sufficient to continue the support of active participants for the 

Fund; however, the Trustees also determined that, if the future accrual rate were to be lowered to 

any significant extent below 0.75% of contributions (e.g., to 0.5%), there would be a serious risk 

of erosion of support for the Plan by the active participants and an increase in employer 

withdrawals. 

The Board of Trustees thus concluded that reducing the rate of future benefit accruals to 

0.75 percent of contributions in conjunction with the plan of benefit suspensions now constitutes 

a reasonable measure to avoid insolvency. 

(c) Prior reductions, if any, of adjustable benefits under § 432(e)(8).

The section responsive to Rev. Proc. 5.01 (document number 18) describes the reductions 

the Board of Trustees has made to adjustable benefits as they implemented and updated the 

rehabilitation plan as required under PPA. As authorized under PPA, adjustable benefits include 

essentially all benefits other than those already in pay status prior to 2008, disability benefits in 

pay status at any time, and accrued benefits payable at age 65. Under the current rehabilitation 

plan, the following events trigger a loss of adjustable benefits: 

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

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

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

20.3
The Fund’s actuary advises that in total, as of December 31, 2014, adjustable benefits 

with an accumulated present value of approximately $1.64 billion (as reflected in the Fund’s 

funding standard account) have been eliminated under these rehabilitation plan rules, including 

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

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

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

the Board of Trustees considered a more expansive rule that would have eliminated all PPA 

adjustable benefits of all active participants, but they determined that doing so would likely (a) 

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

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

and an acceleration of its projected insolvency. However, the Trustees froze early retirement and 

“and-out” pensions at an amount based on years of service earned at that point, while still 

allowing participants to grow into eligibility for a portion of those benefits by earning additional 

years of service. As discussed below in the section titled “The impact on plan solvency of the 

subsidies and ancillary benefits, if any, available to active participants”, the Fund’s actuary 

advised the Board of Trustees that further reductions in the adjustable benefits for active 

participants would not have a meaningful positive impact on the solvency of the Plan. 

(d) Any prior suspension of benefits under § 432(e)(9). 

Not applicable. The Board of Trustees has not previously submitted an application to 

suspend benefits under the Plan. 

(e) Measures undertaken by the plan sponsor to retain or attract 

contributing employers.

As explained in the detailed descriptions of reasonable measures taken over the past 10 

years, the Board of Trustees has taken a number of innovative steps to retain and attract 

contributing employers, including: 

• Adopting a Distressed Employer Schedule which allowed YRC to remain in the

Plan rather than withdraw and incur withdrawal liability sufficient to send the

employer into bankruptcy;

• Creating a hybrid plan whereby employers may withdraw, pay their withdrawal

liability in full, and re-enter the plan as New Employers in what is now a wellfunded pool of liabilities; and

• Freezing the maximum contribution rates during the financial crisis that began in

2008 and during the recovery period thereafter.

These measures are discussed in detail in the section responsive to Rev. Proc. 5.01 (document 

number 18). The Board of Trustees concluded that each of these measures to retain and attract 

Contributing Employers served to protect the Plan from further deterioration. 

20.4
(2) The impact on plan solvency of the subsidies and ancillary benefits, if any, available to 

active participants.

As noted above, the Fund for some time offered benefits that include early retirement 

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

January 1, 2004, however, the Board of Trustees froze early retirement and “and-out” pensions at 

an amount based on years of service earned at that point, while still allowing participants to grow 

into eligibility for those benefits by earning additional years of service. Although this measure 

limited the cost of these benefits, there remain a number of retired Fund participants in pay status 

who receive benefits. 

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

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

retirement benefits accrued by currently active participants. Therefore, the impact on the Fund’s 

solvency of subsidies and ancillary benefits accrued by currently active participants is relatively

minor compared to the more pronounced impact of the subsidized early retirement benefits that

are currently being paid to retired participants in pay status; the Fund’s actuary estimates that, as

of January 1, 2015 the latter benefits composed approximately 16% of the Fund’s total actuarial 

accrued liability of $35.1 billion. 

