Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 1 

Does the application include an original signature of the plan sponsor or an authorized 

representative of the plan sponsor? 

See Section 2.01 of this revenue procedure. 

12 N/A 

Yes 2 

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), 

•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 of this revenue procedure.

12 N/A 

Yes 3 

Does the application include a penalties-of-perjury statement signed by an authorized trustee 

on behalf of the board of trustees? 

See Section 2.03 of this revenue procedure.

13 N/A 

Yes 4 

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 of this revenue procedure.

13 N/A 

Yes 5 

Does the application include the plan actuary's certification of critical and declining status 

and the supporting illustrations, including: 

•the plan-year-by-plan-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 of this revenue procedure.

15 3.01a 

3.01b 

IBT730-0001
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 6 

Does the application include the plan actuary's certification that, taking into account the 

proposed suspension and, if applicable, a proposed partition, the plan is projected to 

avoid insolvency if the suspension takes effect, and the supporting illustrations, 

including: 

•the plan-year-by-plan-year projections demonstrating projected solvency during the 

relevant period, 

•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 of this revenue procedure. 

15 3.02 

Yes 7 

Does the application include the plan sponsor's determination of projected insolvency that 

includes the documentation set forth in section 5 of the revenue procedure? 

See Section 3.03 of this revenue procedure.

16 N/A 

Yes 8 

Does the application include a demonstration that the limitations on individual 

suspensions are satisfied, including a description of each benefit based on disability, as 

defined under the plan, that is paid to an individual under the plan (without regard to 

whether the disability benefits are available to newly disabled participants) and 

calculations regarding: 

• the guarantee-based limitation, 

• the disability-based limitation, 

• the age-based limitation, taking into account the guarantee-based limitation, and 

• if applicable, the age-based limitation taking into account both the guarantee-based 

limitation and the disability-based limitation? 

See Section 4.01 of this revenue procedure.

17 4.01a4.01h 

Yes 9 

Does the application include a demonstration that the proposed suspension is reasonably 

estimated to achieve the level necessary to avoid insolvency for the extended period, 

including illustrations regarding the plan's solvency ratio and available resources? 

See Section 4.02(1) of this revenue procedure.

17 3.02 

IBT730-0002
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

N/A 10 

Does the application include an illustration that the proposed suspension is reasonably 

estimated to achieve the level necessary to avoid insolvency for the extended period 

utilizing stochastic projections? (This illustration is optional if the plan is not required to 

appoint a retiree representative under § 432(e)(9)(B)(v)(I).) 

See Section 4.02(2) of this revenue procedure. 

18 

Yes 11 

Does the application include a demonstration that the proposed suspension is not 

projected to materially exceed the level necessary to avoid insolvency, including: 

•the plan-year-by-plan-year projections demonstrating projected insolvency during the 

relevant period, and 

•a separate identification of the available resources (and the market value of assets and 

changes in cash flow) during each of those years? 

See Section 4.03 of this revenue procedure.

18 4.03 

Yes 12 

Does the application include a demonstration that the proposed suspension is equitably 

distributed, including: 

•information on the 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 

•an explanation of how any difference in treatment among categories or groups of 

individuals results from a reasonable application of the relevant factors? 

See Section 4.04 of this revenue procedure.

18 4.04(1a) 

4.04(1b) 

IBT730-0003
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 13 

Does the application include a copy of the notices (excluding personally identifiable 

information) that meet the requirements under §432(e)(9)(F)? 

See Section 4.05(1) of this revenue procedure. 

24 4.05a4.05h 

Yes 14 

Does the application include a description of the efforts that are being taken to contact 

participants, beneficiaries in pay status, and alternate payees? 

See Section 4.05(2) of this revenue procedure.

24 N/A 

Yes 15 

Does the application describe the steps the plan sponsor has taken to ensure that notices 

delivered electronically are reasonably accessible to the recipients? 

See Section 4.05(3) of this revenue procedure.

24 N/A 

Yes 16 

Does the application include a list of each employer who has an obligation to contribute 

under the plan and each employee organization representing participants under the plan? 

See Section 4.05(4) of this revenue procedure.

24 N/A 

Yes 17 

Does the application include information on past and current measures taken to avoid 

insolvency? 

See Section 5.01 of this revenue procedure.

26 N/A 

IBT730-0004
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 18 

Does the application include information regarding the plan factors described in 

§432(e)(9)(C)(ii), for the past 10 plan years immediately preceding the plan year in which 

the application is submitted? 

See Section 5.02 of this revenue procedure. 

32 N/A 

Yes 19 

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

into account - the factors listed in section 5.02 of this revenue procedure in the 

determination that all reasonable measures were taken to avoid insolvency? 

See Section 5.03 of this revenue procedure.

37 N/A 

Yes 20 

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 of this revenue procedure. 

37 N/A 

Yes 21 

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 of this revenue procedure.. 

42 N/A 

Yes 22 

Does the application include a copy of the proposed ballot, excluding the information 

regarding the statement in opposition, the individualized estimate, and the voting 

procedures? 

See Section 6.01 of this revenue procedure.

43 6.01 

Yes 23 

Does the application indicate whether the plan sponsor is requesting approval from 

PBGC of a proposed partition under section 4233 of ERISA? 

See Section 6.02 of this revenue procedure..

43 N/A 

IBT730-0005
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

N/A 24 

If the answer to item 23 is yes, does the application specify the effective date of the 

proposed partition and include a plan-year-by-plan-year projection of the amount of the 

reduction in benefit payments attributable to the partition? 

See Section 6.02 of this revenue procedure.

N/A N/A 

Yes 25 

Does the application include: 

•a description of each of the assumptions used in the projections required under sections 

3.01, 3.02, 4.02(1), 4.02(2), and 4.03 of this revenue procedure, 

•supporting evidence for the selection of those assumptions, and 

•an explanation of any differences among the assumptions used for various purposes? 

See Section 6.03 and Appendix B of this revenue procedure.

43 6.03 

Yes 26 

Does the application describe the plan's experience with certain critical assumptions, 

including a disclosure for each of the 10 plan years immediately preceding the 

application that separately identifies: 

•the total contributions, 

•the total contribution base units, 

•the average contribution rates, 

•the withdrawal liability payments, and 

•the rate of return on plan assets? 

See Section 6.04 of this revenue procedure. 

43 N/A 

Yes 27 

Does the application include deterministic projections of the sensitivity of the plan's 

solvency ratio throughout the extended period by taking into account the more 

conservative assumptions of investment experience and future contribution base units 

than assumed elsewhere in the application? 

See Section 6.05 of this revenue procedure..

44 6.05(1)- 

6.05(4) 

Yes 28 

Does the plan include deterministic projections for each year in the extended period of: 

•the value of plan assets, 

•the plan's accrued liability, and 

•the plan's funded percentage? 

See Section 6.06 of this revenue procedure.

44 3.02 

IBT730-0006
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 29 

Does the application include the plan sponsor’s representation that, if it receives the Treasury 

Department's final authorization to suspend and then chooses to implement the suspension, it 

will also amend the plan: 

•to provide that the suspension will cease upon the plan sponsor's failure to maintain a written 

record of its annual determination that (i) all reasonable measures continue to be taken to 

avoid insolvency and (ii) the plan would not be projected to avoid insolvency 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 6.07 of this revenue procedure.

44 N/A 

Yes 30 

Does the application indicate whether the plan is a plan described in § 432(e)(9)(D)(vii) and, 

if it is, how that is reflected in the proposed benefit suspension? 

See Section 6.08.

45 N/A 

Yes 31 

Does the application include a narrative statement of the reasons the plan is in critical and 

declining status? 

See Section 6.09.

45 N/A 

Yes 32 

Does the application include the required plan sponsor identification and contact 

information? 

See Section 7.01 of this revenue procedure.

46 N/A 

Yes 33 Does the application include the required plan identification information? 

See Section 7.02 of this revenue procedure.

46 N/A 

N/A 34 Does the application include the required retiree representative information (if applicable)? 

See Section 7.03 of this revenue procedure. N/A N/A 

Yes 35 Does the application include the required enrolled actuary information? 

See Section 7.04 of this revenue procedure. 46 N/A 

IBT730-0007
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

 EIN/PN: 52-6124754 / 001 

Exhibit 7.11 Checklist (Checklist Item #42) 

Response Item Description of Item Page Exhibit 

Yes 36 

Does the application include a designation of power of attorney for each authorized 

representative who will represent the plan sponsor in connection with the application? 

See Section 7.05 and Appendix C of this revenue procedure.

46 7.05 

Yes 37 

Does the application include: 

•the required plan documents 

•any recent amendments 

•the summary plan description (SPD) 

•any summary of material modifications, and 

•the most recent determination letter? 

See Section 7.06 of this revenue procedure.

47 7.06a7.06c 

Yes 38 

Does the application include the required excerpts from the relevant collective bargaining 

agreements and side agreements? 

See Section 7.07 of this revenue procedure.

47 7.07 

Yes 39 Does the application include the required excerpts from the most recently filed Form 5500? 

See Section 7.08 of this revenue procedure. 47 7.08 

Yes 40 Does the application include the most recently updated rehabilitation plan? 

See Section 7.09 of this revenue procedure. 47 7.09 

IBT730-0008

Warehouse Employees Union Local No. 730 Pension Trust Fund 

Application to the 

Secretary of the Treasury 

for 

Approval of Suspension of Benefits 

IBT730-0010
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 1. Background and Purpose 

Section 201 of the Multiemployer Pension Reform Act of 2014, Division O of the Consolidated 

and Further Continuing Appropriations Act, 2015, Public Law 113-235 (128 Stat.2130 (2014)) 

(MPRA), amended the Internal Revenue Code (Code) and the Employee Retirement Income 

Security Act of 1974, Public Law 93-406 (88 Stat. 829 (1974)), as amended (ERISA), to permit 

the sponsor of a multiemployer defined benefit plan in critical and declining status to suspend 

benefits in certain situations. 

In particular, MPRA amended §432(e) (9) of the Code and section 305(e)(9) of ERISA to permit 

the sponsor of a multiemployer defined benefit plan in critical and declining status to submit to the 

Secretary of the Treasury (Secretary) an application to suspend benefits in certain situations. 

MPRA requires the Secretary to approve a plan sponsor’s proposed suspension if the Plan is 

eligible for the proposed suspension and proposed suspension satisfies §432(e)(9)(C) through (F) 

of the Code. 

Revenue Procedure 2017-42 prescribes the application process for approval of a proposed benefit 

suspension in accordance with §432(e)(9)(G) and provides a model notice that a plan sponsor 

proposing a benefit suspension may use to satisfy the content and readability requirements of 

§432(e)(9)(F)(ii) and (iii)(II). 

This Application is submitted in accordance with Revenue Procedure 2017-43 and the section 

numbers and exhibits included with this Application match those in the Revenue Procedure. 

IBT730-0011
2/26/21


App cation for ÅpprovaI ofBenefit Suspension for

Warehouse EmpIoyees Union Local No. 730 Pension Trust Fund

EIIヾ/PN: 52-6124754 / 001

Section 3. Demonstration that Fund is EIigible for SusDenSion

3.01 Fund Actuarv,s CeIlification of CriticaI and DecIining Status

Exhibit 3.01a contains the certification required under §432(b)(3)(A) that the Plan is in

C正ical and declining status as defined in §432(b)(6) for the plan year beginning January

l , 2020 (the most recent certification).

Exhibit 3.0 1 b contains documentation supporting the actuarial certification of status,

including a plan-year-by-Plan-year PrQjection ofthe available resources as defined in

§41 8E(b)(3) and benefits that are due under the Plan, demonstrating血at the Plan is

PrQjected to become insoIvent during the period described in §432(b)(6).

3.02 Fund Actuarvls Certification that the Fund is Proiected to Avoid InsoIvencv

Exhibit 3.02 contains documentation supporting the actuarial certification that the Plan is

Prqjected to avoid insoIvency within the meaning of §41 8E, taking into account the

PrOPOSed suspension, and assuming that the proposed suspension continues indefinitely.

This exhibit includes a plan-year-by-Plan-year Prqiection of the available resources

Within the meaning of §41 8E(b)(3) and the benefits that are due under the Plan

demonstrating the avoidance of insoIvency ofthe Plan over the extended period described

in § 1.432(e)(9)-1(d)(5)(ii)(C).

This Application and its contents have been prepared in accordance with generally

recognized and accepted actuarial principles and practices and our understanding of the

Code ofProfessional Conduct and applicable Actuarial Standards of Practice set out by

the Actuarial Standards Board as well as applicable laws and regulations. Furthemore, as

a credentialed actuary, I meet the Qualification Standards ofthe American Academy of

Actuaries to render the opinion contained in this infomation. This does not address any

COntraCtual or legal issues. I am not an attomey and our fim does not provide any legal

SerVices or advice.

In preparing this certification, We have relied on infomation supplied by the Plan O綿ce

and the Board ofTrustees. This information includes, but is not limited to, Plan provisions,

empIoyee data, and financial infomation. We performed an infomal exanination of the

Obvious characteristics ofthe data for reasonableness and consistency m aCcordan∞ With

Actuarial Standard ofPractice No. 23.

Future results may differ significantly from the current results presented in this analysis

due to such factors as the following: Plan experience di節erent from that anticipated by

the assumptions; Changes in assumptions; and changes in plan provisions or applicable

law.

Peter Hardcastle, CFA, FSA, MAAA, EA Date

Enrolled Actuary (EA#20-05197)
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 3. Demonstration that Fund is Eligible for Suspension 

3.03 Plan Sponsor’s Determination of Projected Insolvency 

Pursuant to §432(e)(9)(C)(ii), the plan sponsor has determined that the Plan would not be 

projected to avoid insolvency if no suspension of benefits were applied under the Plan, 

even though all reasonable measures to avoid insolvency have been taken. 

The Board of Trustee’s determination that the Plan is projected to become insolvent unless 

benefits are suspended is based on Exhibit 3.01a. Additionally, the Board of Trustees’ 

determination is based on the documentation in Section 5 of this Application. 

IBT730-0016
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements 

4.01 Demonstration that Limitations on Individual Suspensions are Satisfied 

Sample calculations demonstrating how the proposed suspension satisfies the individual 

limitations can be found in Exhibits 4.01a-4.01k. Please note the following: 

a. There are no increased benefits that have not become part of the accrued benefit

b. There are no benefit increases in effect for less than 60 months

1. Sample calculations applying the guarantee-based limitation under §432(e)(9)(D)(i)

a. Exhibit 4.01a - individual currently receiving Level Income annuity

b. Exhibit 4.01b - beneficiary currently receiving single life annuity

c. Exhibit 4.01c - Active participant

d. Exhibit 4.01d – Term Vested Participant

2. The Plan does not provide for benefits based on disability

3. Sample calculations applying the age-based limitation under §432(e)(9)(D)(ii)

a. Exhibit 4.01e - individual currently receiving Joint and Survivor annuity who

is between age 75 and age 79 on the last day of the month that contains the

proposed effective date of the suspension

b. Exhibit 4.01f - individual currently receiving single life annuity who is between

age 75 and age 79 on the last day of the month that contains the proposed

effective date of the suspension

c. Exhibit 4.01g - beneficiary currently receiving single life who is between age

75 and age 79 on the last day of the month that contains the proposed effective

date of the suspension

d. Exhibit 4.01h - Term Vested participant who has not commenced benefits who

is between age 75 and age 79 on the last day of the month that contains the

proposed effective date of the suspension

4.02 Demonstration that the Proposed Suspension is Reasonably Estimated to Enable the 

Fund to Avoid Insolvency 

1. Exhibit 3.02 shows a deterministic demonstration that, in accordance with

§432(e)(9)(D)(iv), the proposed benefit suspension is reasonably estimated to enable

the plan to avoid insolvency 

a. For each plan year during the extended period described in §432(e)(9)-

1(d)(5)(ii)(C), the Plan’s solvency ratio is projected to be at least 1.0

b. The Plan’s projected funded percentage at the end of the extended period is less

than 100%, however, neither the Plan’s solvency ratio nor its available resources

are projected to decrease in any of the last five plan years of the extended period

IBT730-0017
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements

2. This illustration is not required. The plan sponsor was not required to appoint a retiree

representative under §432(e)(9)(B)(v)(I)

3. Section 6.03 of this Application includes information on the actuarial assumptions

used for the illustrations herein

4.03 Demonstration that the Proposed Suspension is Reasonably Estimated to not 

Materially Exceed the Level Necessary to Avoid Insolvency 

Exhibit 4.03 shows a deterministic demonstration that, in accordance with 

§432(e)(9)(D)(iv), the proposed benefit suspension is reasonably estimated to not

materially exceed the level necessary to enable the Plan to avoid insolvency. For this 

purpose, the assumptions used are the same as those used for purposes of 4.02 of the 

Application. 

