IW17PF_946

SUBMISSION CHECKLIST ON BEHALF OF IRON WORKERS LOCAL 17 PENSION FUND 

Response Item Description of item Page number in 

number application 

~ 1. Does the application include an original signature of the plan IW17PF _760-761 sponsor or an authorized representative of the plan sponsor. See 

N/A section 2.01. 

I~ 2. Does the application include a description of the proposed benefit IW17PF _762-766 

suspension -calculated as if no other limitations apply- that 

N/A includes: 

• the suspension's effective date (and its expiration date, if 

applicable}, 

• whether the suspension provides for different treatment of 

participants and beneficiaries; 

• a description of the different categories or groups of 

individuals affected, and 

• how the suspension affects these individuals differently . 

See section 2.02. 

~ 

- 3. Does the application include a penalties-of-perjury statement signed IW17PF _767-768 

No by an authorized trustee on behalf of the board of trustees. See 

N/A Section 2.03. 

~ 4. Does the application include a statement, signed by an authorized IW17PF _769-770 

trustee on behalf of the board of trustees, acknowledging that the 

N/A application and the application's supporting material will be publicly 

disclosed on the Treasury Department's website. See section 2.04. 

~ 5. Does the application include the plan actuary's certification of critical IW17PF _011 -025 

No and declining status and the supporting illustrations, including: IW17PF _771-777 

N/A • the year-by-year projections demonstrating projected 

insolvency during the relevant period, and 

• separately identifying the available resources (and the 

market value of assets and changes in cash flow) during 

each of those years. 

See section 3.01. 

I~ 6. Does the application describe the assumptions used including the IW17PF_778 

new entrant profile, the total contribution base units, and the average 

N/A contribution rates. See section 3.01. 

!~ 7. Does the application include the plan actuary's certification that the IW17PF _779-800 

No plan is projected to avoid insolvency if the suspension takes effect 

N/A and the supporting illustrations, including: 

• the year-by-year projections demonstrating projected 

solvency during the relevant period, 

• a description of the assumptions used, including the new 

entrant profile, the total contribution base units, and the 

average contribution rates; and 

• separately identifying the available resources (and the 

market value of assets and changes in cash flow)during 

each of those years. 

See section 3.02. 

~ 8. Does the application include the plan sponsor's determination of IW17PF _58 -198 

No projected insolvency that includes the documentation set forth in 

N/A section 5 of the revenue procedure. See section 3.03. 
IW17PF_947

WP 9. Does the application include a demonstration that the limitations on IW17PF _801-813 

individual suspensions are satisfied, including calculations regarding: 

N/A • the guarantee-based limitation, 

• the disability-based limitation, and 

• the age-based limitation . 

See section 4.01. 

,...., 

·cr;;p 10. Does the application include a demonstration that the proposed IW17PF_814 

suspension is reasonably estimated to achieve the level necessary 

N/A to avoid insolvency for the extended period, including illustrations 

regarding the plan's solvency ratio and available resources. See 

section 4.02(1 ). 

~ 11. Does the application include the required illustration utilizing IW17PF_815 stochastic projections. (This illustration is not required if the plan is 

N/A not required to appoint a retiree representative under 

§ 432(e)(9)(B)(v)(l) and stochastic projections were not used in 

making the required determination.} See section 4.02(2}. 

!qrp 12. Does the application include a demonstration that the proposed IW17PF_816 

suspension is not projected to materially exceed the level necessary 

N/A to avoid insolvency, including illustrations regarding the plan's 

solvency ratio and available resources. See section 4.03. 

~ 13. Does the application include a demonstration that the proposed IW17PF _817-826 

suspension is equitably distributed, including 

N/A • information on he effect of the suspension on the plan in 

the aggregate, 

• information on the effect of the suspension for different 

categories or groups, 

• a list of the factors taken into account, 

• an explanation of why none of the factors listed in 

§432(e)(9)(D)(vi) were taken into account (if applicable), 

• for each factor taken into account that is not one of the 

factors listed in §432(e)(9)(D)(vi), an explanation why the 

factor is relevant; and 

• how any difference in treatment among categories or 

groups of individuals results from a reasonable application 

of the relevant factors. 

See section 4.04. 