The Board of Trustees concluded that these subsidized benefits payable to participants

who have accrued subsidized early retirement benefits represent a considerable portion of the 

Fund’s accrued liabilities and that, at the time these benefits were earned, the Fund did not 

receive contributions commensurate with the value of these benefits. This disproportionality 

compared to the contribution/cost ratio of normal retirement benefits was a factor in the Board of 

Trustees’ decision to adopt a plan of benefit suspensions that based benefits primarily on a 

percentage of the contributions made on each participant’s behalf, effectively eliminating the

early retirement subsidies. By doing so, the Board of Trustees brought the value of benefits 

received by early retirees in return for their employers’ contributions more in line with those of 

normal retirees.

(3) Compensation levels of active participants relative to employees in the participants’ 

industry generally.

Retirement benefit costs in the unionized sector of the service industries generally are 

significantly higher than in the non-unionized sector of those industries. A June 10, 2015 News 

Release by the Bureau of Labor Statistics (“BLS”) titled “Employer Costs for Employee 

Compensation” (“BLS Report”) indicates that, in the unionized sector of the “service producing 

industries,” which includes transportation and warehousing—industries in which a high 

percentage of the Fund’s active participants are engaged—an average of $4.23 per hour (or 9% 

of total employee compensation) is dedicated to retirement benefits. BLS Report at 22. On the 

other hand, in the non-unionized sector of the service producing industries, retirement benefit 

costs average $0.93 per hour (3.2% of total compensation). 

20.5
Although the average union employee (across all industries) enjoys higher wages than a 

comparable non-union worker, in recent years non-union wages have grown far more rapidly 

than union wages. Between 2001 and 2011, non-union wages grew at a rate 28% faster than 

union wages. George L. Long, “Differences Between Union and Non-Union Compensation,” 

Monthly Labor Review (April 2013). From this, it appears likely that pension costs in the 

unionized sector of the economy as a whole are acting as a drag on wage growth in that sector. 

The discrepancy between the unionized and non-unionized pension costs is even more 

pronounced in the case of the Fund. For example, 8,700 of the Fund’s active participants 

currently work under the NMFA or the NMATA (or under contracts that mirror the wage rates 

and benefits therein). Over the last ten years, pension contributions under the NMFA have 

increased by approximately 60%, while wages under that labor agreement have been relatively 

stagnant. As a result, today NMFA Employers pay an average of approximately $17,500 per 

year in pension contributions for each bargaining unit employee; yet the average annual wage 

paid to NMFA employees is less than $50,000. This contrasts sharply with the non-union 

trucking industry, in which annual pension costs average between $1,000 and $3,000 per 

employee.

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

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

the amount of pension benefit accruals they could expect to yield for every dollar contributed on 

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

was due to the reduction (from 2% to 1% of contributions) in their accrual rates, along with the 

other benefit modifications that the Board of Trustees instituted in 2004. See Response to Rev. 

Proc. 5.01 (document number 18). 

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

see increasing amounts of their total compensation dedicated to pension contributions 

(particularly when approximately $0.50 of each dollar of contributions to the Fund generated by 

the work performed by active participants pays for the pension that they earn for that work; most 

of the rest funds the pensions of retirees and terminated participants),4

 the Board of Trustees has 

determined (based on its experience with current trends in hiring and the preferences of the 

various bargaining units that participate in the Fund) that mandatory additional contribution rate 

increases beyond those already scheduled and the increases incorporated into the proposed 

suspension plan would be likely to (a) cause a net decline in support for the Fund among active 

participants and (b) make it more difficult for Contributing Employers to attract and retain 

qualified employees. These consequences, in turn, will lead to more Employer withdrawals and 

to a decline in contribution revenue for the Fund. Based in part on these considerations with 

respect to compensation levels of active participants relative to employees in the participants’ 

industry generally, the Board of Trustees has concluded that they have taken all reasonable 

measures to avoid insolvency. 