4.04 Demonstration that the Proposed Benefit is Distributed Equitably 

1. In accordance with §432(e)(9)(D)(vi), the proposed benefit suspension is distributed in

an equitable manner

a. Exhibit 4.04(1a) shows information about the Plan in aggregate

b. Exhibit 4.04(1b) is the demonstration of the distribution of benefit suspension

2. The proposed suspension provides for different treatment for different categories of

employment history

a. Exhibits 4.04(1a) and 4.04(1b) include the information broken out by category

b. The factors the Trustees considered in designing the proposed benefit suspensions

to be distributed in an equitable manner across the participant and beneficiary

population, which include:

 Risk of continued employer withdrawals (including the Plan’s largest

contributing employer) from the Plan and increasing the risk of additional

benefit reductions for participants in and out of pay status.

 Negative reaction by participants employed by Current Contributing

Employers that would further prompt withdrawals of Current Contributing

Employers’ participant groups and Current Contributing Employers, and

participants employed by Current Contributing Employers reasonably

likely to withdraw support for the Plan’s Application.

 History of benefit reductions for participants employed by Current

Contributing Employers.

 Failure of Former Contributing Employers to pay the full amount of

withdrawal liability or completely fund the benefits of their employees.

IBT730-0018
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements 

 Differences in historical and future employer contribution rates/increases

between Current Contributing Employers and Former Contributing

Employers.

 Negative reaction by Current Contributing Employers that are responsible

for funding current benefit payments and are also funding benefits for past

service for participants who were employees of Former Contributing

Employers.

c. Certain factors listed in Section 432(e)(9)(D)(I) through (XII) were taken into

account in designing the proposed suspensions

d. For each factor identified under Section 4.04(2)(b) of this revenue procedure that

is not one of the factors listed in §432(e)(9(D)(vi)(I) through (XI), an explanation

of why the factor is relevant

The Trustees took into account the potential negative reaction of Current 

Contributing Employers when deciding that benefit reductions for participants who 

earned a pension working for Current Contributing Employers would be reduced 

by 28% and benefit reductions for participants whose pension benefit is based on 

service for a Former Contributing Employer(s) would be reduced to 110% of the 

PBGC Guarantee. This factor is relevant because Giant is the Plan’s largest 

contributing employer and has been for decades. Eight O’Clock Coffee is the Plan’s 

second largest employer, and Giant and Eight O’Clock Coffee employ more than 

91% of the Plan’s participants. These two employers have endured annual 

contribution rate increases since 2009. Despite the imposition of these annual 

increases, their employees’ future accruals were reduced, and their adjustable 

benefits eliminated more than 10 years ago. These employers will continue to 

endure contribution rate increases through at least 2032 under the assumptions set 

forth in this Application (and perhaps beyond 2032 depending on labor 

negotiations) and their employees’ benefits will be reduced again under this 

Application. Giant and Eight O’Clock Coffee’s continued participation in the Plan 

is not only funding Current Contributing Employers’ participants’ current benefits, 

but the contributions help pay for past service earned by former employees of their 

companies, as well as for participants of Former Contributing Employers that left 

the Plan without funding their employees’ benefits in full.

The Trustees recognized that, in order to obtain the support of the Plan’s two largest 

contributing employers, they had to design a suspension plan that reduced the 

benefits for service with those employers the least amount possible. Former 

Contributing Employers that have withdrawn from the Plan have not paid for their 

employees’ benefits in full and have left the remaining employers holding the bag 

for the shortfalls. If either of the two largest employers were to withdraw (especially 

Giant) the Plan would likely not survive. Even if Giant paid its withdrawal liability, 

IBT730-0019
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements

the Plan would not recover the full amount needed to fund all Giant employees’ 

benefits due to the 20-year cap set forth in ERISA § 4219(c)(1)(B). Former 

Contributing Employers left the Plan willfully, in some cases to go non-union and 

save the money in benefit costs that Current Contributing Employers have been 

paying, and will continue to pay for the foreseeable future.

e. An explanation of how the differences in treatment under the proposed suspension

among the categories or groups identified result from a reasonable application of

the relevant factors

After thorough consideration of the factors set forth in subsection 2(b), the Plan 

proposes a different suspension in benefits for two different categories of service: 

(1) Benefits earned based on service with Current Contributing Employers will be 

reduced by 28%. Current Contributing Employers are Giant Food, Inc., Eight 

O’Clock Coffee, Washington Food, Inc., and Teamsters Union Local No. 730; (2) 

Benefits earned based on service with Former Contributing Employers will be 

reduced to 110% of the PBGC guaranteed benefit or by 28% if this results in a 

lower benefit1

. A Former Contributing Employer is an employer who formerly had 

an obligation to pay contributions to the Plan but is no longer paying contributions 

to the Plan.

Participants who have service with both a Current Contributing Employer and a 

Former Contributing Employer will have their benefit split between their service 

for a Current Contributing Employer and service for a Former Contributing 

Employer. Benefits earned based on service with both Current and Former 

Contributing Employers will be added together and increased, if necessary, to 

comply with the legal limitations set forth in Revenue Procedure 2017-43. 

The Trustees have proposed different suspensions for these two groups and 

designed them equitably based on a reasonable application of relevant factors. 

First, the Plan will not survive unless it retains its active participant population, all 

of whom are employed by Current Contributing Employers. Former Contributing 

Employers and their employees have left the Plan at an alarming rate over the last 

decade as contribution rates have steadily increased and the Plan reduced benefits. 

As discussed below, two of the Plan’s three largest employers in terms of active 

participants withdrew in 2012. In 2018, the Plan lost another contributing employer. 

To stop this trend, the Plan must demonstrate to Current Contributing Employers 

and the active participants they employ that there is an end in sight for contribution 

1

 A 28% reduction in the benefit relating to service with a Former Contributing Employer will only occur if the 

participant has service with both Former and Current Contributing Employers and a 28% reduction in the 

participant’s total benefit leaves the benefit after suspension greater than 110% of the PBGC guarantee, 

IBT730-0020
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements 

increases for which they receive no benefit, and which can adversely affect 

potential wage increases. It is important that the Plan offer competitive retirement 

benefit options in exchange for the rates at which Current Contributing Employers 

are paying and which are part of a competitive compensation package. Failing to 

provide a competitive pension benefit, the Trustees fear – and history has 

demonstrated – will result in more employers and bargaining groups withdrawing 

from the Plan and the Plan will not be able survive. 

The proposed suspensions in this Application demonstrate to participants of 

Current Contributing Employers that a final 28% reduction in their benefits, 

together with a reduction to 110% of the PBGC guarantee level for service with 

Former Contributing Employers are not only projected to save the Plan, but will 

allow participants employed by Current Contributing Employers to continue 

accruing benefits at the same rate they have since 2009. Participants now have a 

reason to remain in the Plan. The Trustees determined that reducing benefits based 

on service with Current Contributing Employers by 28% and continuing benefit 

accruals will make the Plan more attractive to participants who continue to be the 

life blood of the Plan and will result in their voting in favor of the proposed 

suspensions and against any potential employer-negotiated withdrawal. 

Likewise, the benefit suspensions and contribution increases provide Current 

Contributing Employers with more specific information about their future 

economic obligations to the Plan. Current Contributing Employers are responsible 

for funding all of the Plan’s benefits, including those benefits earned by Former 

Contributing Employers’ employees. Current Contributing Employers will know 

that future contribution increases will be assumed to be less than what are currently 

required under the Plan’s Rehabilitation Plan, but could cease all together within a 

decade. The contribution rate increases required under the Rehabilitation Plan are 

not sustainable, and Giant has negotiated a provision in its Memorandum of 

Understanding with Local No. 730 (MOA) that freezes its contribution obligation 

if the benefits are not reduced in accordance with a plan approved pursuant to 

MPRA. The contribution rate increases set forth in this Application are sustainable, 

realistic, and will provide an incentive for employers not to withdraw. 

In considering the different suspension percentages, the Trustees considered 

relative benefit levels and previous benefit reductions for participants employed by 

Current Contributing Employers. Current Contributing Employers’ participants 

had their benefits cut by more than 50% in 2009, as well as certain adjustable and 

other benefits eliminated. Since 2009, there have been annual 4.9% contribution 

increases, none of which have gone to enhance benefits for employees of Current 

Contributing Employers. Instead, those increases have helped keep the Plan afloat 

and fund the benefits of participants with service with Former Contributing 

Employers. Those with service with Former Contributing Employers have not 

IBT730-0021
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements 

endured the continual contribution increases with no corresponding benefit and 

have presumably moved on and obtained jobs that offer other retirement options 

and more attractive wage increases. Participants employed by Current Contributing 

Employers have paid more for less and have not derived any benefit from the annual 

pension contribution rate increases. Those participants with service with Former 

Contributing Employers have reaped the benefit of the Current Contributing 

Employers’ participants’ sacrifices. 

Prior to 2002, the Plan had no unfunded vested benefits, so employers that withdrew 

prior to 2002 paid no withdrawal liability. However, as the Plan’s financial 

condition deteriorated, participants whose benefits were earned with Former 

Contributing Employers that withdrew prior to 2002 still have to be paid. It is 

Current Contributing Employers and their employees who participate and have 

participated in the Plan that are paying for these benefits. 

Likewise, three Former Contributing Employers have withdrawn from the Plan 

after 2002, including two of the Plan’s three largest employers. None of these 

Former Contributing Employers have paid their full liability. Two did not pay the 

full allocation of unfunded vested liability and, for technical reasons, the third’s 

allocation of unfunded vested liability did not reflect the underfunding attributable 

to the service of its employees. The employers are: McKesson Drug Corporation, 

Jessup Logistics, and Adams Burch, LLC. 

In 2012, McKesson Drug Corporation (McKesson) withdrew from the Plan. At the 

time of its withdrawal, McKesson was the Plan’s second largest employer. 

McKesson was allocated $7,275,224 of unfunded vested liability using the 

presumptive method but the Plan was limited to demanding 80 quarterly payments 

of $165,919, with a present value of $7,037,333. As of February 1, 2021, McKesson 

has made 32 quarterly payments. 

While the difference between the allocation and present value of payments appears 

small, the Trustees view this cost difference as material. First, at the time of 

withdrawal, McKesson accounted for 11% of the contributions paid to the Plan and,

under the Rehabilitation Plan, McKesson’s future contributions were expected to 

cover 11.3% of the underfunding. Second, the unfunded vested liabilities were 

measured as of December 31, 2011, nearly a full year before McKesson ceased 

contributing to the Plan in December 2012. By December 31, 2012 the unfunded 

vested liabilities had grown to $101.9 million. From a prospective view, 

McKesson’s share of the burden of unfunded vested liabilities was $11.5 million. 

Third, the present value of withdrawal payments shown above assumes that 

quarterly payments are paid annually in advance (ERISA’s assumption) which 

ignores the delay between withdrawal, assessment, beginning of payments, and 

timing of payments within the year. Accounting for the actual timing of payments 

IBT730-0022
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements 

and expected payments yields a present value of $6.7 million. From this viewpoint, 

McKesson’s withdrawal left the Plan with a shortfall of $4.8 million.

Thus, McKesson will neither pay the allocated unfunded vested liability in full, nor 

the amount the Trustees had anticipated them paying in the Rehabilitation Plan. 

In 2012, Jessup Logistics (Jessup) took over certain warehouses that Giant Food 

had operated and assumed Giant’s collective bargaining agreement with Local No. 

730. Jessup did not assume a portion of Giant’s withdrawal liability but rather 

entered the Plan as a new contributing employer. A labor dispute followed, and 

Jessup withdrew from the Plan in late 2012. At the time of its withdrawal, Jessup 

was the Plan’s third largest employer. The Plan assessed withdrawal liability of 

$1,838,375, which Jessup paid in 5 installments. Had Jessup taken the contribution 

history of the Giant employees affected by the change of ownership of the 

warehouses the withdrawal assessment would have been significantly larger. This 

withdrawal financially harmed the Plan. 

In 2018, Adams Burch, LLC withdrew from the Plan. The Plan negotiated a lump 

sum settlement payment of $1.7 million. The lump sum amount was agreed upon 

as a compromise between $1,283,475 (the present value of 20 years’ payments 

using the valuation actuarial assumption of 8% return) and $2,084,000 (the 

withdrawal liability the Plan calculated). 

Although the Trustees have collected withdrawal liability from these employers, 

the amount collected is still not enough to pay the entire accrued benefits of the 

employees of those withdrawing employers. Instead, Current Contributing 

Employers have been and will continue to pay for the funding of these benefits. 

In sum, the Trustees have designed a suspension plan they believe is equitable. Current 

Contributing Employers and their participants (both active and non-active) have endured annual 

contribution increases since 2009 and will continue to incur contribution increases until at least 

2032. These annual increases have done nothing to enhance participants’ benefits, but merely have 

helped stave off insolvency. Participants employed by Current Contributing Employers had their 

benefits cuts by more than 50% in 2009 and will not see those benefits increased. If Former 

Contributing Employers had paid for their employees’ benefits, it is possible there would be more 

money available to fund wage increases for employees of Current Contributing Employers. While 

there are participants who were employed by Current Contributing Employers who retired prior to 

the benefit reductions and Rehabilitation Plan-imposed annual contribution increases, Current 

Contributing Employers have paid and continue to pay into the Plan to fund those participants’ 

benefits. Former Contributing Employers have not continued to fund their employees’ benefits. 

For this reason, the Trustees determined that it would not be equitable to impose the same 

suspensions on former employees of Current Contributing Employers than are being imposed on 

IBT730-0023
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements

employees of Former Contributing Employers. The sacrifices that Current Contributing 

Employers’ participants have made, and continue to make, have helped fund the benefits for 

Former Contributing Employers’ participants. The Former Contributing Employers’ participants 

voted or otherwise opted to leave the Plan and go non-union, and did not make the financial 

sacrifices that employees of Current Contributing Employers made. Former Contributing 

Employers have either not paid withdrawal liability in amounts sufficient to fully fund their 

employees’ benefits or withdrew when the Plan was financially sound and have not had to deal 

with the carnage that ensued after their withdrawal. Current Contributing Employers are funding 

not only the current benefits that their employees earn but are also funding the benefits of their 

former employees, and employees of Former Contributing Employers. After reviewing all these 

factors, the Trustees determined that it is fair and equitable that benefits earned for service with 

Current Contributing Employers be reduced by 28%, and that benefits earned for service with 

Former Contributing Employers be reduced to 110% of the PBGC guarantee amount. 

4.05 Participant Notice

The following is the plan sponsor’s method for satisfying the notice requirements under 

§432(e)(9)(F)

1. Exhibit 4.05 contains sample participant notices. Exhibits 4.05a-4.05h contain sample

benefit statements (without personally identifiable information)

2. Efforts that are being made to contact participants, beneficiaries and alternate payees

include; contracting with Accurint, an independent firm, to search for deceased

participants and out-of-date or invalid addresses. The Plan receives a monthly report

from Accurint for review and also perform searches on an as-needed basis

3. Steps the plan sponsor has taken to ensure that any electronically delivered notices are

reasonably accessible to the recipients include; the fund does not distribute

electronically

4. A list of

a. Employers that have an obligation to contribute within the meaning of section

4212(a) of ERISA

These include all who have obligation to contribute but excludes any employer

paying withdrawal liability:

Giant Warehouse

8580 Dorsey Run Road

Jessup, MD 20794

Eight O’Clock Coffee

3300 Pennsy Drive 

Landover, MD 20785

Giant Recycling Local 730 Union Staff

2001 Rhode Island Ave, NE

IBT730-0024
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 4. Demonstration that the Proposed Suspension Satisfies the Statutory 

Requirements

8580 Dorsey Run Road 

Jessup, MD 20794

Washington, DC 20018

Washington Food

8908 Bells Mills Road 

Potomac, MD 20854

b. Employee organizations representing participants under the Plan;

Warehouse Employees Union Local No. 730 

IBT730-0025
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

5.01 Measures Taken to Avoid Insolvency 

A detailed description of measures taken to avoid insolvency over the past 10 plan years 

immediately preceding the 2020 plan year, is provided below: 

Plan Design 

In its 2008 Pension Protection Act (PPA) certification, the Plan’s actuary certified that 

the Plan was “Safe” or in the “Green Zone.” As of December 31, 2007, the Plan had 

assets valued at approximately $202 million, and Plan assets appeared to be growing. At 

the end of 2007, the Plan’s funding percentage was 109%. The Plan had 2,213 

participants, of which 941 were active participants, 651 were retired or separated from 

service and receiving benefits, and 621 were retired or separated from service and entitled 

to future benefits. 