~ 14. Does the application include a copy of the actual notices (including IW17PF 827-842 

redacted sample calculations) that meet the requirements under 

N/A §432(e)(9)(F). See section 4.05(1). 

c;;p 15. Does the application include a description of the efforts that are IW17PF_226 

being taken to contact participants, beneficiaries in pay status, and 

N/A alternate payees. See section 4.05(2). 

C'f;P 16. Does the application describe the steps the plan sponsor has taken IW17PF _227 

to ensure that notices delivered electronically are reasonably 

N/A accessible to the recipients. See section 4.05(3) 

WiP 17. Does the application include a list of each employer who has an IW17PF _228-232 

obligation to contribute under the Plan and each employee 

N/A organization representing participants under the Plan. See section 

4.05(4). 
IW17PF_948

~ 18. Does the application include information on past and current IW17PF _233-239 

measures taken to avoid insolvency. See section 5.01. 

N/A 

rrcp 19. Does the application include the plan information required by section IW17PF _240-244 

5.02. 

N/A 

-

~ 20. Does the application describe how the plan sponsor took into IW17PF _245-247 

account- or did not take into account- the factors listed in section 

N/A 5.02 in the determination that all reasonable measures were taken to 

avoid insolvency. See section 5.03. 

~ 21. Does the application describe how the plan sponsor took into IW17PF _248-249 

account - or did not take into account - in the determination that all 

N/A 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. 

~ 22. Does the application include a discussion of any other factors the IW17PF _250 

plan sponsor took into account including how and why those factors 

N/A were taken into account. See section 5.04. 

I~ 23. Does the application include a copy of the proposed ballot excluding IW17PF843-852 

the information regarding the statement in opposition, the 

N/A individualized estimates, and the voting procedures. See section 

6.01. 

I~ 24. Does the application indicate whether the plan sponsor is requesting IW17PF_260 

approval from the PBGC of a proposed partition under section 4233 

N/A of ERISA. See section 6.02. 

~ 25. If the answer to item 24 is yes, does the application specify the IW17PF_261 

effective date of the proposed partition and include a year-by-year 

N/A projection of the amount of the reduction in benefit payments 

attributable to the partition. See section 6.02. 

I~ 26. Does the application describe the plan's experience with certain IW17PF _853-

No critical assumptions. including a disclosure for each of the 1 0 plan 877 

N/A years immediately preceding the application that separately 

identifies 

• total contributions, 

• total contribution base units, 

• average contribution rates, 

• withdrawal liability payments, and 

• the rate of return on plan assets . 

See section 6.03. 

-...:"'"'\ 

~ 27. Does the application include deterministic projections of the IW17PF _878 

sensitivity of the plan's solvency ratio throughout the extended 

N/A period by taking into account more conservative assumptions of 

investment experience and future contribution base units than 

assumed elsewhere in the application. See section 6.04. 
IW17PF_949

~ 28. Does the plan include deterministic projections for each year in the IW17PF_879 

extended period of 

N/A • the value of plan assets, 

• the plan's accrued liability, and 

• the plan's funded percentage . 

See section 6.05. 

~ 29. Does the application include the plan sponsor's representation that, IW17PF 880-885 

if it receives the Treasury Department's final authorization to 

N/A suspend and then chooses to implement the suspension, it will also 

amend the plan 

• to indicate that the suspension will cease upon the plan 

sponsor's failure to determine that both all reasonable 

measures continue to be taken to avoid insolvency and that 

the plan is projected to become insolvent without a 

suspension, 

• to require that any future benefit improvements must satisfy 

§ 432(e)(9)(E), and 

• to specify that the plan sponsor will not modify these 

amendments, notwithstanding any other provision of the 

plan document. 

See section 6.06. 

~ 30. Does the application indicate whether the plan is a plan described in IW17PF _362 

§ 432(e)(9)(D)(vii)(lll) and, if so, how is that fact reflected in the 

N/A proposed benefit suspension. See section 6.07. 

~ 31 . Does the application include the required plan sponsor information, IW17PF _363 

No including 

N/A • name 

• address 

• telephone number 

• email address 

• fax number 

• employer identification number (EIN) and 

• 3-digit plan number (PN) . 

See section 7.01. 

~ 32. Does the application include the required plan identification IW17PF _364 

information. See section 7.02. 

