~ DEPARTMENT OF THE TREASURY 

WASHINGTON, O.C. 20220 

VI 

February 6, 2020 

Mr. Thomas Dalton 

Mr. Rodney Toole 

Board of Trustees 

Composition Roofers Local 42 Pension Plan 

205 W. 4•h Street, Ste. 225 

Cincinnati, OH 45202 

Re: Composition Roofers Local 42 Pension Plan (Fund) 

Application for Reduction of Benefits 

Dear Mr. Dalton & Mr. Toole: 

The application submitted by the Board of Trustees of the Fund to the Secretary of the Treasury 

(Treasury) on June 28, 2019 to reduce benefits pur~uant 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(c)(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 Wednesday, February 12, 2020: 

• a voting roster that idenlifies eligible voters in accordance with the regulations under 

MPRA, including all Fund parlicipants (active participants, deferred vested participants, 

and retirees) and beneficiaries of deceased participants; 

• Fund information (such as participant identification codes used by the Fund) to enable 

Treasury to verify the identity of each eligible voter; 

• mailing addresses for all voters on the roster ( or an indication that an address could not be 

identified through reasonable efforts); 

• current electronic mailing addresses for those voters who also may be contacted 

electronically; and 
Board of Trustees 

Composition Roofers Local 42 Pension Plan 

February 6, 2020 

Page 2 

• individualized estimates of the effect of the proposed benefit reduction on each 

participant and beneficiary in the Fund.1 

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). 2 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.3 

Please contact Treasury staff if you have any questions regarding this information. 

Sincerely, 

Danielle Norris 

MPRA Director 

cc: Michael A. Ledbetter 

Michael Rust 

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

3 See Treas. Reg.§ 1.432(e)(9)-1 (a)(4)(iii)(D). (The effective dale of a benelil reduction may not precede the date 

on which a linal authorization lo reduce bcnelits is issued.)