As was the case for most other multiemployer pension funds, the unprecedented global 

financial crisis of 2008 had a devastating effect on the Plan. That year alone, the Plan’s 

investments lost 29.1%. The Plan incurred a net asset loss of almost $65 million, or 

approximately 33% of its total assets. The Plan’s total assets went from approximately 

$202 million at the end of 2007 to approximately $137 million at the end of 2008. The 

Plan’s funding percentage went from 108.8% to 88.7%. As a result, for the 2009 Plan 

Year, the Plan was projected to have a funding deficiency within the next four years, and 

the actuary certified the Plan as “Critical” or in the “Red Zone.”

Rehabilitation Plan 

In 2009, the Trustees adopted a Rehabilitation Plan. In so doing, the Trustees undertook 

an analysis of the steps required to return the Plan to “Safe” status. This included 

eliminating the payment of all lump sum benefits, developing a rehabilitation plan, 

imposing employer contribution rate surcharges, and eliminating adjustable benefits. 

Because the Plan was certified as “Safe” in 2008, it availed itself of the Worker, Retiree 

& Employer Recovery Act of 2008, which allowed the Board to develop a Rehabilitation 

Plan designed to return the Plan to “Safe” status in thirteen (13) years as opposed to ten 

(10) years. The Board did not elect to postpone the development of the Rehabilitation 

Plan by electing to use the 2008 PPA zone certification for 2009 as permitted under the 

law but proactively accepted Critical Status and developed a Rehabilitation Plan. 

The Rehabilitation Plan applied to collective bargaining agreements renewed or extended 

after December 25, 2009. Based on the Plan’s reasonably anticipated experience and 

actuarial assumptions, the Rehabilitation Plan set forth revised employer contribution and 

benefit structures (the Schedules) which, if adopted by the Plan’s Contributing Employers 

(the Bargaining Parties), could reasonably be expected to enable the Plan to emerge from 

“Critical” status by the end of the thirteen (13) year Rehabilitation Period. The required 

schedules were the “Preferred Schedule” and the “Default Schedule.” The Trustees 

strongly recommended that the Bargaining Parties adopt the Preferred Schedule of 

contribution increases and benefit reductions. The Rehabilitation Plan automatically 

IBT730-0026
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

imposed the Default Schedule on Bargaining Parties that failed to adopt the Preferred 

Schedule. 

The Rehabilitation Plan imposed an automatic surcharge of 5% during the initial year of 

the Rehabilitation Plan and 10% in subsequent years upon any employer who failed to 

adopt a collective bargaining agreement consistent with either the Preferred or Default 

Schedules.

The Preferred Schedule required a contributing employer to annually increase its 

contribution rate during the Rehabilitation Period, eliminated all adjustable and lump sum 

benefits and certain early pension retirement options, and reduced the accrual rate (the 

rate at which pension benefits increase) for future benefit accruals. Specifically, the 

Preferred Schedule required compounded contribution rate increases of 4.9% annually. 

Under the Preferred Schedule, all early retirement options and adjustable and lump sum 

benefits were eliminated except for the “30 & Out” Early Retirement Pension. In 

addition, under the Preferred Schedule, the accrual rate for future benefit accruals was 

reduced by more than 50% from 4.17% of contributions to 2.0% of contributions. 

Thereafter, the accrual rate was reduced from 2% to 1% after the pension had been in 

effect for 60, 84, 96, or 120 months, depending on the terms of the applicable collective 

bargaining agreement. Finally, under the Preferred Schedule, the Plan’s Normal 

Retirement Age was increased to 62 years of age for service accrued after the date of 

adoption of the Preferred Schedule. 

The Rehabilitation Plan also contained a Default Schedule, which required compounded 

annual employer contribution rate increases of 2.3%. The future service accrual rate for 

participants whose employer adopted the Default Schedule was reduced to 1% of the 

contribution rate in effect. Under the Default Schedule, all early retirement and adjustable 

benefits and lump sum payments were eliminated, and the Plan’s Normal Retirement Age 

was increased to 62 years of age for service accrued after the date of adoption or 

imposition of the Default Schedule. 

In comparison, the benefits under the Default Schedule were less valuable than the 

benefits under the Preferred Schedule. Overall, the benefits provided under the Default 

Schedule had a value that was approximately 60% of the value of the benefits provided 

under the Preferred Schedule. This is because the accruals are lower under the Default 

Schedule and the unreduced pension after 30 years of service was eliminated. The 60% 

figure applies to the Plan as a whole. For each participant, the value of the Default 

Schedule compared to the value of the Preferred Schedule depended on an individual’s 

circumstances. All Contributing Employers adopted the Preferred Schedule. See 2009 

Rehabilitation Plan attached at the end of Exhibit 7.06a.

2014 Updated Rehabilitation Plan 

In 2012, two of the Plan’s larger employers (Jessup Logistics and McKesson Drug) 

withdrew from the Plan. Both Jessup Logistics and McKesson Drug began systematically 

IBT730-0027
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

ramping down operations in 2011. When these two employers finally withdrew in 2012, 

the Plan had lost 422 active employees and more than $2 million in annual employer 

contributions. In 2014, the Trustees determined that based on reasonable actuarial 

assumptions and upon exhaustion of all reasonable measures, the Plan could not 

reasonably be expected to emerge from critical status by the end of its Rehabilitation 

Period (December 1, 2024). Accordingly, the Trustees updated the Rehabilitation Plan to 

provide that the Plan would emerge from Critical Status at a time later than the end of the 

extended Rehabilitation Period or to forestall possible insolvency (as defined by ERISA 

Section 4245). 

The 2014 Rehabilitation Plan was based on reasonable assumptions about how the Plan’s 

assets and liabilities would change in the coming years, particularly as a result of changes 

in the Plan’s level of participation. The withdrawals of Jessup Logistics and McKesson 

Drug caused the Plan to lose more than 1/3 of its active participants. The Trustees 

considered alternatives to enable the Plan to emerge from Critical Status by the end of the 

Rehabilitation Period. 

The alternatives considered were based on projections by the Plan’s actuary using 

reasonable actuarial assumptions. The Plan’s actuary projected that, with no further 

changes to the Plan’s current plan of benefits, Employer contribution rates would have to 

be increased by 25% every year from when the current collective bargaining agreements 

expired until 2024 for the Plan to emerge from Critical Status by the end of the 

Rehabilitation Period. This would have raised the hourly contribution rate of the largest 

contributor from $5.70 per hour to $53.09 per hour. Alternatively, the Plan’s actuary also 

projected that, with the elimination of all future benefit accruals and all adjustable 

benefits, Employer contribution rates would have to be increased by 18% annually for the 

Plan to emerge from Critical Status by the end of the Rehabilitation Period. This would 

raise the hourly contribution rate of the largest contributor from $5.70 per hour to $29.83 

per hour. 

The Trustees considered whether it would be reasonable to expect the Plan’s largest 

employer, and thereafter the remaining large contributors, and the Union to negotiate the 

increased Employer contributions necessary for the Plan to emerge from Critical Status 

prior to the end of the Rehabilitation Period. The Trustees concluded that the contribution 

rate increases under the alternatives discussed above were not reasonable and likely could 

not be negotiated. Solutions in between these two extremes also were not likely 

achievable. Therefore, the possible and likely outcome of collective bargaining over these 

types of alternatives would be negotiated withdrawals from the Plan. Upon a mass 

withdrawal, while the Employer withdrawal liability payments are fixed, participant 

benefits are at risk for further reduction if Employer liability payments are not collected, 

and the Plan becomes insolvent, thus reducing benefits to the PBGC guaranteed levels. 

The Trustees noted that, since the contributions of the Plan’s largest employer make up 

over 50% of the Plan’s contribution income, and that the bargaining parties best know the 

competitive market and the employer’s potential future in the market, it would be most 

IBT730-0028
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

prudent to be informed by the parties’ negotiations. The negotiation with the largest 

Employer yielded a 4.9% annual rate increase. The Trustees reviewed that result and had 

no objective reason to reject it. Therefore, the Trustees adopted the 4.9% annual increase 

for the remaining bargaining parties as collective bargaining agreements expired. See 

2014 Rehabilitation Plan attached as Exhibit 7.09b.

2020 Rehabilitation Plan 

In 2018, Adams Burch withdrew from the Plan, taking with it another 56 active 

participants and almost $100,000 in annual employer contributions. On March 29, 2019, 

the Plan’ actuary certified that the Plan was in Critical and Declining Status for the 2019 

Plan Year. By the end of 2019, the Plan had 312 active participants, and 816 participants 

and beneficiaries who were either receiving benefits or entitled to receive benefits in the 

future. The Trustees adopted the updated 2020 Rehabilitation Plan, which noted that the 

Plan’s actuary now projected that employer contribution rates beginning with 2020 

collective bargaining agreement anniversaries would require 60% increases every year 

from when the current contracts expired until 2024 for the Plan to emerge from Critical 

Status by the end of the Rehabilitation Period. The Trustees again concluded that 

contribution rate increases of 60% were not reasonable and likely could not be 

negotiated. The Trustees determined that the possible and likely outcome of collective 

bargaining over such extreme rate increases would be negotiated withdrawals from the 

Plan. The Trustees observed that negotiations with the Plan’s largest employer resulted in 

4.9% annual contribution rate increases, and that contribution rate increases above that 

amount would further hamper the employer’s ability to remain competitive and would 

potentially jeopardize the employer’s continued participation in the Plan. The Trustees 

adopted annual 4.9% increases for the remaining bargaining parties as contracts expired. 

In sum, the Trustees have done everything allowable under pre-MPRA law to avoid 

insolvency from a plan design perspective. In 2010, the Trustees adopted a Rehabilitation 

Plan that reduced future accruals and eliminated all adjustable benefits, while at the same 

time imposing annual compounded contribution rate increases of 4.9%. See 2020 

Rehabilitation Plan attached as Exhibit 7.09a.

Investments

In 2005, the Plan’s investments earned 9.6%, exceeding the Plan’s actuarial assumption 

of 8%. At the end of 2005, the funding ratio was 106% -- meaning the Plan had 6% more 

in assets than was necessary to pay all of its liabilities. In 2006, the Plan’s investments 

earned 13.4% -- exceeding the Plan’s actuarial assumption by 5.4%. At the end of 2006, 

the Plan was 107% funded. In 2007, the Plan’s investments earned 7.4% -- 0.6% below 

the Plan’s actuarial assumption. Nevertheless, at the end of 2007, the Plan was 109% 

funded. Under the PPA, the Plan was certified as “Safe/Green Zone” for 2008. At the 

end of 2007, no one anticipated the staggering losses that would occur in 2008. The 

Plan’s actuary in the 2008 Valuation Report stated that: “[t]he funding ratio is expected to 

IBT730-0029
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

increase over the next several years from 109% to 125%.” This did not include any future 

contribution increases. 

During 2008, financial markets experienced catastrophic losses and this Plan was not 

spared. The Plan’s investments lost 29.1%. From an actuarial standpoint, the Plan lost 

37.1% (factoring in the Plan’s actuarial assumed rate of return of 8%). 

Recognizing that the Plan would require increasingly greater investment income to cover 

increasing benefit expenses, and in consultation with their investment consultant, 

Investment Performance Services (IPS), the Trustees adopted and implemented an asset 

allocation strategy utilizing best practices for risk control, diversification, and return 

enhancement. The Trustees also realized that this increased reliance on investment 

income meant the Plan needed to protect itself from extreme market fluctuations and 

required an investment portfolio and asset allocation that could increase investment 

return without adding imprudent, additional risk. With these goals and objectives, the 

Trustees implemented a diversified investment strategy. Since 2009, the Plan’s 

investments have outperformed market benchmarks 9 out of 10 years. Over the past 10 

years, the Plan’s investments have earned 10.3% (compared to the benchmark return of 

8.4%) -- exceeding the Plan’s actuarial assumption by 2.3% and putting it in the 2nd

percentile of its peer group (consisting of approximately 400 other multiemployer defined 

benefit plans). 

The Trustees have adopted an Investment Policy Statement, which they and IPS 

continually monitor and review. The Trustees occasionally make changes to the 

investment allocation after consulting with IPS, and in accordance with formal 

recommendations from IPS. The Plan’s current investment portfolio is well-diversified, 

and is allocated as follows: U.S. Large Cap Equities 29.7%, U.S. Small/Mid Cap 9.7%, 

International Equities 8.1%, Fixed Income Core 0.8%, Fixed Income High Yield 6.8%, 

Real Estate 25.7%, Opportunistic Strategies 8.2%, Global Tactical Asset Allocation 

5.3%, Private Equity 5.1% and cash 0.5%. The Plan’s asset allocation is not overly reliant 

on any one asset class. 

In sum, prior to 2008, currently, and during all periods in between, the Plan has 

maintained a well-diversified investment program. The diversification is by asset class 

(currently 11) and number of managers (ranging from 13-17). With the assistance of IPS, 

over time, additional asset classes have been added to the portfolio to take advantage of 

market opportunities. In addition, the Plan’s assets are periodically rebalanced in 

accordance with the Plan’s Investment Policy Statement. For example, if the Plan’s 

equity allocation approaches the high end of the permitted range for an asset class, a 

portion is liquidated with the proceeds allocated to an underweight asset class(es). The 

majority of the Plan’s assets are actively managed with investment managers who have 

generally added value (net of fees) in excess of their respective benchmarks. The 

Trustees, with the guidance of their investment consultant, have avoided taking 

imprudent or unnecessary risk to “catch up,” but rather followed a long-term game plan, 

which has and continues to work extremely well. 

IBT730-0030
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

Employer Withdrawals 

The Trustees recognize that employer withdrawals from the Plan are a serious threat to 

the Plan’s solvency, particularly withdrawals by employers that do not pay their full 

withdrawal liability due to company closures, bankruptcies, liquidations, de minimis

reductions, and ERISA’s 20-year cap limitation. Employer withdrawals are particularly 

important to the Plan since it has only four contributing employers. 

Although the Trustees cannot generally control whether an employer withdraws, the 

Trustees have taken measures to protect the Plan’s solvency with respect to employer 

withdrawals. The Plan has been diligent about assessing and collecting withdrawal 

liability from all withdrawing employers. Since 2012, three employers have withdrawn 

from the Plan. Two of those employers were the Plan’s second and third largest 

employers. As described below, the Plan has successfully assessed and collected 

withdrawal liability from these withdrawing employers. 

In 2012, McKesson Drug Corporation (McKesson) withdrew from the Plan. At the time of 

its withdrawal, McKesson was the Plan’s second largest employer. McKesson was 

allocated $7,275,224 of unfunded vested liability using the presumptive method but the 

Plan was limited to demanding 80 quarterly payments of $165,919, with a present value of 

$7,037,333. As of February 1, 2021, McKesson has made 32 quarterly payments. 

While the difference between the allocation and present value of payments appears small 

the Trustees view of the cost of this withdrawal is rather different. First, at the time of 

withdrawal, McKesson accounted for 11% of the contributions paid to the Plan and under 

the Rehabilitation Plan McKesson’s future contributions were expected to cover 11.3% of 

the underfunding. Second, the unfunded vested liabilities were measured as of December 

31, 2011 nearly a full year before McKesson ceased contributing to the Plan in December 

2012. By December 31, 2012 the unfunded vested liabilities had grown to $101.9 million. 

From a prospective view, McKesson’s share of the burden of unfunded vested liabilities 

was $11.5 million. Third, the present value of withdrawal payments shown above assumes 

that quarterly payments are paid annually in advance (ERISA’s assumption) which ignores 

the delay between withdrawal, assessment, beginning of payments, and timing of payments 

within the year. Accounting for the actual timing of payments and expected payments 

yields a present value of $6.7 million. From this viewpoint, McKesson’s withdrawal left 

the Plan with a shortfall of $4.8 million. 

Thus, McKesson will neither pay the allocated unfunded vested liability in full, nor the 

amount the Trustees had anticipated them paying in the Rehabilitation Plan.

In 2012, Jessup Logistics (Jessup) took over certain warehouses that Giant Food had 

operated and assumed Giant’s collective bargaining agreement with Local No. 730. 

Jessup did not assume a portion of Giant’s withdrawal liability but rather entered the Plan 

as a new contributing employer. A labor dispute followed, and Jessup withdrew from the 

IBT730-0031
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

Plan in late 2012. At the time of its withdrawal, Jessup was the Plan’s third largest 

employer. The Plan assessed withdrawal liability of $1,838,375, which Jessup paid in 5 

installments. Had Jessup taken the contribution history of the Giant employees affected 

by the change of ownership of the warehouses the withdrawal assessment would have 

been significantly larger. This withdrawal did financial harm to the Plan. 

In 2018, Adams Burch, LLC withdrew from the Plan. The Plan negotiated a lump sum 

settlement payment of $1.7 million. The lump sum amount was agreed upon as a 

compromise between $1,283,475 (the present value of 20 years’ payments using the 

valuation actuarial assumption of 8% return) and $2,084,000 (the withdrawal liability the 

Plan calculated). 