N/A 

~ 33. Does the application include the required retiree representative IW17PF_365 

No information (if applicable). See section 7.03. 

N/A 

~ 

- 34. Does the application include the required enrolled actuary IW17PF _366 

No information. See section 7.04. 

N/A 

~ 35. Does the application include a designation of power of attorney for IW17PF _886-888 

each authorized representative who will represent the plan sponsor 

N/A in connection with the application. See section 7.05 and Appendix 

B. 
"Yes:) 36. Does the application include 

1W • the required plan documents, 

NIA • any recent amendments, 

• the summary plan description (SPD), 

• the summary of material modifications, and 

• the most recent determination letter . 

See section 7.06. 

~ 37. Does the application include the required excerpts from the relevant 

collective bargaining agreements and side agreements. See section 

N/A 7.07. 

~ 38. Does the application include the required excerpts from the most recently filed Form 5500. See section 7.08. 

N/A 

~ 39. Does the application include the most recently updated rehabaitation 

plan. See section 7.09. 

N/A 

I 

cT:P 40. Does the application include the most recently updated actuarial 

valuation report. See section 7.10. 

I N/A 

I 

~ 41. Does the application include this checklist, completed and placed on 

top of the application. See section 7 .11. 

N/A 

CYJP 42. Does the application being submitted for resubmission review, include: 

N/A • a statement that the application is being submitted for 

resubmission review, and 

• the date on which the Treasury Department gave approval 

to submit an application for resubmission review?, 

See section 8. 

rustee Representative for the 

Iron Workers Local 17 Pension Fund 

IW17PF_950 

IW17PF 370-667 

IW17PF _889-

892 

IW17PF _668-698 

IW17PF _: 893-943 

IW17PF _741 751 

IW 17PF 286-353 

IW17PF=944 

IW17PF _ 945-950 

IW17PF _951-953 
Checklist Item #1 Resubmitted Application for Approval of a

Suspension of Benefits Under MPRA

Iron Workers Local 17 Pension Fund EIN: 51-0161467

Plan No.: 001

Does the application 

include an original 

signature of the Plan 

Sponsor or an authorized 

representative of the Plan 

Sponsor? 

See Section 2.01. 

A letter which includes the signatures for the full 

Board of Trustees is attached as IW17PF_761. 

IW17PF_760
Iron Workers Local17 Fringe Benefit Funds, Inc. INS URA N CE PLA N • Pf N S!O N fl! N D • A NN II/TY fl! N O 

~3 

July 28, 2016 

Mailing Add ress: P.O. BOX 6327 • CLEVELAND, OHIO 44101 -1327 

3250 EUCLID AVENUE- ROOM 150 • CLEVELAND, OHIO 44115 

PHONE: 2161241 -1 086 • TOLL FREE: 1-800-788-8406 • FAX: 216/431-7707 

Electronic Submission to www.treasury.gov/mpra 

The Honorable Jacob J. Lew 

Secretary of the Treasury 

Department of the Treasury 

1500 Pennsylvania Avenue, NW 

Washington DC 20220 

Re: Iron Workers Local17 Pension Fund - Application for Suspension of Benefits under the 

Multiemployer Pension Relief Act of 2014 

Dear Secretary Lew: 

The Board of Trustees for the Iron Workers Local 17 Pension Fund, as the Plan Sponsor, respectfully 

requests that the attached resubmitted application for approval o f a proposed suspension of benefits 

pursuant to Internal Revenue Code Section 432(e)(9) and the Employee Retirement Income Security 

Act of 1976 Section 305(e)(9), previously f iled on December 23, 2015 and withdrawn on July 26, 2016, 

be accepted for resubmission in accordance with 26 CFR 1.432(e)(9) l(g)(3). 

Pursuant to the approval for the resubmission granted by the U.S. Department of Treasury on July 12, 

2016, the Plan Sponsor is providing all information required, with the exception of information which 

has not changed. This resubmitted application provides a cross reference to the unchanged 

information pursuant to Revenue Procedure 2016 27 Section 8. 

The full Board also hereby designates its Chairman Trustee, Richard Jordan, as its Authorized 

Representative Trustee for purposes of executing all documents necessary for this resubmitted 

application. 

