DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.

November 9, 2019

Mr. Tom Wiant

Mr. Joe Stella

Board of Trustees of the Sheet Metal Workers Local Pension Fund
PO Box 368

Troy, MI 48099-0368

Re: Sheet Metal Workers Local Pension Fund (Fund)
Application for Reduction of Benefits

Dear Mr. Wiant and Mr. Stella:

The application submitted by the Board of Trustees of the Fund to the Secretary of the Treasury
(Treasury) on March 29, 2019 to reduce benefits pursuant to the Multiemployer Pension Reform
Act of 2014 (MPRA) has been reviewed to determine whether it satisfies the requirements
established by Congress under MPRA. In consultation with the Secretary of Labor (DOL) and
the Pension Benefit Guaranty Corporation (PBGC), Treasury has determined that the Fund is
eligible to reduce benefits under MPRA and that your application satisfies the requirements of
subparagraphs (C), (D), (E), and (F) of section 432(e)(9) of the Internal Revenue Code (Code),
as added by MPRA.

This notification is not a final authorization to implement the benefit reduction described in your
application. Pursuant to Code section 432(e)(9)(H), no reduction of benefits can take effect
before a vote of the participants and beneficiaries of the Fund with respect to the proposed
reduction. MPRA requires Treasury, in consultation with DOL and PBGC, to administer this
vote. Accordingly, Treasury, in consultation with DOL and PBGC, will administer a vote of the
participants and beneficiaries of the Fund.

Pursuant to the regulations under MPRA, the Trustees must submit the following to Treasury or
its designated vendor no later than Monday, November 18, 2019:

© a voting roster that identifies eligible voters in accordance with the regulations under
MPRA, including all Fund participants (active participants, deferred vested participants,
and retirees) and beneficiaries of deceased participants;

e Fund information (such as participant identification codes used by the Fund) to enable
Treasury to verify the identity of each eligible voter;

e mailing addresses for all voters on the roster (or an indication that an address could not be
identified through reasonable efforts);


Board of Trustees

Sheet Metal Workers Local Pension Fund
November 9, 2019

Page 2

© current electronic mailing addresses for those voters who also may be contacted
electronically; and

e individualized estimates of the effect of the proposed benefit reduction on each
participant and beneficiary in the Fund.'

The Trustees are responsible for making reasonable efforts to identify the mailing addresses for
those eligible voters whose ballot packages are returned as undeliverable (upon notice of such
returns by Treasury). Please review the regulations under MPRA for further details regarding
these requirements. If you fail to satisfy the applicable requirements, it may not be possible
to timely administer, and certify the results of, the vote. In that case, it may not be possible
to issue a final authorization permitting implementation of the proposed reduction.>

Please contact Treasury staff if you have any questions regarding this information.
Sincerely,
Bel Fenn
Danielle Norris
MPRA Director

ce: Paul M. Newcomer
Michael A. Novara

' Treas. Reg. § 1.432(e)(9)-1(h)(2)(iii)(B)(2).

? Treas. Reg. § 1.432(e)(9)-1(h)(2)(iii)(B)(3).

3 See Treas. Reg. § 1.432(e)(9)-1(a)(4)(iii)(D). (The effective date of a benefit reduction may not precede the date
on which a final authorization to reduce benefits is issued.)