While the Plan has successfully collected withdrawal liability, it is important to note that 

since 2012, three of the Plan’s seven employers (and two of its largest) have withdrawn. 

These withdrawals have adversely affected the Trustees’ efforts to keep the Plan solvent 

because the withdrawal liability collected is still not enough to pay the entire accrued 

benefits of the employees of those withdrawing employers. 

5.02 Fund Factors 

In accordance with §432(e)(9)(C)(ii), the following specific information was taken into 

account by the plan sponsor in determining that all reasonable measures have been taken 

to avoid insolvency: 

1. For the 10 plan years immediately preceding 2020:

a. Contribution levels:

Participating employers in the Plan contribute on behalf of covered employees on

a fixed dollar per hour basis. The contribution schedule, basis, and amounts are

determined through collective bargaining between the parties. In 2008,

contribution rates ranged from .65 per hour on the low end to $3.48 on the high

end. Today, those rates range from $3.24 on the low end to $7.24 on the high end,

with increases to $10.62 by 2028. The information concerning contribution levels

for the past 10 years is included in Section 6.04

b. Benefit accrual levels are as follows:

For service prior to the adoption of the Rehabilitation Plan, participants receive a

monthly life annuity reducing to 55% of the original amount after a specific number

of months, equal to (a) 4.17% of all contributions required to be made on a

participant’s behalf on and after January 1, 1978; plus (b) Percentage of

Contributions Benefit.

The Percentage of Contribution Benefit is X% of all contributions required to be

made on a participant’s behalf prior to January 1, 1978, where “X” is determined

from the following table:

IBT730-0032
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency

Participant’s 

Age on 

January 1, 

1978

X%

Participant’s 

Age on 

January 1, 

1978

X%

60 or over 12.0 49 7.6

59 11.6 48 7.2

58 11.2 47 6.8

57 10.8 46 6.4

56 10.4 45 6.0

55 10.0 44 5.6

54 9.6 43 5.2

53 9.2 42 4.8

52 8.8 41 4.4

51 8.4 40 and under 4.17

50 8.0

Note that the percentage for those aged 40 and under on January 1, 1978 is the same 

4.17%. All participants ages over 40 will now be over age 80 and so not impacted 

by the suspension (although a few widow(er)s may be impacted. 

The period before the benefit reduces was originally 60 months. This was extended 

under certain contracts as follows: 

For those employers who elected through a collective bargaining agreement to 

make a supplemental (not benefit bearing) contribution beginning January 1, 

1998, the monthly life annuity above reduces to 55% of the original amount 

after 96 months instead of 60. 

Effective for participants who earned an hour of service on or after January 1, 

1999, 24 months is added to the number of months described above (i.e. 60 

months and 96 months for a total of 84 and 120 months, respectively). 

For service after the adoption or imposition of a Rehabilitation Benefit Schedule: 

Preferred Schedule: 2% of all contributions required to be made on a 

participant’s behalf on and after the date of adoption of the Preferred Schedule, 

reducing to 1.0% after the pension has been in effect for 60, 84, 96, or 120 

months. 

IBT730-0033
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency

Default Schedule: 1.0% of all contributions required to be made on a participant’s 

behalf on and after the date of adoption or imposition of the Default Schedule. 

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

As discussed above, the Trustees adopted a Rehabilitation Plan which applied to all

collective bargaining agreements entered into or extended after December 25, 2009,

and which, among other actions, eliminated all adjustable benefits under the Default

Schedule and all adjustable benefits except for the “30 & Out” Early Retirement

Pension under the Preferred Schedule. Specifically, the Rehabilitation Plan

eliminated the following benefits: Disability lump sum benefit, all lump sum Death

Benefits, and all Early Retirement Benefits (except the 30 Years & Out).

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

The Plan had no prior suspension under §432(e)(9). 

e. Measures undertaken by the plan sponsor to retain or attract contributing employers

The Trustees have attempted to maintain the Plan’s existing contributing employer 

base by communicating with the bargaining parties during negotiations and taking 

into account the bargaining parties’ knowledge and understanding of the industry. 

Based on this dialogue, the Trustees have agreed to accept collective bargaining 

agreements that provide for annual 4.9% contribution increases, and which have 

motivated the current Contributing Employers to remain in the Plan. The Trustees 

could have imposed higher contribution rate increases when they updated the first 

and subsequent updated versions of the Rehabilitation Plan. The Trustees 

recognized that imposing unrealistic contribution rate increases would result in the 

loss of more Contributing Employers.

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

the active participants

The Plan for many years offered several ancillary benefits like disability and death

benefits and certain early retirement subsidies. The December 25, 2009 Rehabilitation

Plan eliminated all subsidies and ancillary benefits under the Default Schedule and all

subsidies and ancillary benefits under the Preferred Schedule except the “30 & Out”

Early Retirement Pension. The Trustees feared that eliminating the “30 & Out” pension

would likely have driven employee groups to withdraw from the Plan.

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

industry generally

The Plan’s participants are primarily engaged in operating warehousing and storage

facilities for general merchandise, refrigerated goods, and other warehouse products.

IBT730-0034
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

The compensation levels (i.e., wages) for the Plan’s largest Employer range from $13 

per hour to $26.33 per hour, with the average base rate being $21.37 per hour. 

Employees hired in 2015 and earlier have an average base wage rate of $25.24 per hour. 

The average base salary for an employee in the transportation and material moving 

industry in 2018 was $21.51 per hour. See June 18, 2018 Bureau of Labor Statistics 

(BLS) Press Release. The Plan’s participants’ wages are generally higher than the 

industry average, but the costs of their benefits far exceed the market average. The 

average retirement costs for private industry material movers is $1.79 per hour. BLS 

Press Release. The retirement costs for Plan participants range from $1.90 to $7.60 per 

hour, with a majority (72%) of the Plan’s participants on which contributions are made 

are at $7.24 per hour. The industry average for health insurance costs is $3.38 per hour, 

while Plan participants’ health insurance costs range from $6.88 per hour to $8.50 per 

hour. Put another way, on average, retirement and health costs comprise 61% of Plan 

participants’ compensation, while the industry average is 24%.

Although, on average, unionized employees have traditionally received higher wages 

than non-union employees, in recent years, non-union workers’ wages have increased 

more rapidly than unionized workers’ wages. The benefit costs for unionized workers 

are adversely affecting their wages. The increase in benefit costs has hurt the employees 

and industry and was caused (in substantial part) by increases in employer contribution 

rates for the Plan’s largest employer from $3.13 in 2008 to $7.60 in 2021. Under the 

Rehabilitation Plan, the contribution rate will be $10.62 by 2028. This means that by 

2028, the pension contribution alone will be almost 60% of the highest industry wage. 

This does not take into account health insurance costs, which also continue to increase. 

While there may be some increase in the wages between now and 2028, contributing 

employers that are forced to pay such high contribution rates will likely be less able to 

provide significant wage increases. This adversely effects the employers’ 

competitiveness in the marketplace and threatens their viability. 

4. Competitive and other economic factors facing contributing employers.

A number of competitive and economic factors over the past 40 years have negatively

affected the Plan’s contributing employers and directly impacted the Plan’s solvency.

For years the Plan was heavily reliant on the unionized retail food industry. Of the 30

employers that have withdrawn from the Plan since 1980, approximately 10 were in

the retail food industry (including certain divisions of Giant Food, which is the Plan’s

largest contributing employer). Competition from non-union competitors has

devastated the Plan’s contribution base.

In 1980, the Plan had 28 contributing employers. Today, there are four contributing

employers, one of which is the sponsoring union. Five divisions of the Plan’s largest

employer no longer contribute to the Plan. In the 1970s and 80s, when the basic

structure of contributing employer labor contracts was set, nearly ALL of the

Washington D.C. metropolitan area food retailers were covered by union contracts

IBT730-0035
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

with very similar terms. This is important because these contracts set the whole 

market labor costs. When nearly all employers were union, the employers could 

accept the contract labor costs and pass along any increases in prices throughout the 

market. Simply put, everyone had the same labor costs so labor costs were NOT a 

competitive factor. 

In the 1970s, the companies and unions made a big bet – that the Washington D.C, 

metropolitan area, retail food market would stay union and therefore the main 

competitors would have the same labor costs. Because labor costs were not a 

competitive problem they could create a contract that had: (1) High straight-time 

wages; (2) Defined benefit pensions with no employee contribution for both full-time 

and part-time employees despite the fact that in labor markets generally few part-time 

employees receive pension benefits from the employer; and (3) Expensive active 

employee health benefits for both full-time and part-time employees with a 

maintenance of benefits clause at employer expense, although in general labor markets 

part-time employees receive modest or no health benefits paid by the employer. Many 

of these high cost items linger in today’s labor contracts. However, the old world where 

all major food employers had the same labor costs was turned upside down. The level 

playing field is gone and now most of the retail food market share is captured by nonunion competitors that are not burdened by the high benefit costs that hamper unionized 

employers. 

Additionally, during the past 10 years, there has been a shifting demographic whereby 

the “baby boomer” generation has been retiring in record numbers, and the unionized 

workforce employed by the Plan’s contributing employers has steadily declined. In 

2010, the Plan had 925 active participants and 1,331 retired and deferred vested 

participants. As of 2020, there were 312 active participants and 1,701 retired and 

deferred vested participants. In 2010, the ratio of retirees/deferred vested participants 

to active participants was approximately 1.4 to 1; today the ratio is almost 5.5 to 1. 

The Plan has simply been unable to replace retirees with new hires on a one-to-one 

basis, which has hurt the Plan. 

The trend of workers retiring and not being replaced by active employees has 

negatively impacted the Plan’s funding over the years. In 2000, the Plan received 

approximately $5,050,034 in employer contributions and paid $3,255,470 in benefits. 

By 2010, the cash flow was reversed, and the Plan took in employer contributions of 

$6,393,573 and paid $12,644,145 in benefits. By 2019, the Plan’s negative cash flow 

was simply crippling, with the Plan receiving $3,879,728 in contributions and paying 

$20,591,785 in benefits. Since 2000, the Plan’s contribution income declined by 

almost 24%, while its benefit obligations increased almost 700%. This demographic 

shift has caused the Plan, which has historically been dependent on contribution 

income, like many other multiemployer plans, to grow increasingly dependent on 

investment income to cover the differences between contributions received and 

benefits paid. While this was manageable when the gap between contribution income 

IBT730-0036
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency

and benefit payments was reasonable, it is no longer a viable plan as the gap has 

grown considerably. 

Employers have been moving away from establishing or participating in defined benefit 

plans and are instead moving into defined contribution plans. Such plans are generally 

less expensive for the employer than defined benefit plans, and they shift the 

investment risk away from the employer. The availability of such plans makes it harder 

to attract new employers to the Plan. Employers are unwilling to accept exposure to 

withdrawal liability, or the risk associated with economic market fluctuations they 

know can leave them with a volatile contribution obligation. 

5.03 How Funds Factors Were Taken Into Account 

The factors listed under section 5.02 of this Application were taken into account in the 

determination that all reasonable measures have been taken to avoid insolvency, as follows 

1. Contribution levels

Since 2008, the Trustees have taken all reasonable measures with respect to employer 

contribution levels. Since 2010, contributions have increased annually by 4.9% on a 

compounded basis. While employer contributions have increased annually, benefits 

have not increased at all. Participants’ benefits were cut in 2010 and there have been 

no increases since. Health care costs for participants are more than twice the industry 

average, yet participants’ health benefits were cut in 2016. Today, the average base 

wage for participants employed by Giant (which accounts for 215 of the Plan’s 312 

participants) is $25.24 for participants hired in 2015 and prior, and $21.37 for 

participants hired thereafter. Giant’s pension contribution rate is $7.24 per hour for 

warehouse employees, and $6.65 per hour for recycling employees, and its health plan 

contribution rate is $8.34 per hour. By 2028, Giant’s pension contribution rate will 

approach $11 per hour, which is close to the average entry level wage rate for the 

industry. 

The current contribution rates are economically stifling for the Plan’s contributing 

employers. Given the contribution increases over the years, the substantial increase of 

non-union competitors, and the continued withdrawal of contributing employers, it is 

clear that additional contribution rate increases (especially those set forth in the 

Rehabilitation Plan) are not sustainable for the Plan’s remaining contributing 

employers if they wish to remain competitive and stay in business. As of January 1, 

2021, the Plan has four (4) contributing employers. The result of further contribution 

increases will be more employer and participant group withdrawals. 

Accordingly, for purposes of this Application, the Trustees agreed that contribution 

rate increases would be equal to those called for under the Rehabilitation Plan until 

IBT730-0037
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

2027. Those contribution increases are annual 4.9%, compounded, after which they are 

assumed to be 2% annually for 5 years and then 0.0% thereafter (this assumption does 

not prevent the bargaining parties from negotiating higher increases). In developing 

these rates, the Trustees gave serious consideration to macroeconomic factors, the 

financial strength of contributing employers, competition in the marketplace, the 

relationship between contribution levels and benefit levels, and expected changes in 

wage packages over the next several years. In doing so, the Trustees determined that it 

was reasonable to require contribution increases at the rates prescribed in the 

Rehabilitation Plan for the next 6 years, followed by additional increases at a rate less 

than what is required under the Rehabilitation Plan, with the understanding that, in 11 

years, the employers might not have to incur any additional increases. The Trustees 

determined that such increases will avoid insolvency, keep employers financially 

viable, and help retain and attract qualified employees. 

2. Levels of Benefit accruals

As explained above, the Trustees reduced benefit accruals from 4.17% to 2% over the 

last 10 – 12 years. The benefit reductions, when coupled with the required annual 

contribution increases, have resulted in employers paying more for their employees to 

receive a smaller benefit. This has caused many employers – and increasingly rankand-file union members – to support their employers’ withdrawal from the Plan. In 

reviewing levels of benefit accruals, the Trustees concluded, in consultation with the 

Plan’s actuary, that any further reduction in the future accrual rate beyond that 

contained in the Rehabilitation Plan would have a detrimental effect on the Plan by 

undermining contributing employers’ ability to attract and retain employees. It would 

also severely undermine support of the Plan’s remaining participants. Further, it was 

determined that further reductions in accruals would have an immaterial effect on the 

solvency of the Plan because the Plan is projected to become insolvent by 2032. There 

is just not enough time for additional reductions in accrual rates to have a significant 

impact on the Plan’s solvency. Accordingly, the Trustees concluded that maintaining 

future accruals at the rates set forth in the Rehabilitation Plan is a reasonable measure 

to avoid insolvency. 

3. Prior reductions of adjustable benefits under §432(e)(8)

Section 5.02(3)(c) above details the reductions in adjustable benefits the Trustees made 

after adopting the Rehabilitation Plan. Adjustable benefits include essentially all 

subsidized benefits other than those in pay status prior to 2010 and disability benefits 

in pay status at any time. The Rehabilitation Plan eliminated the following adjustable 

benefits for all participants: 

 The Disability Lump Sum Benefit Retirement;

 All Lump Sum Death Benefits; and

 All Early Retirement Benefits (except the 30 Years & Out)

IBT730-0038
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency

Under the Rehabilitation Plan’s Default Schedule, the following adjustable benefits 

were also eliminated 

 The 30 Years and Out Early Retirement Pension

4. Prior benefit suspensions under Section 432(e)(9).

The Plan has not implemented prior benefit suspensions under Section 432(e)(9). 

5. Measures undertaken by the plan sponsor to retain or attract contributing employers

The Trustees adopted a Rehabilitation Plan that took into account employers’ 

knowledge and understanding of the industry when establishing contribution rate 

increases and reducing benefit accruals. They understood that imposing unrealistic 

contribution rate increases would result in the loss of the remaining contributing 

employers and further benefit accruals would impede contributing employers from 

attracting qualified employees. The Trustees believe that the measures proposed in this 

Application, as a whole, will provide the Plan its best chance of retaining – and possibly 

attracting – employers.

6. Impact on plan solvency of the subsidies and ancillary benefits available to active

participants

Effective January 1, 2010, the Trustees eliminated all subsidies, disability benefits, and 

early retirement benefits under the Rehabilitation Plan’s Preferred Schedule except the 

“30 and Out” Pension. The Trustees balanced the savings from eliminating this benefit 

with the potential loss of long-time employees that might have resulted from 

eliminating the benefit. After due consideration, the Trustees determined that retaining 

employees who were eligible or near eligibility for this benefit was more valuable to 

the Plan’s solvency than the relatively modest savings from eliminating it. The Trustees 

also noted that most of the subsidized benefits are paid to retired participants in pay 

status and that, at the time those benefits were earned, the Plan did not receive 

contributions commensurate with the value of those benefits. The disproportionality of 

the subsidies compared to the contribution/cost ratio of normal retirement benefits was 

a factor in the Trustees’ decision to adopt a plan of benefit suspensions which provides 

for larger reductions to those participants whose employers are no longer contributing 

to the Plan. Participants whose employers remain in the Plan are having larger 

contributions made on their behalf, while deriving less benefit from them. 