Executed on July 26, 2016: 

Redacted by the U.S. Department of the 

Treasury 

Richard Jordan 

IW17PF _761 

Redacted by the U.S. Department of the 

Treasury 

Redacted by the U.S. Department of the 

Treasury 

~ 

y 
Checklist Item #2 Resubmitted Application for Approval of a Suspension 

of Benefits Under MPRA

Iron Workers Local 17 Pension Fund EIN: 51-0161467

Plan No.: 001

Does the application 

include a description of the 

proposed benefit 

suspension - calculated as 

if no other limitations apply 

- that includes:

• the suspension’s

effective date (and

its expiration date, if

applicable),

• a description of the

different categories

or groups of

individuals affected,

and

• how the suspension

affects these

individuals

differently.

See section 2.02.

The application filed on behalf of the Iron Workers Local 17 

Pension Fund sets forth the following proposed Benefit 

Suspension Plan to be effective as of February 1, 2017 and 

continuing indefinitely thereafter.

The Plan Sponsor proposes to amend the Pension Fund to 

recalculate all accrued benefits or benefits in pay status for 

all participants, beneficiaries and Alternate Payees without 

regard to any different category or classifications based 

upon employer, years or service etc. However, this

recalculation will not reduce any benefit below 110% of the 

guaranteed level by the PBGC or be applied if contrary to 

the age based limitations described below. 

The recalculation will include the following changes:

• Reduction of Benefit Credit Rate

The accrued benefit earned for each participant

under the Pension Fund depended upon the Benefit

Credit amount in effect during the participant’s

working career. The rates ranged from $12.00 to

$100.00 per Benefit Credit since the Pension Fund’s

inception. The current Benefit Credit rate of $50.00

was adopted in November 2004.

Under the proposed Suspension Plan, the accrued

benefit and benefit in pay status for all Affected or

Limited Suspension Participants, Beneficiaries and

Alternate Payees, will be recalculated as of April 30,

2016 (the fiscal plan year-end immediately prior to

the Suspension Date) to be reduced so the highest

average accrual rate is no more than $72.00 per year

of Benefit Credit.

• Elimination of Excess Benefit Credits.

During the period from May 1, 1986 to April 30, 2005,

participants that worked more than 1,200 hours in a

Plan Year could earn more than one (1) full year of

Benefit Credit. Effective May 1, 2005, the Pension

Fund changed the crediting schedule to require

IW17PF_762
1,900 hours in a Plan Year to earn one (1) full year of 

Benefit Credit and eliminated the ability of any 

participant to earn more than one (1) Benefit Credit. 

Under the proposed Suspension Plan, the accrued 

benefit and benefits in pay status for all Affected and 

Limited Suspension Participants, Beneficiaries and 

Alternate Payees will be adjusted so any additional 

Benefit Credits over one (1) will be eliminated as of 

February 1, 2017. 

• Modification of Unreduced Early Retirement Benefit

Prior to 2009, the Pension Fund provided for an

unreduced early retirement for participants with long

service of 30+ years of Vesting Service.

Under the proposed Suspension Plan, the benefits in

pay status for all Affected and Limited Suspension

Participants, Beneficiaries and Alternate Payees that

received an unreduced early retirement benefit will

be recalculated as of February 1, 2017 to apply a

1.5% reduction for each year that the participant’s

pension commenced prior to age 62.

These changes will only apply to “Affected Participants, 

Beneficiaries and Alternate Payees” that are defined as 

those participants, beneficiaries and Alternate Payees that 

do not fall under the “Exempt Participants” and who are not 

part of the “Limited Suspension Participants” defined below. 

The proposed Suspension Plan recognizes that certain 

groups are exempted from the application of these benefit 

reductions. These groups which the Suspension Plan refers 

to as Exempted Participants are as follows:

• All participants that were awarded with a disability

pension and beneficiaries of such participants;

• All participants and beneficiaries who are at least

age 80 as of February 28, 2017; and

• Any participant or beneficiary that would receive

a benefit that is less than 110% of the PBGC

guaranteed level if the Suspension Plan is applied

to them.

Additionally, the proposed Suspension Plan will limit the 

application of these proposed reductions for any participant, 

beneficiary or Alternate Payee that is between age 75 and 

80 as of February 28, 2017. This group, which the 

Suspension Plan refers to as “Limited Suspension 

Participants”, will have their accrued benefit or benefit in pay 

IW17PF_763
status recalculated under the changes that apply to the 

Affected Participants above called the suspended benefit. 