4

 We note that, at a .75% contribution rate, this ratio worsens, such that roughly two thirds of 

each dollar contributed to the Plan on behalf of an active participant goes to pay for the benefits 

of retirees and terminated participants.

20.6

of further benefit cuts would be “a serious erosion of support for the Fund among the rank-andfile Fund participants and their bargaining representatives.” February 19, 2008 Letter from C. 

Thomas Keegel to Thomas C. Nyhan. In the IBT’s view, it would be “virtually impossible” to 

retain union participation in the Fund if further benefit cuts were coupled with contribution 

increases. Id. As discussed previously, the Board of Trustees concluded that further reductions 

in benefit levels would be counterproductive and would decrease support for the Fund, 

worsening rather than improving its financial condition. 

In developing the proposed plan of benefit suspensions, the Board of Trustees has 

considered the elimination of all adjustable benefits accrued by terminated vested participants 

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

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

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

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

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

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

percentage reduction from current benefits entitlements) on suspensions that the Board of 

Trustees has built into their proposed suspension plan of less than 1% of pre-suspension benefits. 

The Board of Trustees has determined that this amount of reduction in the maximum suspension 

for the general population of affected participants is not large enough to justify the elimination of 

all PPA adjustable benefits of terminated participants who have less than 20 years of Service 

Credit. 

• The impact of past and anticipated contribution increases under the plan on employer

attrition and retention levels.

When designing the plan of benefit suspensions, the Board of Trustees reconsidered 

whether, when applied in conjunction with benefit suspensions, contribution increases that 

previously had been unreasonable became reasonable when applied over a longer time horizon. 

See Time Horizon Chart. 

To determine whether the Fund’s contributing employers could withstand additional 

contribution increases that may now have a significant impact on solvency given the Fund’s 

longer time horizon, the Board of Trustees engaged SRR to provide an update to its 2010 study. 

In July 2015, SRR issued an opinion (document number 19.8, pages 165-325) opining on the 

reasonableness of the following proposed contribution rates increases for the employers listed 

below: 

20.8
[*] An NMFA Employer currently subject to the “cap” of $342 per week placed on NMFA 

contribution rate increases. 

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

require contribution increases). 

SRR concluded, on the basis of information available concerning the Employers listed 

above, that it is reasonable to expect those entities to sustain the indicated contribution rate 

increases, with the exception of the increases shown for YRC beginning in 2019. However, with 

respect to YRC, SRR also noted that, because SRR based its conclusion solely upon the financial 

statements of the publically traded Employers it was asked to analyze in its July 2015 report, its 

report did not take into account any potential ability of YRC to absorb the proposed pension 

contribution rate increases by means of reducing other costs (e.g., health coverage costs) in the 

collective bargaining process or through other negotiations. 

Accordingly, the Board of Trustees determined to accept the recommendations and 

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

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

bargaining or through other negotiations. Therefore, the Board of Trustees determined, on the 

basis of information currently available, that the future rate increases showing in the chart above, 

including the increase in 2019 of 2.5% for YRC, are reasonable. Further, the Board of Trustees 

has determined that for Employers currently subject to the $342 and $348 weekly rates and YRC 

Proposed Change in Contribution Rates

Employer Name 2015 2016 2017 2018 2019

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

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

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

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

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

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

Deutsche Post AG

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

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

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

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

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

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

20.9
(whose contribution rates are presently frozen), the proposed suspension plan will contain 

additional compounded annual contribution rate increases of 2.5% subsequent to 2018 (2019 in 

the case of YRC) until 2028, at which point those employers whose contribution rates are 

currently frozen will increase their contributions at the compounded annual rate of 3.0% 

indefinitely. In addition, the Board of Trustees has determined that, under the plan of benefit 

suspensions, these same rate increases will apply to those Employers whose rates are currently 

below the rehabilitation plan maximum rates of $342 and $348 per week. 