7. Compensation levels of active participants relative to employees in the participants’

industry generally

IBT730-0039
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

As was discussed above, the compensation levels for the Plan’s largest employer range 

from $13 per hour to $26.33 per hour, with the average base rate being $21.37 per hour. 

Employees hired in 2015 and earlier have an average base wage rate of $25.24 per hour. 

The average base salary for an employee in the transportation and material moving 

industry in 2018 was $21.51 per hour. The retirement costs for Plan participants range 

from $1.90 to $7.60 per hour, with a majority (72%) of the Plan’s participants requiring 

contributions at the $7.24 per hour rate. The industry average for health insurance costs 

is $3.38 per hour, while Plan participants’ health insurance costs range from $6.88 per 

hour to $8.50 per hour. Against this backdrop, material increases in wages over the next 

several years is unlikely, as more and more money is required to be spent on pension 

and health costs. 

Although on average unionized employees have traditionally received higher wages 

than non-union employees, in recent years non-union workers’ wages have increased 

more rapidly than unionized workers’ wages. Pension costs for unionized workers 

generally are keeping their wages stagnant. As the contribution rates needed to sustain 

pension and health plans continue to increase, employers cannot absorb them. This 

means that participants will likely be required to reallocate a portion of their total 

compensation package from wages to pension contributions. Union employees are 

seeing reductions in wages, and reductions in retirement benefits, but are paying more 

than ever for those reduced retirement benefits. 

Because of these trends and the desire of many workers to see a material improvement 

in their wages rather than see increasing amounts of their total compensation dedicated 

to pension contributions, the Trustees have determined that mandatory additional 

contribution rate increases would likely: (a) cause a net decline in support for the Plan 

among the remaining participants; and (b) make it more difficult for Current 

Contributing Employers to attract and retain qualified employees. These consequences, 

in turn, will lead to more employer withdrawals and to a decline in contribution income 

to the Plan. The aforementioned factors relating to the compensation levels of active 

participants relative to other employees in the participants’ industry generally have 

caused the Trustees to conclude that they have taken all necessary steps to avoid 

insolvency. 

8. Competitive and other economic factors facing contributing employers

As discussed above, the Trustees have continually considered the competitive pressures 

and financial constraints faced by the Plan’s contributing employers. The Trustees 

recognize that if they set contribution requirements at a level that the employers cannot 

sustain, it is very likely that the employers will go out of business, and/or file for 

bankruptcy, or simply leave the Plan. 

IBT730-0040
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

The Trustees are also aware that most non-union employers do not sponsor defined 

benefit plans. Current Contributing Employers are competing with non-union 

employers that do not have legally required pension contribution obligations. Most of 

the Current Contributing Employers’ non-union competitors maintain profit sharing or 

401(k) plans or employ work schedules so as to avoid having to pay any benefits, 

including retirement benefits. Such plans are not subject to the Internal Revenue Code’s 

minimum funding requirements and place the investment risk on the employee. The 

Plan’s employers bear the burden of having to make contributions that are not only 

contractually required, but legally required. Moreover, when the financial markets 

underperform or suffer losses, it is the employers that must make up the difference.

9. 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) 

As discussed above, the Trustees recognize that benefit and contribution levels have an 

effect on retaining active participants. In enacting reasonable measures to avoid 

insolvency, the Trustees were mindful of recent experience, where in 2012 one of the 

Plan’s Former Contributing Employers (Adams Burch) negotiated a withdrawal from 

the Plan with the approval of its employees. 

In developing this Application, the Trustees took into account all the benefit reductions 

the remaining participants have experienced since 2010. Benefit accrual rates have 

been cut from 4.17% of contributions to 2%. The reality is that the contribution rate 

increases are not completely going to pay for the remaining participants’ reduced 

benefits; the bulk of the increases are going to pay the benefits for participants whose 

employers are no longer contributing to the Plan. The Trustees know that there is a 

limit to what the remaining Plan participants will tolerate before they look for other 

retirement options. They also know that, if there are no active employees, the Plan is 

not viable and all participants’ benefits are at risk. With this in mind, the Trustees took 

the reasonable measure of proposing a 28% reduction for benefits accrued with an 

employer that continues to contribute to the Plan, and a reduction to 110% of the PBGC 

guarantee for benefits accrued with employers that left the Plan. 

10. The impact of past and anticipated contribution increases under the Plan on employer

attrition and retention levels

As discussed above, the prior contribution increases imposed on Current Contributing 

Employers have become unsustainable. Contribution rates have increased 4.9% 

annually since 2010, far outpacing inflation and retirement costs in the non-union 

arena. Current Contributing Employers cannot pay 4.9% increases in perpetuity and 

expect to remain competitive in the marketplace or retain employees. The Plan’s largest 

IBT730-0041
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 5. Plan Sponsor Determination Relating to Reasonable Measures Taken to Avoid 

Insolvency 

contributing employer has committed to continue paying the 4.9% increases through 

2027. However, the Trustees have seen first-hand the affect that ever-increasing 

contribution rates have on employers, as two of the three largest contributing employers 

have withdrawn since the adoption of the Rehabilitation Plan in 2009. Giant Food has 

threatened to withdraw from the Plan in 2024, if the Trustees do not seek to suspend 

benefits. Given the foregoing, the Trustees concluded that the prior contribution rate 

increases resulted in the loss of two large employers and brought the Plan’s largest 

employer to the brink of leaving the Plan. The contribution rate increases assumed in 

this Application give Current Contributing Employers some hope that there is light at 

the end of the tunnel and provides Giant and the other Current Contributing Employers 

with an incentive to remain in the Plan. 

5.04 Other Factors Considered 

The Trustees considered the 2019 Memorandum of Agreement (MOA) between Local No. 

730 and Giant. The MOA requires Giant to pay contribution rate increases of 4.9% through 

May 2027, provided the Plan submits a MPRA application to the Department of Treasury 

by 2024. Otherwise, the contribution rate in effect in 2024 will be frozen through 2027. 

The Trustees considered the Giant MOA’s terms, as well as the actuary’s certification that 

the Plan is in critical and declining status and determined that the only mechanism by which 

they can keep the Plan solvent is to suspend benefits in accordance with this Application.

IBT730-0042
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 6. Other Required Information 

6.01 Ballot 

Exhibit 6.01 contains the proposed ballot intended to satisfy the requirements of 

§432(e)(9)(H)(iii)

6.02 Partition 

The plan sponsor is not requesting approval from the Pension Benefit Guaranty 

Corporation (PBGC) of a proposed partition under section 4233 of ERISA 

6.03 Actuarial Assumptions Used for Projections 

Exhibit 6.03 contains: 

1. A description of each of the assumptions used in the projections required under

Sections 3.01, 3.02, 4.02(1). 4.02(2) and 4.03 of Revenue Procedure 2017-43

2. Supporting evidence for the selection of these assumptions

3. An explanation of any difference among assumptions used for various purposes

throughout this Application

6.04 Ten-Year Experience for Certain Critical Assumptions 

Plan Year 

Beginning 

January 1,

Total 

Contributions

Contribution 

Base Units

Average 

Contribution 

Rate

Withdrawal 

Liability 

Payments

Rate of 

Return on 

Plan Assets

(1) (2) (3) (4) (5)

2010 $ 6,538,008 1,720,293 $3.80 12.63%

2011 $ 6,467,235 1,601,163 $4.04 0.81%

2012 $ 4,503,437 847,458 $5.31 $ 500 12.46%

2013 $ 3,584,236 813,911 $4.40 $ 2,207,669 19.04%

2014 $ 3,616,621 816,164 $4.43 $ 1,037,408 7.96%

2015 $ 3,673,433 785,867 $4.67 $ 663,674 4.78%

2016 $ 3,785,773 754,470 $5.01 $ 663,674 7.22%

2017 $ 3,641,080 702,709 $5.18 $ 663,674 15.94%

2018 $ 3,759,761 640,923 $5.87 $ 2,363,674 -0.24%

2019 $ 3,879,728 592,951 $6.54 $ 663,674 17.22%

IBT730-0043
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 6. Other Required Information 

6.05 Demonstration of Sensitivity of Projections 

Exhibits 6.05(1)-6.05(4) contain the deterministic projections of the sensitivity of the 

Plan’s solvency ratio throughout the extended period to the following key assumptions. 

All other assumptions used for these projections are the same as those used under section 

4.02(1) of the Application, except that; 

1. The assumed rate of return is reduced by 1 percentage point

2. The assumed rate of return is reduced by 2 percentage points

3. Future contribution base units decrease at a rate of 11% (the average annual rate of

decrease that the Plan experienced over the past ten years)

4. Future contribution base units decrease at a rate of 12% (the rate stated in 6.05(3)

reduced by one percentage point)

6.06 Projection of Funded Percentage 

Exhibit 3.02 contains the illustration, prepared on a deterministic basis, of the projected 

value of Plan assets, the accrued liability of the Plan (calculated using the unit credit 

funding method) and the funded percentage for each year in the extended period. 

6.07 Plan Sponsor Certifications Relating to Plan Amendments 

The plan sponsor certifies that if it receives final authorization to implement the suspension 

as described in §432(e)(9)(H)(vi) and chooses to implement the authorized suspension, 

then, in addition to the plan amendment implementing the suspension, the following plan 

amendments will be timely adopted and not modified at any time thereafter before the 

suspension of benefits expires: 

1. A plan amendment providing that in accordance with §432(e)(9)(C)(ii) the benefit

suspension will cease as of the first day of the first plan year following the plan year in

which the plan sponsor fails to maintain a written record of its determination that both:

a. All reasonable measures to avoid insolvency continue to be taken during the period

of the benefit suspension

b. The Plan would not be projected to avoid insolvency if no suspension of benefits

were applied under the Plan

2. A plan amendment providing that any future benefit improvements must satisfy the

requirements of §432(e)(9)(E)

IBT730-0044
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 6. Other Required Information 

6.08 Whether a Plan is Described in §432(e)(9)(D)(vii) 

This is not a plan described in §432(e)(9)(D)(vii) 

6.09 Narrative Statement of Reasons Fund is in Critical and Declining Status 

The reasons for the Plan being in critical and declining status is captured best in Section 

5.02(4). Simply put, the Plan is in critical and declining status because its contribution 

base deteriorated while its benefit obligations have soared. The Plan has lost contributing 

employers, active participants, and the corresponding contribution base associated with 

those losses. While active employees on whom contributions are made has declined, 

retired or otherwise separated participants entitled to pensions increased significantly. 

In 2010, the Plan had 925 active participants and 1,331 retired and deferred vested 

participants. The Plan lost 480 active participants during 2011 – 2012, as two of the Plan’s 

three largest employers ramped down operations and implemented a pre-planned 

withdrawal strategy. As of 2020, there were 312 active participants and 1,701 retired and 

deferred vested participants. There currently are more than 5 times the number of inactive 

participants receiving or entitled to receive benefits than there are active participants on 

whom the Plan receives contributions. This means that the amount of money coming into 

the Plan is dwarfed by the amount of money going out to pay benefits. Contribution income 

in 2019 was $3,879,728, while benefit payments were $20,591,785. Even the Plan’s 

remarkable investment returns over the past 10 years (10.3%), which have far exceeded the 

Plan’s actuarial assumption, reductions in future accruals, and elimination of virtually all 

adjustable benefits, have not been sufficient to compensate for such extreme negative cash 

flow. The Plan is in dire straits. 

IBT730-0045
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 7. Identification and Background Information on the Fund 

7.01 Board of Trustees Information 

Board of Trustees Information

Sponsor Name Board of Trustees of Warehouse Employees Union 

Local No. 730 Pension Trust Fund

Sponsor EIN/PN 52-6124754/001

Address 911 Ridgebrook Road

Sparks, MD 21152-9451

Telephone 410-683-7763

Email 730questions@associated-admin.com

7.02 Plan Identification 

Plan Identification

Plan Name Warehouse Employees Union Local No. 730 Pension Trust 

Fund

Plan EIN / PN 52-6124754/001

7.03 Retired Participant Representative 

The plan sponsor was not required to appoint a retiree representative under 

§432(e)(9)(B)(v)(I)

7.04 Fund’s Enrolled Actuary

Fund’s Enrolled Actuary

Actuary Name Peter Hardcastle

Enrollment Number 20-05197

Company Cheiron, Inc.

Address 8300 Greensboro Drive, Suite 800

McLean, VA 22102

Telephone 703-893-1456 x1004

Email phardcastle@cheiron.us

7.05 Power of Attorney 

Designation of power of attorney for all authorized representatives who will represent the 

Board of Trustees in connection with the Application is provided as Exhibit 7.05.

IBT730-0046
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust Fund 

EIN/PN: 52-6124754 / 001 

Section 7. Identification and Background Information on the Fund 

7.06 Plan Documents 

The following information is provided as Exhibits 7.06a-c:

Exhibit 7.06a: Most recent Plan document and 

Plan amendments adopted since 

that restatement 

Exhibit 7.06b: Most recent summary plan 

description (SPD) and all 

subsequent summaries of 

material modification

Exhibit 7.06c: Most recent determination letter 

issued to the Plan

7.07 Collective Bargaining and Side Agreements 

Excerpts from the collective bargaining agreement pursuant to which the Plan is

maintained are provided as Exhibit 7.07. The required excerpts contain language from the 

collective bargaining agreement that are relevant to the Plan or the proposed suspension 

7.08 Annual Return 

Exhibit 7.08 contains the following excerpts from the most recently filed Form 5500, the 

Form 5500 for the Plan Year ending December 31, 2019: 

 Pages 1 and 2 of the Form 5500, without attachments or schedules

 The Schedule MB, including attachments

 The Schedule R, including attachments

 The accountant’s report under section 103(a)(3) of ERISA

7.09 Rehabilitation Plan 

Exhibit 7.09 contains the most recently updated Rehabilitation Plan described in 

§432(e)(3)

7.10 Valuation Reports 

Exhibit 7.10 contains the two most recent actuarial valuation reports for the Plan 

7.11 Completed Checklist 

A completed checklist of Information required to be included in the Application is 

provided as Exhibit 7.11 

IBT730-0047
FOR PLAN YEAR COMMENCING JANUARY 1, 2020

ANNUAL CERTIFICATION OF PLAN STATUS UNDER SECTION 432(b) OF THE 

INTERNAL REVENUE CODE, (SEC. 305(b) OF THE EMPLOYEE RETIREMENT 

INCOME SECURITY ACT OF 1974) 

FOR 

WAREHOUSE EMPLOYEES UNION 

LOCAL NO. 730 PENSION TRUST FUND 

March 30, 2020 

EIN: 52-6124754

PN: 001

Plan Year 1/1/2020

Fund Contact

Ms. Alicia Cochran

Account Executive

(410) 683-6500

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0048
Board of Trustees of the Warehouse Employees Union March 30, 2020 

Local No. 730 Pension Trust Fund EIN: 52-6124754 

911 Ridgebrook Road PN: 001 

Sparks, Maryland 21152-9451 Tel: (410) 683-6500 

Re: Annual Certification of Plan Status under Internal Revenue Code §432(b) and 

Employee Retirement Income Security Act of 1974 §305(b) 

Dear Board of Trustees:

CERTIFICATION 

As required by Section 432(b)(3) of the Internal Revenue Code (“Code”) and Section 305(b)(3) 

of the Employee Retirement Income Security Act of 1974 (“ERISA”), we certify, for the plan 

year beginning January 1, 2020, that the Fund is classified as being in Critical and Declining 

status as this term is defined in Section 432(b) of the Code and Section 305(b) of ERISA as 

amended by the Multiemployer Pension Reform Act of 2014. 

The rehabilitation period for the Rehabilitation Plan adopted by the Trustees on 

November 26, 2009 began on January 1, 2012 and requires all reasonable measures to forestall 

insolvency. As discussed in Appendix III, we certify that the Fund is making scheduled progress 

in meeting the requirements of its Rehabilitation Plan due to the exhaustion of all reasonable 

measures to forestall insolvency. 

This certification is complete and has been prepared in accordance with the requirements of 

Section 432 of the Code, Section 305 of ERISA, and generally recognized and accepted actuarial 

principles and practices and our understanding of the Code of Professional Conduct and 

applicable Actuarial Standards of Practice set out by the Actuarial Standards Board as well as 

applicable laws and regulations. Furthermore, as credentialed actuaries, we meet the 

Qualification Standards of the American Academy of Actuaries to render the opinion contained 

in this certification. This certification does not address any contractual or legal issues. We are not 

attorneys, and our firm does not provide any legal services or advice. 