However, the Pension Fund will then determine 1/60th of the 

difference between the current benefit and suspended 

benefit. This factor will be multiplied by the number of 

months the Limited Suspension Participant is over age 75 

as of February 28, 2017 to determine the increase factor. 

The new benefit under the proposed Suspension Plan for 

this Limited Suspension Participant group is the sum of the 

suspended benefit plus the increase factor. 

Finally, the Pension Fund currently does not allow retirees 

that are younger than age 65 to return to any work in the 

industry. Under the proposed Suspension Plan, the 

Trustees would amend the current return to work restrictions 

on retirees who are younger than age 65 to allow 

participants in pay status as of February 1, 2017 to return to 

work for up to 39.5 hours per month under the same rules 

that currently apply to retirees that have reached Normal 

Retirement Age without having their monthly benefit 

suspended. 

As stated above, the proposed Suspension Plan does not 

have a different set of benefit reductions that applies to 

different categories or groups of participants and 

beneficiaries. All three proposed reductions will apply to any 

Affected or Limited Suspension Participant. However, each 

participant in the Pension Fund has a different work history 

and retirement date. Accordingly, the impact of the 

proposed Suspension Plan does have a different effect 

upon different groups of participants once it is applied 

equally to all Affected and Limited Suspension Participants. 

For these purposes, the Plan Sponsor has designated the 

following seven (7) categories based upon the presuspension benefit accrual formula. These are:

• Category 1 – Participants with a pre-suspension 

$100 Benefit Credit

• Category 2 – Participants with a pre-suspension $90 

Benefit Credit

• Category 3 – Participants with a pre-suspension 

$85.50 Benefit Credit

• Category 4 – Participants with a pre-suspension $75 

Benefit Credit

• Category 5 – Participants with a pre-suspension 

$72.50 Benefit Credit

IW17PF_764
• Category 6 – Participants with a pre-suspension $72 

or less Average Benefit Credit

• Category 7 – Participants with a pre-suspension

Average Benefit Credit between $99.99 and $72.01 

Categories 6 and 7 are made up of the participants that have 

a blended pre-suspension benefit formula due to the fact 

that individuals in these categories have different 

proportions of their pre-suspension benefits calculated 

under different benefit formulas as authorized by Regulation 

§1.432(e)(9)-1(c)(6)(iv)(B). Affected and Limited 

Suspension Participants in all Categories except 6 are 

subject to a reduction of their Benefit Credit Rate to $72.00 

per Benefit Credit. Affected and Limited Suspension 

Participants in Category 6 are already at or below the $72.00 

Benefit Credit Rate, so they will have no further reduction to 

their Benefit Credit Rate under the proposed Suspension 

Plan. 

Within each of these Categories, there are sub-groups of 

participants that are further affected differently due to the 

separate reductions related to the proposed Elimination of 

Excess Benefit Credits and Modification of the Unreduced

Early Retirement Benefit. The Plan Sponsor has further 

categorized these participants by grouping them into four (4)

separate sub-groups as follows:

Subgroup A = Participants with no Excess Benefit Credits 

that did not retire on an Unreduced Early Benefit prior to May 

2009. Affected and Limited Suspension Participants, 

Beneficiaries and Alternate Payees in this subgroup will not 

be impacted by the Elimination of Excess Benefit Credits or 

Modification of the Unreduced Early Retirement Benefit 

reductions under the proposed Suspension Plan. 

Subgroup B – Participants with Excess Benefit Credits that 

did not retire on an Unreduced Early Benefit prior to May 

2009. Affected and Limited Suspension Participants, 

Beneficiaries and Alternate Payees in this subgroup will 

have all Excess Benefit Credits eliminated under the 

proposed Suspension Plan. 

Subgroup C – Participants no Excess Benefit Credits that 

did retire on an Unreduced Early Benefit prior to May 2009. 

Affected and Limited Suspension Participants, Beneficiaries 

and Alternate Payees in this subgroup will have an Early 

Retirement reduction factor of 1.5% per year that they 

retired prior to age 62 applied to their normal retirement

benefit under the proposed Suspension Plan. 