Similarly, prior to the enactment of MPRA at the end of 2014, the Fund’s actuary advised 

that in light of the Fund’s projected insolvency, even if the Contributing Employers that were 

subject to the rate caps approved in 2010 were later required to continue to increase their

contributions at the rate of 4% per year (which the Rehabilitation Plan would have required prior 

to the rate caps), there would not be sufficient time prior to the projected insolvency for those 

rate increases to have a material positive impact on the Fund’s financial condition. However, the 

Fund’s actuary has reported that because implementation of the proposed MPRA suspension plan 

would eliminate the projected insolvency, some measures that had little or no positive impact on 

the Fund’s financial condition when it was projected to be insolvent in a short timeframe—such 

as the future contribution rate increases for the “capped Employers” described above—now have 

a material positive impact. In addition, the July 2015 SRR report (in conjunction with YRC’s 

likely ability to cover pension increases by reductions in other employee compensation costs in 

the collective bargaining process, if necessary) indicates that, based on currently available 

information, it is not unreasonable to expect those Employers to pay the increased rates

described above in the future. 

The Board of Trustees has also determined, based on their experience in negotiating 

collective bargaining agreements that include contribution obligations to the Fund (and in 

particular, the experience of the Employee Trustees, all of whom are present or former principal 

officers of Teamster Local Unions), that, regardless of the Employer size and financial strength, 

the pension contribution rates required under the Fund’s rehabilitation plan have grown to such 

an extent that requiring additional rate increases significantly in excess of those already required 

(including the anticipated future contribution rate increases described above) would create an 

unreasonable risk that Contributing Employers would seek to negotiate withdrawals from the 

Fund at a substantially increased rate, and that an increased number of bargaining units would 

cease their efforts to negotiate agreements requiring contributions to the Fund. The Board of 

Trustees has concluded that these risks of increased Employer withdrawals and declining 

contribution revenue would in large part result from a perception that the Fund’s demands for 

increased contributions would be absorbing too much of the limited amounts of Employer funds 

available in the collective bargaining process to cover employee compensation.

The Board of Trustees bases this conclusion in part on their understanding that 

contribution rate increases required of Contributing Employers in the past have been a factor in 

the loss of Contributing Employers. For example, Hostess Brands, Inc., a former Contributing 

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

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

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

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

20.10
would not be making any further contributions to the Fund until it implemented a planned overall 

debt restructuring. Hostess claimed that one of the principal causes of its financial distress was 

the amount of pension contributions it owed each month to various multiemployer pension plans, 

with the Pension Fund at or near the top of that list. Hostess incurred a total contribution 

delinquency of approximately $6 million to the Fund in 2011 before the Board of Trustees 

determined that Hostess’ participation in the Fund should be terminated in November 2011. In 

early 2012, Hostess filed bankruptcy, subsequently ceased all operations, and began liquidating 

its assets. 

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

bankruptcy in 2012, claiming that its pension contribution obligations contributed significantly to 

its financial problems. Allied employed 600 active participants prior to its bankruptcy. Like 

Hostess, Allied is undergoing a liquidation of its assets. In both these bankruptcies the 

liquidations are expected to yield little or no payment on the Fund’s claims for withdrawal 

liability (withdraw liability assessments of $584 million in the case of Hostess and $968 million 

in the case of Allied). 

For these reasons, the Board of Trustees has concluded that, in conjunction with the plan 

of benefit suspensions, the contribution rate increases that SRR opined would be manageable for 

the large Contributing Employers represent rate increases that will put the Fund on the path to 

solvency without increasing employer attrition.

.04 Other factors considered. If the plan sponsor considered any other factors, then 

the application must discuss how and why that factor was taken into account in the 

plan sponsor’s determination that all reasonable measures have been taken to avoid 

insolvency. 

All of the factors considered by the Trustees have been discussed above. 

20.11
Tab A 

20.12
 

 

 

 

 

Checklist Nos. 20-21 / Rev. Proc § 5.03:

20.13