This certification was prepared exclusively for the Trustees of the Warehouse Employees Union 

Local 730 Pension Trust Fund and the Secretary of Treasury. It only certifies the condition of the 

Fund under Code Section 432 as added by the Pension Protection Act of 2006 and should be 

used only for that purpose. Other users of this certification are not intended users as defined in 

the Actuarial Standards of Practice, and Cheiron assumes no duty or liability to such other users. 

In preparing this certification, we have relied on information (some oral and some written) 

supplied by the Fund Office staff and the Fund’s investment manager. This information includes, 

but is not limited to, the plan provisions, employee data, financial information, and expectations 

of future industry activity. We performed an informal examination of the obvious characteristics 

of the data for reasonableness and consistency in accordance with Actuarial Standard of Practice 

No. 23. 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0049
Board of Trustees 

March 30, 2020

Page ii

Future analyses may differ significantly from those presented in this certification letter due to 

such factors as the following: plan experience differing from that anticipated by the assumptions; 

changes in assumptions; and changes in plan provisions or applicable law. 

The attached appendices show the results for the statutory tests and describe the methodologies 

and assumptions used to perform the tests. Please contact the undersigned with any questions. 

Sincerely, 

Peter Hardcastle, FSA, EA (17-05197) Matthew Deveney, FSA, EA (17-07754) 

Attachments: Appendix I: Tests of Fund Status 

Appendix II: Detail for Actuarial Certification 

Appendix III: Scheduled Progress 

Appendix IV: Methodology and Assumptions 

cc: Secretary of the Treasury 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0050
APPENDIX I – TESTS OF FUND STATUS 

1

Critical Status – The Fund, which has a 431(d) five-year automatic extension,

was certified as Critical last year and will remain Critical unless it meets the two 

conditions for emergence:

Condition

Met?

1 The Fund is not projected to have an accumulated funding deficiency for the 

current plan year or the next nine plan years.

NO

2 The Fund is not projected to become insolvent within 30 years.

NO

Critical and Declining Status – The Fund will be certified as Critical and 

Declining if it meets test 3.

3 The Fund is in Critical Status and is projected to become insolvent within the 

current or the next 19 plan years since the funding level is below 80%. YES

The Fund is certified to be in Critical and Declining status for 2020.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0051
APPENDIX II – DETAIL FOR ACTUARIAL CERTIFICATION 

2

A. CREDIT BALANCE / FUNDING DEFICIENCY (Used for Test 1)

(uses 431(d) five-year automatic extension) 

Date

Credit

Balance

adjusted with interest to end of year

Charges Credits Contributions

1/1/2020 ($36,920,882) $23,749,834 $10,103,711 $4,920,186

1/1/2021 ($48,600,489)

Because a funding deficiency is projected at year-end, there is no need to project the funding 

standard account credit balance any further. The projected funding standard account is based 

on the methods and assumptions set out in Appendix IV. 

The projection of future contributions is based on the Trustees’ estimate of future industry 

activity multiplied by the contribution rates contained in the current collective bargaining 

agreements under which the Fund is maintained. Additionally, future Withdrawal Liability 

payments by McKesson Drug Corporation are included. 

B. SOLVENCY PROJECTION (Used for Tests 2 and 3) 

(assumes contribution increases continue at 4.9% per year) 

The chart below shows a projection of the assets of the Fund over the next 13 years. The 

projection indicates that the Fund is expected to run out of assets during the 2032 Plan Year. 

Market Value Projected Projected Benefits Projected Investment

Date Assets Contributions and Expenses Earnings

1/1/2020 $ 158,996,891 $ 4,734,451 $ 23,408,089 $ 11,987,175 

1/1/2021 152,310,428 4,932,119 23,770,475 11,445,796

1/1/2022 144,917,869 5,140,603 24,225,727 10,844,711

1/1/2023 136,677,455 5,360,004 24,984,294 10,164,326

1/1/2024 127,217,490 5,590,591 25,842,814 9,382,895

1/1/2025 116,348,162 5,832,500 26,865,217 8,482,729

1/1/2026 103,798,175 6,086,287 27,255,535 7,473,374

1/1/2027 90,102,301 6,352,535 27,629,618 6,373,474

1/1/2028 75,198,692 6,631,855 27,902,466 5,181,439

1/1/2029 59,109,520 6,924,889 27,358,377 3,927,146

1/1/2030 42,603,177 7,232,312 27,416,971 2,616,400

1/1/2031 25,034,918 7,554,829 26,978,169 1,240,806

1/1/2032 6,852,384 7,893,181 26,170,173 0

1/1/2033 0 7,584,472 25,474,924 -701,851

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0052
APPENDIX III – SCHEDULED PROGRESS

3

Pursuant to ERISA Section 305(e)(3)(A)(ii), the Board of Trustees has adopted a Rehabilitation 

Plan to forestall insolvency as defined in ERISA Section 4245. The Rehabilitation Plan removes 

some adjustable benefits and requires contribution increases from all employers to match those 

affordable to the largest employer. The current required increases are 4.9% per year. Currently, 

all active employers are increasing contribution rates by 4.9% annually. On this basis and also 

considering lack of guidance from the Internal Revenue Service, we are certifying that the Fund 

is making the scheduled progress in meeting the requirements of its Rehabilitation Plan as 

discussed in ERISA Section 305(b)(3)(A)(ii). 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0053
APPENDIX IV – METHODOLOGY AND ASSUMPTIONS 

4

A. Actuarial Assumptions 

1. Rates of Investment Return

 8.00% net of investment expenses. 

2. Administrative Expenses 

$363,794 for 2020 at the beginning of the year, increasing 3.0% per year thereafter. 

3. Rates of Mortality 

RP 2000 Mortality Table with blue collar adjustment and generational improvements. 

4. Rates of Retirement 

Age

Less than 

30 Years 

Service

30 

Years

Service

Over 30 

Years 

Service

51 – 59 0% 50% 10%

60 and over 100% 100% 100%

5. Rates of Turnover

Double the combination of Sarason’s Advanced Pension Tables. Sample rates: 

Age Rate

20 24.77%

22 22.62

24 20.47

25 19.40

26 18.02

28 15.25

30 12.49

35 8.21

40 5.24

45 2.57

50 0.00

6. Rates of Disability 

None assumed. 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0054
APPENDIX IV – METHODOLOGY AND ASSUMPTIONS 

5

7. Marital Status 

 80% of participants are assumed to be married. 

 Wives are assumed to be three years younger than the husband. 

8. Active Participants 

 All non-retired participants who have hours worked during the plan year ending 

December 31, 2018. 

9. Future Hours Worked By Active Participants 

Each active participant will work average annual hours worked in the past three years, 

excluding the year of entry. No participant is assumed to work less than 870 hours per 

year. 

10. Contribution Rate Used for Determination of Minimum Flat Benefit 

The contribution rate in effect when the CBA first adopted a schedule under the 2009 

Rehabilitation Plan or subsequent Rehabilitation Plan, if applicable. 

11. Contribution Rate Used for Determination of Percentage of Contributions Benefit 

The contribution rate in effect when the CBA first adopted a schedule under the 2009 

Rehabilitation Plan or subsequent Rehabilitation Plan, if applicable. 

12. Participant Data 

This report is based upon employee data furnished by the Fund Administrator. All nonretired participants who have hours worked during the plan year ending 

December 31, 2018 are assumed to be active participants as of January 1, 2019 unless 

identified as having been terminated. 

13. Rehabilitation Plan Benefit Schedule 

In preparing our report and valuation results, all participating employers were valued 

under the Preferred Schedule as of January 1, 2019.

14. Justification for Assumptions 

Economic: The expected investment return was chosen by comparing long-term real 

portfolio returns with inflation expectations. For a portfolio weighted 60% in US Large 

Cap equity and 40% in investment grade bonds, the 25-year return ending on the 

valuation date was 8.26% or a return in excess of inflation of approximately 6%. The 

Fund’s investments are invested more diversely than the model portfolio in expectation of 

generating higher returns but today’s inflation targets adopted by the Federal Reserve are 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0055
APPENDIX IV – METHODOLOGY AND ASSUMPTIONS 

6

lower than the experience over the last 25 years. A long-term rate return of a little over 

8% would be indicated by history and Fed policy. 

Demographic: The demographic assumptions were last changed with the 2012 valuation. 

The gains and losses from demographic experience have been minor since then with the 

exception of a large number of actives becoming terminated vested due to their employer 

withdrawing from the Fund, which is not part of a demographic assumption set. A 

quinquennial experience study will be performed in conjunction with the 2020 valuation. 

B. Actuarial Methods 

1. Funding Method: Entry Age Normal Cost Method 

Under the entry age normal actuarial cost method the individual entry age normal cost is 

determined for each participant by calculating the level annual contribution required to 

fund that individual’s expected benefits based on the current plan provisions over the 

participant’s expected active working lifetime with the Fund at entry.

At the valuation date the present value of future normal cost is calculated for each 

individual participant by multiplying the entry age normal cost by the present value of the 

participant’s expected future active working lifetime with the Fund. The cost for each 

participant is then summed to yield the present value of future normal costs. 

The excess of the present value of future benefits for all individuals at the valuation date 

over the present value of future normal costs is called the actuarial liability, or past 

service liability. 

The excess, if any, of the actuarial liability over the actuarial value of assets is known as 

the unfunded accrued liability. If the actuarial value of assets exceeds the actuarial 

liability the Fund may have a surplus. 

2. Asset Valuation Method 

The actuarial value of assets is determined in accordance with Section 3.16 of Revenue 

Procedure 2000-40 using a five-year smoothing period. Specifically, the actuarial value 

of assets as of January 1, 2006 is set equal to the market value of assets. For each 

subsequent plan year, the actuarial value shall be the market value minus a decreasing 

fraction (4/5, 3/5, 2/5, 1/5) of each gain or loss for each of the preceding four plan years 

(with the exception of the 2008 loss which is recognized at a rate of 1/10 per plan year 

due to funding relief). Gains or losses prior to January 1, 2006 are ignored. 

3. PRA 2010 Funding Relief 

 

The Fund’s Board of Trustees elected funding relief under § 431(b)(8) of the Code and 

§ 304(b)(8) of ERISA. This included the “special amortization rule,” which allows the 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0056
APPENDIX IV – METHODOLOGY AND ASSUMPTIONS 

7

Fund’s investment losses for the plan year ended December 31, 2008 to be separately 

amortized over 29 years. 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01a 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

IBT730-0057
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.01b 

Actuarial Certification of Status for the 2020 Plan Year (Checklist #5) 

Withdrawal Terminated Future Total

Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency

Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio

2020 158,996,891 $ $ 4,070,777 $ 663,674 $ 378,066 $ 18,617,882 $ 2,639,706 $ 1,772,435 $ 23,030,023 0 $ 8.00% 11,987,175 $ $ 152,310,428 $ 175,340,452 7.61

2021 152,310,428 4,268,445 663,674 389,408 17,270,926 3,575,749 2,534,391 23,381,067 0 8.00% 11,445,796 144,917,869 168,298,935 7.20

2022 144,917,869 4,476,929 663,674 401,090 16,134,782 4,469,213 3,220,642 23,824,637 0 8.00% 10,844,711 136,677,455 160,502,092 6.74

2023 136,677,455 4,696,330 663,674 413,123 15,601,169 5,400,075 3,569,927 24,571,172 0 8.00% 10,164,326 127,217,490 151,788,662 6.18

2024 127,217,490 4,926,917 663,674 425,516 15,053,222 6,511,411 3,852,665 25,417,298 0 8.00% 9,382,895 116,348,162 141,765,460 5.58

2025 116,348,162 5,168,826 663,674 438,282 14,451,993 7,617,253 4,350,552 26,426,935 7,137 8.00% 8,482,729 103,798,175 130,225,110 4.93

2026 103,798,175 5,422,613 663,674 451,430 13,766,687 8,354,424 4,670,482 26,804,105 12,511 8.00% 7,473,374 90,102,301 116,906,406 4.36

2027 90,102,301 5,688,861 663,674 464,973 12,923,392 9,116,457 5,106,444 27,164,645 18,352 8.00% 6,373,474 75,198,692 102,363,336 3.77

2028 75,198,692 5,968,181 663,674 478,922 12,236,968 9,776,712 5,385,610 27,423,543 24,253 8.00% 5,181,439 59,109,520 86,533,063 3.16

2029 59,109,520 6,261,215 663,674 493,290 11,586,475 10,014,131 5,235,428 26,865,087 29,053 8.00% 3,927,146 42,603,177 69,468,265 2.59

2030 42,603,177 6,568,638 663,674 508,089 11,150,878 10,224,342 5,486,191 26,908,883 47,472 8.00% 2,616,400 25,034,918 51,943,801 1.93

2031 25,034,918 6,891,155 663,674 523,331 10,702,171 10,161,718 5,527,394 26,454,838 63,554 8.00% 1,240,806 6,852,384 33,307,221 1.26

2032 6,852,384 7,229,507 663,674 539,031 10,241,352 9,968,361 5,344,657 25,631,141 76,770 8.00% 0 14,206,533 0 0.55

Benefit Payments

IBT730-0058
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 3.02 

Certification of Avoiding Insolvency (Checklist Item #6, #9, & #28) 

 

Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 4,268,706 $ 663,674 $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 $ 21,401,972 - $ 6.53% 9,995,376 $ $ 154,367,749 $ 175,769,721 8.21 290,501,153 56%

2022 154,367,749 4,477,160 663,674 390,000 13,594,190 1,574,102 1,237,371 - 16,405,664 6.53% 9,705,701 152,418,621 168,824,284 10.29 214,666,426 72%

2023 152,418,621 4,696,712 663,674 397,800 13,151,957 2,091,952 1,574,545 16,818,464 9 6.53% 9,571,963 150,134,706 166,953,169 9.93 213,963,725 71%

2024 150,134,706 4,927,361 663,674 405,756 12,707,118 2,710,626 1,792,158 17,210,297 395 6.53% 9,417,388 147,527,076 164,737,373 9.57 212,781,934 71%

2025 147,527,076 5,168,712 663,674 413,871 12,173,243 3,379,238 2,026,285 17,580,213 1,447 6.53% 9,242,718 144,608,095 162,188,308 9.23 211,143,650 70%

2026 144,608,095 5,421,705 663,674 422,149 11,647,408 4,043,020 2,326,095 18,023,647 7,124 6.53% 9,045,723 141,293,401 159,317,048 8.84 209,021,665 69%

2027 141,293,401 5,686,341 663,674 430,592 10,965,401 4,677,468 2,677,266 18,335,597 15,463 6.53% 8,827,481 137,704,708 156,040,306 8.51 206,278,685 68%

2028 137,704,708 5,809,214 663,674 439,203 10,402,698 5,199,508 2,915,445 18,542,123 24,473 6.53% 8,590,175 133,786,445 152,328,568 8.22 202,982,683 68%

2029 133,786,445 5,927,091 663,674 447,987 9,699,636 5,723,110 3,150,127 18,606,828 33,955 6.53% 8,335,739 129,658,133 148,264,961 7.97 199,249,000 67%

2030 129,658,133 6,045,524 663,674 456,947 9,224,416 6,136,135 3,338,586 18,744,260 45,122 6.53% 8,065,261 125,231,385 143,975,645 7.68 195,186,820 66%

2031 125,231,385 6,164,415 663,674 466,086 8,838,398 6,379,005 3,516,334 18,791,153 57,415 7.34% 8,743,910 121,546,146 140,337,299 7.47 190,678,524 66%

2032 121,546,146 6,287,877 663,674 475,408 8,454,789 6,544,745 3,608,388 18,683,988 76,066 7.34% 8,481,392 117,819,693 136,503,682 7.31 185,788,166 65%

2033 117,819,693 6,287,877 165,919 484,916 8,065,555 6,615,355 3,657,373 18,436,100 97,817 7.34% 8,198,520 113,550,993 131,987,093 7.16 180,658,547 65%

2034 113,550,993 6,287,877 - 494,614 7,672,183 6,609,829 3,798,895 124,285 18,205,192 7.34% 7,887,190 109,026,255 127,231,447 6.99 175,439,081 65%

2035 109,026,255 6,287,877 - 504,507 7,276,136 6,584,778 3,837,835 153,154 17,851,903 7.34% 7,567,454 104,525,176 122,377,080 6.86 170,078,230 64%

2036 104,525,176 6,287,877 - 514,597 6,878,769 6,443,229 3,968,290 186,844 17,477,132 7.34% 7,250,222 100,071,546 117,548,679 6.73 164,723,737 63%