IW17PF_765
Subgroup D – Participants with Excess Benefit Credits that

did retire on an Unreduced Early Benefit prior to May 2009. 

Affected and Limited Suspension Participants, Beneficiaries 

and Alternate Payees in this subgroup will have all Excess 

Benefit Credits eliminated and will have an Early Retirement 

reduction factor of 1.5% per year that they retired prior to 

age 62 applied to their normal retirement benefit under the 

proposed Suspension Plan. 

Pursuant to Regulation §1.432(e)(9)-1(c)(6)(iv)(C), all 

participants who retired on an Unreduced Early Benefit prior 

to May 2009 regardless of different pre-suspension 

retirement ages are placed in one subgroup. Based upon 

this guidance, the Plan Sponsor is also treating all 

participants with any number of pre-suspension Excess 

Benefit Credits as one subgroup for these purposes. 

IW17PF_766
Checklist Item #3 Resubmitted Application for Approval of a 

Suspension of Benefits Under MPRA

Iron Workers Local 17 Pension Fund EIN: 51-0161467

Plan No.: 001

Does the application 

include a penalties-ofperjury statement signed 

by an authorized trustee 

on behalf of the board of 

trustees. 

See Section 2.03.

A Penalty of Perjury statement signed by the 

Authorized Trustee Representative for the Iron 

Workers Local 17 Pension Fund is attached as 

IW17PF_768. 

IW17PF_767
Iron Workers Local17 Fringe Benefit Funds, Inc. 

IN S URANCE P L AN • P E N S ION FUND • A N NUITY FU N D 

Mailing Address: P.O. BOX 6327 • CLEVELAND, OHIO 441 01 -1327 

3250 EUCLID AVENUE- ROOM 150 • CLEVELAND, OHIO 44115 

PHONE: 216/241-1086 • TOLL FREE: 1-800-788-8406 FAX:216/431-7707 

Penalty of Perjury Statement 

Under Penalty of Perjury, I, Richard Jordan, Chairman Trustee for the Iron Workers Local 17 

Pension Fund, declare that I have examined this request for Suspension of Benefits under the 

Multiemployer Pension Relief Act of 2014 and all accompanying documents. To the best of my 

knowledge and belief, this application contains all relevant facts relating to the request for the 

Suspension of Benefits and such facts are true, correct and complete. 

Redacted by the U.S. 

Department of the Treasury 

• • • 

Authorized Trustee Representative for the 

Iron Workers Loca117 Pension Fund 

IW17PF _768 

Date: _1-+-/_;2ot-+-/..:...:;..LC __ 
Checklist Item #4 Resubmitted Application for Approval of a

Suspension of Benefits Under MPRA

Iron Workers Local 17 Pension Fund EIN: 51-0161467

Plan No.: 001

Does the application 

include a statement, 

signed by an authorized 

trustee on behalf of the 

board of trustees, 

acknowledging that the 

application and the 

application’s supporting 

material will be publicly 

disclosed on the Treasury 

Department’s website. 

See section 2.04.

An acknowledgment of public disclosure statement 

signed by the Authorized Trustee Representative

for the Iron Workers Local 17 Pension Fund 

is attached as IW17PF_770. 

IW17PF_769
Iron Workers Local17 Fringe Benefit Funds, Inc. INSURANCE PLAN • PENSION FUND • ANNUITY FUND 

Mailing Address: P.O. BOX 6327 • CLEVELAND, OHIO 44101-1327 

3250 EUCLID AVENUE - ROOM 150 • CLEVELAND, OHIO 44115 

PHONE: 216/241-1086 • TOLL FREE: 1-800-788-8406 F~: 16/24 1-2904 

Acknowledgement of Public Disclosure 

The Board of Trustees for the Iron Workers Local 17 Pension Fund, understands and 

acknowledges that this complete Application for Approval of a Suspension of Benefits under the 

Multiemployer Pension Relief Act of 2014 and all accompanying supporting material will be 

publicly disclosed through publication on the Department of Treasury website pursuant to 

Internal Revenue Code Section 432(e)(9)(G)(ii). 

Redacted by the U.S. Department 

of the Treasury 

• • • • an 

Authorized Trustee Representative for the 

Iron Workers Local17 Pension Fund 

IW17PF _770 

Date: -,I ao../t (, 

' f