2037 100,071,546 6,287,877 - 524,889 6,481,356 6,280,847 4,055,380 230,400 17,047,983 7.34% 6,938,425 95,724,977 112,772,960 6.62 159,355,966 63%

2038 95,724,977 6,287,877 - 535,386 6,085,135 6,120,063 4,069,262 276,982 16,551,442 7.34% 6,636,909 91,562,935 108,114,377 6.53 154,038,018 62%

2039 91,562,935 6,287,877 - 546,094 5,691,316 5,955,077 4,112,736 326,323 16,085,452 7.34% 6,347,828 87,567,094 103,652,546 6.44 148,875,471 62%

2040 87,567,094 6,287,877 - 557,016 5,301,107 5,785,252 4,183,239 378,834 15,648,432 7.34% 6,069,894 83,719,419 99,367,850 6.35 143,840,993 61%

2041 83,719,419 6,287,877 - 568,156 4,915,754 5,618,250 4,257,544 433,987 15,225,535 7.34% 5,802,319 80,015,924 95,241,458 6.26 138,891,053 60%

2042 80,015,924 6,287,877 - 579,519 4,536,567 5,445,291 4,208,814 494,367 14,685,039 7.34% 5,549,558 76,588,800 91,273,839 6.22 134,015,280 60%

2043 76,588,800 6,287,877 - 591,110 4,164,944 5,278,082 4,223,682 552,329 14,219,038 7.34% 5,314,388 73,380,918 87,599,956 6.16 129,380,105 59%

2044 73,380,918 6,287,877 - 602,932 3,802,383 5,109,052 4,219,409 615,426 13,746,270 7.34% 5,095,547 70,415,140 84,161,410 6.12 124,906,728 59%

2045 70,415,140 6,287,877 - 614,991 3,450,495 4,919,705 4,334,536 675,864 13,380,601 7.34% 4,890,607 67,598,033 80,978,634 6.05 120,601,572 58%

2046 67,598,033 6,287,877 - 627,291 3,110,981 4,743,930 4,306,335 746,540 12,907,785 7.34% 4,700,433 65,051,267 77,959,052 6.04 116,341,454 58%

2047 65,051,267 6,287,877 - 639,836 2,785,595 4,553,959 4,336,410 829,392 12,505,356 7.34% 4,527,555 62,721,507 75,226,863 6.02 112,273,679 58%

2048 62,721,507 6,287,877 - 652,633 2,476,059 4,350,227 4,276,540 917,205 12,020,032 7.34% 4,373,586 60,710,306 72,730,337 6.05 108,316,354 58%

2049 60,710,306 6,287,877 - 665,686 2,183,965 4,136,817 4,187,481 1,017,568 11,525,831 7.34% 4,243,309 59,049,975 70,575,806 6.12 104,606,573 58%

2050 59,049,975 6,287,877 - 678,999 1,910,735 3,917,703 4,058,915 1,154,348 11,041,701 7.34% 4,138,414 57,755,566 68,797,267 6.23 101,160,120 58%

2051 57,755,566 6,287,877 - 692,579 1,657,569 3,690,177 3,882,935 1,319,434 10,550,115 7.34% 4,060,636 56,861,386 67,411,501 6.39 97,975,058 59%

2052 56,861,386 6,287,877 - 706,431 1,425,338 3,460,675 3,730,747 1,488,996 10,105,756 7.34% 4,010,524 56,347,600 66,453,356 6.58 95,078,331 60%

2053 56,347,600 6,287,877 - 720,560 1,214,516 3,230,248 3,553,200 1,663,612 9,661,576 7.34% 3,988,315 56,241,657 65,903,233 6.82 92,440,262 61%

2054 56,241,657 6,287,877 - 734,971 1,025,124 3,000,763 3,375,656 1,832,085 9,233,629 7.34% 3,995,447 56,556,382 65,790,011 7.13 90,074,953 62%

2055 56,556,382 6,287,877 - 749,670 856,737 2,777,226 3,164,367 1,997,292 8,795,622 7.34% 4,033,808 57,332,775 66,128,397 7.52 87,990,194 64%

2056 57,332,775 6,287,877 - 764,664 708,634 2,554,059 2,988,909 2,164,071 8,415,673 7.34% 4,103,952 58,544,267 66,959,940 7.96 86,217,720 66%

2057 58,544,267 6,287,877 - 779,957 579,872 2,337,376 2,785,041 2,332,771 8,035,059 7.34% 4,206,045 60,223,174 68,258,233 8.50 84,717,067 69%

2058 60,223,174 6,287,877 - 795,556 469,240 2,128,389 2,614,917 2,496,070 7,708,617 7.34% 4,340,483 62,347,361 70,055,978 9.09 83,504,870 72%

2059 62,347,361 6,287,877 - 811,467 375,319 1,928,142 2,459,619 2,651,901 7,414,981 7.34% 4,506,410 64,915,201 72,330,182 9.75 82,545,696 76%

Benefit Payments

IBT730-0059
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.01a-4.01h 

Demonstration of Federal Limitations on Individual Suspension (Checklist Item #8) 

Data 4.01a 4.01b 4.01c 4.01d 4.01e 4.01f 4.01g 4.01h

1 Rec ID 168 1884 1219 1897 1474 1481 1565 2014

2 Status RETS BENS ACTIVE TV RETS RETS BENS TV

3 Date of Birth 5/10/1953 2/26/1950 11/10/1978 11/29/1967 11/8/1945 3/4/1942 2/15/1944 6/8/1943

4 Spouse Date of Birth 5/15/1954

5 Effective Date 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022

6 Form of Payment1 Normal Form - 

Level Income Single Life

Normal Form - 

Level Income

Normal Form - 

Level Income J&S Single Life Single Life

Normal Form - 

Level Income

7 Credited Service at Effective Date 32.6860 21.6260 10.7830 5.3970 33.6590 41.6040 21.0000 18.0000

8 Accrued Benefit at Effective Date $ 909.42 $ 980.28 $ 919.68 $ 124.20 $ 2,086.17 $ 427.36 $ 682.62 $ 743.71

Participant Calculations

9 Benefit with Suspension Formula 654.78 705.80 662.17 89.42 1,502.04 307.70 491.49 535.47 

10 Plan's Accrual Rate ([8]/[7]) 27.82 45.33 85.29 23.01 61.98 10.27 32.51 41.32 

11 PBGC Accrual Rate 23.62 35.75 35.75 20.01 35.75 10.27 27.13 33.74 

12 PBGC Guarantee ([7]*[11]) 771.95 773.13 385.49 107.99 1,203.31 427.36 569.72 607.28 

13 110% PBGC Guarantee

(110%*[12], not more than [8]) 849.15 850.44 424.04 118.79 1,323.64 427.36 626.69 668.01 

14 Maximum Suspendable

([8]-max([9],[13])) 60.27 129.84 257.51 5.41 584.13 - 55.93 75.70 

15 Age for MPRA Limitation 68.67 71.92 43.17 54.17 76.17 79.83 77.92 78.58 

16 Age Based Protection 0% 0% 0% 0% 23.33% 96.67% 58.33% 71.67%

17 Proposed Benefit ([8]-[14]*(1-[16])) $ 849.15 $ 850.44 $ 662.17 $ 118.79 $ 1,638.34 $ 427.36 $ 659.31 $ 722.26

Beneficiary Calculations (if applicable)

18 Survivor's Benefit with Suspension Formula $ 1,001.86

19 Survivor's Benefit $ 1,391.48

20 Plan's Accrual Rate ([19]/[7]) 41.34 

21 PBGC Accrual Rate 33.76 

22 PBGC Guarantee ([7]*[21]) 1,136.17 

23

110% PBGC Guarantee

(110%*[22], not more than [19]) 1,249.79 

24

Maximum Suspendable

([19]-max([18],[23]) 141.69 

25 Proposed Benefit ([19]-[24]*(1-[16])) $ 1,282.85

1

For the Normal Form - Level Income options, only the current level is shown for the in-pay examples, the maximum level is shown for the Active and TVs. 

A similar calculation is performed after the benefit step down.

IBT730-0060
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.01a-4.01k 

Demonstration of Federal Limitations on Individual Suspension (Checklist Item #8) 

Data 4.01a 4.01b 4.01c 4.01d 4.01e 4.01f 4.01g 4.01h 4.

1 Rec ID 168 1884 1219 1897 1474 1481 1565 2014 132 Status RETS BENS ACTIVE TV RETS RETS BENS TV ACT

Formerly 

Contributory

Currently 

Contributory

Currently 

Contributory

Formerly 

Contributory

Currently 

Contributory

Formerly 

Contributory

Currently 

Contributory

Currently 

Contributory Comb

3 Date of Birth 5/10/1953 2/26/1950 11/10/1978 11/29/1967 11/8/1945 3/4/1942 2/15/1944 6/8/1943 7/14 Spouse Date of Birth 5/15/19545 Effective Date 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/1/2022 1/6 Form of Payment1

Normal Form ‐ 

Level Income Single Life

Normal Form ‐ 

Level Income

Normal Form ‐ 

Level Income J&S Single Life Single Life

Normal Form ‐ 

Level Income

Norma‐ Level

7 Credited Service at Effective Date 32.6860 21.6260 10.7830 5.3970 33.6590 41.6040 21.0000 18.0000 

8 Accrued Benefit at Effective Date $            909.42 $            980.28 $           919.68 $            124.20 $         2,086.17 $            427.36 $      682.62 $       1,2

743.71 $     

Participant Calculations

9 Benefit with Suspension Formula 654.78 705.80    662.17    89.42       1,502.04 307.70     491.49     535.47     8

         

10 Plan's Accrual Rate ([8]/[7]) 27.82 45.33      85.29      23.01       61.98       10.27       32.51       41.32       1

         

11 PBGC Accrual Rate 23.62 35.75      35.75      20.01       35.75       10.27       27.13       33.74       

12 PBGC Guarantee ([7]*[11]) 771.95 773.13    385.49 107.99 1,203.31 427.36     569.72     607.28     3

         

13 110% PBGC Guarantee

(110%*[12], not more than [8]) 849.15 850.44    424.04 118.79 1,323.64 427.36     626.69     668.01     3

         

14 Maximum Suspendable

([8]‐max([9],[13])) 60.27 129.84    257.51    5.41         584.13     ‐   55.93       75.70       3

         

15 Age for MPRA Limitation 68.67 71.92      43.17      54.17       76.17       79.83       77.92 78.58 

16 Age Based Protection 0% 0% 0% 0% 23.33% 96.67% 58.33% 71.67% 

17 Proposed Benefit ([8]‐[14]*(1‐[16])) $            849.15 $            850.44 $           662.17 $            118.79 $         1,638.34 $            427.36 $      659.31 $      722.26 8

$         

Beneficiary Calculations (if applicable)

18 Survivor's Benefit with Suspension Formula $         1,001.86

19 Survivor's Benefit $         1,391.4820 Plan's Accrual Rate ([19]/[7]) 41.34

21 PBGC Accrual Rate 33.76

22 PBGC Guarantee ([7]*[21]) 1,136.17

23

110% PBGC Guarantee(110%*[22], not more than [19]) 1,249.79

24

Maximum Suspendable([19]‐max([18],[23]) 141.69

25 Proposed Benefit ([19]‐[24]*(1‐[16])) $         1,282.85

1 For the Normal Form ‐ Level Income options, only the current level is shown for the in‐pay examples, the maximum level is shown for the Active and TVs. 

A similar calculation is performed after the benefit step down.
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.03 

Does Not Materially Exceed Projection (Checklist Item #11) Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 4,268,706 663,674$ $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 -$ 21,401,972 $ 6.53% 9,995,376 $ $ 154,367,749 $ 175,769,721 8.21 290,501,153 56%

2022 154,367,749 4,477,160 663,674 390,000 13,912,399 1,617,223 1,271,616 - 16,801,237 6.53% 9,692,990 152,010,336 168,811,573 10.05 220,202,384 70%

2023 152,010,336 4,696,712 663,674 397,800 13,461,157 2,150,704 1,617,841 10 17,229,711 6.53% 9,532,087 149,275,297 166,505,008 9.66 219,478,016 69%

2024 149,275,297 4,927,361 663,674 405,756 13,007,074 2,787,442 1,841,032 403 17,635,950 6.53% 9,347,591 146,172,217 163,808,167 9.29 218,256,828 68%

2025 146,172,217 5,168,712 663,674 413,871 12,461,494 3,475,396 2,080,917 1,464 18,019,272 6.53% 9,140,137 142,711,596 160,730,868 8.92 216,561,488 67%

2026 142,711,596 5,421,705 663,674 422,149 11,924,144 4,158,457 2,387,876 7,196 18,477,673 6.53% 8,907,292 138,804,445 157,282,118 8.51 214,364,584 67%

2027 138,804,445 5,686,341 663,674 430,592 11,226,144 4,810,273 2,746,711 15,550 18,798,679 6.53% 8,650,072 134,575,262 153,373,941 8.16 211,525,961 66%

2028 134,575,262 5,809,214 663,674 439,203 10,651,383 5,346,906 2,989,959 24,563 19,012,811 6.53% 8,370,697 129,966,833 148,979,644 7.84 208,118,253 65%

2029 129,966,833 5,927,091 663,674 447,987 9,932,206 5,885,067 3,229,338 34,048 19,080,658 6.53% 8,071,092 125,100,045 144,180,703 7.56 204,257,177 64%

2030 125,100,045 6,045,524 663,674 456,947 9,447,204 6,309,776 3,420,315 45,224 19,222,519 6.53% 7,752,250 119,882,027 139,104,546 7.24 200,055,437 63%

2031 119,882,027 6,164,415 663,674 466,086 9,053,780 6,559,545 3,600,220 57,522 19,271,067 7.34% 8,333,967 115,306,930 134,577,997 6.98 195,393,229 61%

2032 115,306,930 6,287,877 663,674 475,408 8,662,691 6,729,863 3,692,309 76,189 19,161,052 7.34% 8,006,235 110,628,257 129,789,309 6.77 190,336,472 61%

2033 110,628,257 6,287,877 165,919 484,916 8,265,667 6,802,420 3,740,782 97,946 18,906,815 7.34% 7,653,699 105,344,021 124,250,836 6.57 185,031,757 60%

2034 105,344,021 6,287,877 - 494,614 7,864,184 6,796,544 3,883,341 124,422 18,668,491 7.34% 7,268,097 99,736,889 118,405,380 6.34 179,631,503 59%

2035 99,736,889 6,287,877 - 504,507 7,459,724 6,770,685 3,921,770 153,297 18,305,476 7.34% 6,869,263 94,084,048 112,389,523 6.14 174,084,882 57%

2036 94,084,048 6,287,877 - 514,597 7,053,672 6,625,067 4,052,978 186,986 17,918,702 7.34% 6,467,924 88,406,551 106,325,252 5.93 168,541,676 56%

2037 88,406,551 6,287,877 - 524,889 6,647,336 6,457,934 4,139,569 230,561 17,475,400 7.34% 6,066,806 82,760,946 100,236,345 5.74 162,984,398 54%

2038 82,760,946 6,287,877 - 535,386 6,241,998 6,292,478 4,152,365 277,150 16,963,990 7.34% 5,670,477 77,219,923 94,183,914 5.55 157,478,317 53%

2039 77,219,923 6,287,877 - 546,094 5,838,907 6,122,679 4,195,217 326,497 16,483,301 7.34% 5,280,709 71,759,114 88,242,415 5.35 152,129,848 51%

2040 71,759,114 6,287,877 - 557,016 5,439,324 5,947,922 4,265,196 379,014 16,031,456 7.34% 4,895,781 66,354,300 82,385,756 5.14 146,911,638 49%

2041 66,354,300 6,287,877 - 568,156 5,044,544 5,776,025 4,338,910 434,169 15,593,648 7.34% 4,514,449 60,994,822 76,588,470 4.91 141,780,440 47%

2042 60,994,822 6,287,877 - 579,519 4,655,930 5,598,156 4,288,296 494,554 15,036,935 7.34% 4,140,723 55,806,967 70,843,903 4.71 136,726,144 45%

2043 55,806,967 6,287,877 - 591,110 4,274,941 5,426,302 4,302,049 552,507 14,555,800 7.34% 3,776,862 50,724,797 65,280,597 4.48 131,916,725 42%

2044 50,724,797 6,287,877 - 602,932 3,903,132 5,252,646 4,295,786 615,608 14,067,172 7.34% 3,421,019 45,763,590 59,830,761 4.25 127,272,563 40%

2045 45,763,590 6,287,877 - 614,991 3,542,179 5,058,207 4,410,121 676,039 13,686,545 7.34% 3,070,154 40,820,085 54,506,630 3.98 122,801,072 37%

2046 40,820,085 6,287,877 - 627,291 3,193,842 4,877,636 4,379,701 746,725 13,197,905 7.34% 2,724,472 36,007,239 49,205,144 3.73 118,378,449 34%

2047 36,007,239 6,287,877 - 639,836 2,859,942 4,682,575 4,408,196 829,596 12,780,309 7.34% 2,385,812 31,260,784 44,041,092 3.45 114,153,161 32%

2048 31,260,784 6,287,877 - 652,633 2,542,260 4,473,291 4,346,636 917,420 12,279,607 7.34% 2,055,011 26,671,432 38,951,039 3.17 110,042,986 28%

2049 26,671,432 6,287,877 - 665,686 2,242,441 4,253,928 4,255,211 1,017,802 11,769,382 7.34% 1,736,076 22,260,317 34,029,699 2.89 106,185,563 25%

2050 22,260,317 6,287,877 - 678,999 1,961,960 4,028,590 4,123,784 1,154,637 11,268,970 7.34% 1,429,860 18,030,084 29,299,054 2.60 102,597,709 22%

2051 18,030,084 6,287,877 - 692,579 1,702,052 3,794,528 3,944,642 1,319,758 10,760,981 7.34% 1,137,184 14,001,585 24,762,567 2.30 99,278,188 18%

2052 14,001,585 6,287,877 - 706,431 1,463,623 3,558,375 3,789,576 1,489,352 10,300,926 7.34% 857,578 10,139,684 20,440,610 1.98 96,254,559 15%

2053 10,139,684 6,287,877 - 720,560 1,247,162 3,321,230 3,608,825 1,663,985 9,841,202 7.34% 590,178 6,455,978 16,297,180 1.66 93,496,939 11%

2054 6,455,978 6,287,877 - 734,971 1,052,696 3,085,039 3,428,246 1,832,459 9,398,440 7.34% 335,237 2,945,680 12,344,121 1.31 91,019,790 7%

2055 2,945,680 6,287,877 - 749,670 879,791 2,855,084 3,213,522 1,997,671 8,946,068 7.34% 93,359 - 8,577,246 0.96 88,830,688 3%

Benefit Payments

IBT730-0061
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.04(1a) 

Effect of Proposed Suspension in Aggregate and by Group (Checklist Item #12) 

Average Monthly Average Monthly Aggregate Present

Participant Benefit Before Benefit After Value of Reduction

Status Count Suspension Suspension in Benefits

Retired 878 2,083.02 1,576.39 38,860,419 

Beneficiary 143 506.64 445.96 973,399 

QDRO 27 1,029.81 775.33 635,712 

Term Vested 685 1,690.67 1,189.32 22,579,749 

Active 294 2,219.96 1,595.62 11,111,456 

Total 2,027 1,845.06 1,491.87 74,160,735 

IBT730-0062
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.04(1a) 

Effect of Proposed Suspension in Aggregate and by Group (Checklist Item #12) 

Average Monthly Average Monthly Aggregate Present

Participant Benefit Before Benefit After Value of Reduction

Status Count Suspension Suspension in Benefits

Retired 878 2,083.02 1,576.39 38,860,419 

Beneficiary 143 506.64 445.96 973,399 

QDRO 27 1,029.81 775.33 635,712 

Term Vested 685 1,690.67 1,189.32 22,579,749 

Active 294 2,219.96 1,595.62 11,111,456 

Total 2,027 1,845.06 1,491.87 74,160,735 

Total

Formerly Contributing Average Monthly Average Monthly Aggregate Present

Employers Participant Benefit Before Benefit After Value of Reduction

Status Count Suspension Suspension in Benefits

Retired 155 339.04 290.99 545,614 

Beneficiary 36 145.52 143.37 9,975 

QDRO 0 0 0 0 

Term Vested 163 536.12 318.34 2,021,587 

Active 0 0 0 0 

Total 354 410.10 249.10 2,577,176 

Currently Contributing Average Monthly Average Monthly Aggregate Present

Employers Participant Benefit Before Benefit After Value of Reduction

Status Count Suspension Suspension in Benefits

Retired 641 2,282.03 1,743.54 29,463,131 

Beneficiary 102 622.02 547.74 842,426 

QDRO 21 961.28 737.98 395,712 

Term Vested 405 1,700.71 1,226.98 12,996,406 

Active 277 2,195.21 1,580.62 10,351,088 

Total 1,446 1,966.30 1,080.06 54,048,763 

Combination Average Monthly Average Monthly Aggregate Present

Participant Benefit Before Benefit After Value of Reduction

Status Count Suspension Suspension in Benefits

Retired 82 3,823.95 2,699.50 8,851,674 

Beneficiary 5 752.90 548.34 120,999 

QDRO 6 1,269.68 906.08 239,998 

Term Vested 117 3,264.41 2,272.40 7,561,756 

Active 17 2,623.38 1,839.99 760,367 

Total 227 3,310.48 159.10 17,534,794 

IBT730-0062.1
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.04(1b) 

Distribution of Proposed Suspension by Group (Checklist Item #12) 

Total

>0% and >10% and >20% and >30% and >40% and >50% and >60% and >70% and >80% and >90% and

Status 0% <=10% <=20% <=30% <=40% <=50% <=60% <=70% <=80% <=90% <=100% Total

Retired 222 124 54 438 32 1 3 2 1 1 0 878

Beneficiary 71 40 13 18 1 0 0 0 0 0 0 143

QDRO 5 3 1 18 0 0 0 0 0 0 0 27

Term Vested 18 63 16 436 84 3 18 47 0 0 0 685

Active 0 0 3 281 10 0 0 0 0 0 0 294

Total 316 230 87 1191 127 4 21 49 1 1 0 2,027 

Headcount by Benefit Reduction Percentage

Formerly Contributing

Employers >0% and >10% and >20% and >30% and >40% and >50% and >60% and >70% and >80% and >90% and

Status 0% <=10% <=20% <=30% <=40% <=50% <=60% <=70% <=80% <=90% <=100% Total

Retired 85 48 9 5 1 1 2 2 1 1 0 155

Beneficiary 31 5 0 0 0 0 0 0 0 0 0 36

QDRO 0 0 0 0 0 0 0 0 0 0 0 0

Term Vested 16 58 13 3 5 3 18 47 0 0 0 163

Active 0 0 0 0 0 0 0 0 0 0 0 0

Total 132 111 22 8 6 4 20 49 1 1 0 354 

Headcount by Benefit Reduction Percentage

Currently Contributing

Employers >0% and >10% and >20% and >30% and >40% and >50% and >60% and >70% and >80% and >90% and

Status 0% <=10% <=20% <=30% <=40% <=50% <=60% <=70% <=80% <=90% <=100% Total

Retired 135 76 45 385 0 0 0 0 0 0 0 641

Beneficiary 39 35 13 15 0 0 0 0 0 0 0 102

QDRO 5 3 1 12 0 0 0 0 0 0 0 21

Term Vested 2 5 3 395 0 0 0 0 0 0 0 405

Active 0 0 3 274 0 0 0 0 0 0 0 277

Total 181 119 65 1081 0 0 0 0 0 0 0 1,446 

Headcount by Benefit Reduction Percentage

Combination

>0% and >10% and >20% and >30% and >40% and >50% and >60% and >70% and >80% and >90% and

Status 0% <=10% <=20% <=30% <=40% <=50% <=60% <=70% <=80% <=90% <=100% Total

Retired 2 0 0 48 31 0 1 0 0 0 0 82

Beneficiary 1 0 0 3 1 0 0 0 0 0 0 5

QDRO 0 0 0 6 0 0 0 0 0 0 0 6

Term Vested 0 0 0 38 79 0 0 0 0 0 0 117

Active 0 0 0 7 10 0 0 0 0 0 0 17

Total 3 0 0 102 121 0 1 0 0 0 0 227 

Headcount by Benefit Reduction Percentage

IBT730-0062.b
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.04(1b) 

Distribution of Proposed Suspension by Group (Checklist Item #12) 

>0% and >10% and >20% and >30% and >40% and >50% and >60% and >70% and >80% and >90% and

Status 0% <=10% <=20% <=30% <=40% <=50% <=60% <=70% <=80% <=90% <=100% Total

Retired 222 124 54 438 32 1 3 2 1 1 0 878

Beneficiary 71 40 13 18 1 0 0 0 0 0 0 143

QDRO 5 3 1 18 0 0 0 0 0 0 0 27

Term Vested 18 63 16 436 84 3 18 47 0 0 0 685

Active 0 0 111 173 10 0 0 0 0 0 0 294

Total 316 230 195 1083 127 4 21 49 1 1 0 2,027 

Headcount by Benefit Reduction Percentage

IBT730-0063
Warehouse Employees Union Local No. 730 

Pension Trust Fund 

911 Ridgebrook Road 8400 Corporate Drive, Suite 430 

Sparks, Maryland 21152-9451 Landover, Maryland 20785-2361

Telephone: (800) 730-2241 Telephone: (800) 730-2241 

www.associated-admin.com www.associated-admin.com

1

 A version of this notice that does not include the estimate of the effect on your benefit is being sent to the Union 

that represents Plan participants and to all Contributing Employers. 

NOTICE OF A PROPOSED REDUCTION OF YOUR PENSION BENEFITS 

On or about February 26, 2021, the Board of Trustees of the Warehouse Employees Local No. 

730 Pension Trust Fund (“Plan”) submitted an application to the U.S. Treasury Department for 

approval to reduce benefits under the Plan. This type of benefit reduction is allowed by the 

Multiemployer Pension Reform Act of 2014. 

You are getting this notice because you have a pension benefit under the Plan. The end of this 

notice describes the proposed reduction of your monthly payments.1 This notice also answers 

the following questions: 

1. Why is the Board of Trustees proposing to reduce benefits?

2. What will happen if the Plan runs out of money?

3. How did the Board of Trustees decide whose benefits to reduce and by how much?

4. What are the proposed reductions in benefits?

5. What comes next?

1. WHY IS THE BOARD OF TRUSTEES PROPOSING TO REDUCE BENEFITS?

Since 2009, the Plan’s financial status has declined. As was the case for most other 

multiemployer pension funds, the unprecedented global financial crisis of 2008 had a devastating 

effect on the Plan. In addition, because of employer withdrawals and participant retirements for 

a variety of reasons, the Plan went from having nearly 950 active participants in 2008 to slightly 

more than 300 active participants in 2019. As of 2020, there were 312 active participants and 

1,701 retired and deferred vested participants. In 2010, the ratio of retirees/deferred vested 

participants to active participants was approximately 1.4 to 1; today the ratio is almost 5.5 to 1. 

The Plan has simply been unable to replace retirees with new hires on a one-to-one basis. 

The Plan’s actuary estimated that, unless benefits are reduced, the Plan will not have enough 

money to pay benefits in the year 2032. This estimate is based on how much money the Plan’s 

actuary expects the Plan to receive and to pay out each year. The Plan’s actuary estimated that, 

with the reduction of benefits that the Board of Trustees has proposed, the Plan should not run 

out of money. 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05 

Participant Notice Calculations (Checklist Item #13)

IBT730-0064
2. WHAT WILL HAPPEN IF THE PLAN RUNS OUT OF MONEY? 

If the Plan does not have enough money to pay benefits, then only the amount guaranteed by 

the Pension Benefit Guarantee Corporation (“PBGC”) will be paid. You can find the amount of 

your benefit that is guaranteed by PBGC at the end of this notice. 

3. HOW DID THE BOARD OF TRUSTEES DECIDE WHOSE BENEFITS TO REDUCE AND BY HOW 

MUCH?

Under federal law, the Board of Trustees must apply the following rules to the proposed 

reduction— 

■ The total reduction in all participants’ benefits must be estimated to be large enough to 

keep the Plan from running out of money, but not larger than needed to keep the Plan 

from running out of money. 

■ Your monthly benefit and the benefit of your beneficiary cannot be reduced below 110% 

of the amount guaranteed by PBGC. 

■ The benefits of people who are at least 80 years old on January 31, 2022 and their 

beneficiaries cannot be reduced. 

■ The benefits of people who are at least 75 years old on January 31, 2022 and their 

beneficiaries are partially protected, and the closer the person is to age 80 the less the 

benefits can be reduced. 

■ The reduction of benefits must be spread fairly among the people who have a pension 

benefit under the Plan. 

In deciding whether the proposed reduction is spread fairly, the Board of Trustees took into 

account the following: 

■ Risk of continued employer withdrawals (including the Plan’s largest contributing 

employer) from the Plan and increasing the risk of additional benefit reductions for 

participants in and out of pay status. 

■ Negative reaction by participants employed by Current Contributing Employers that 

would further prompt withdrawals of Current Contributing Employers’ participant groups 

and Current Contributing Employers, and participants employed by Current Contributing 

Employers reasonably likely to withdraw support for the Plan’s application. 

■ History of benefit reductions for participants employed by Current Contributing 

Employers. 

■ Failure of Former Contributing Employers to pay the full amount of withdrawal liability or 

completely fund the benefits of their employees. 

■ Differences in historical and future employer contribution rates/increases as between 

Current Contributing Employers and Former Contributing Employers. 

■ Negative reaction by Current Contributing Employers that are funding current benefits as 

well as helping to fund benefits for past service earned by participants who were 

employees of Former Contributing Employers. 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05 

Participant Notice Calculations (Checklist Item #13)

IBT730-0065
4. WHAT ARE THE PROPOSED REDUCTIONS IN BENEFITS? 

The Board of Trustees proposes the following reduction in benefits effective January 1, 2022: 

Your benefit and service will be split between the amounts you earned during the time you 

worked for an employer that currently contributes to the Plan (Current Contributing Employer) 

and the amounts you earned during the time you worked for an employer that no longer 

contributes to the Plan (Former Contributing Employer(s)). The Current Contributing Employers 

are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff. All other employers 

for whom you worked and accrued benefits under the Plan are Former Contributing Employers. 

Benefits earned based on service with Current Contributing Employers will be reduced by 28%. 

Benefits earned based on service with Former Contributing Employers will be reduced to 110% 

of the PBGC guaranteed benefit or by 28% if this results in a lower benefit. 

Your Benefits earned on service with both Current and Former Contributing Employers will then 

be added together and increased if necessary to comply with legal limits. In no event will your 

total benefit be reduced below the legal limitation. 

The last page of this notice provides a dollar estimate of how the proposed reduction applies 

to you. 

The proposed reduction will remain in effect indefinitely and will not expire by its own terms. 

These reductions are projected to keep the Plan from running out of money. 

5. WHAT COMES NEXT?

Approval or Denial of the Application by the Treasury Department 

The Treasury Department will review the application to see whether it meets all of the legal 

requirements under federal Law. If the application meets all of those requirements, the Treasury 

Department is required to approve the application. If the application does not meet the legal 

requirements, the Treasury Department will deny the application. The Treasury Department will 

have until October 8, 2021 to make a decision. 

You Can Get Information from the Treasury Department 

More information about the proposed benefit reductions and a copy of the application will be 

available at https://home.treasury.gov/services/the-multiemployer-pension-reform-act-of-2014

The application will be available on that website within 30 days after the Treasury Department 

receives it. The application includes more information about the proposed reduction, including 

details about: 1) the Plan actuary’s certification that the Plan will run out money (that is, that the 

Plan is in “critical and declining status”); 2) how the proposed reduction would satisfy the 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05 

Participant Notice Calculations (Checklist Item #13)

IBT730-0066
requirement that it be large enough so that the Plan is estimated not to run out of money, while 

not being larger than needed; and 3) the sensitivity of these estimates to the assumptions used. 

The application describes the steps the Board of Trustees has already taken to keep the Plan from 

running out of money and why the Board of Trustees believes that benefit reduction is the only 

remaining option to keep the Plan from running out of money. In addition, the application 

explains why the Board of Trustees believes that the proposed reduction is spread fairly among 

the people who have a pension benefit under the Plan. 

The Treasury Department website will also provide updated information on the application, such 

as whether the application has been withdrawn. 

For further information and assistance, you can also write to the Treasury Department at the 

following address: 

Department of the Treasury 

Attn: MPRA Office, Room 1204 

1500 Pennsylvania Avenue, NW 

Washington, DC 20220 

You can Comment on the Application to Reduce Benefits 

You will be able to submit a comment on the application by going to www.treasury.gov/mpra. 

Comments may also be mailed to the Treasury Department, at the address listed above. All 

interested parties can make comments, and the comments will be publicly available. 

Retiree Representative 

Because the Plan has fewer than 10,000 participants, the Board of Trustees is not required to 

select a retiree representative. 

Vote on the Proposed Benefit Reduction 

If the application for the proposed reduction of benefits is approved by the Treasury Department, 

then you will have the opportunity to vote on the proposed reduction. Unless a majority of all 

participants and beneficiaries of the Plan vote to reject the reduction, the Treasury Department 

must allow the reduction of benefits to take effect. This means that not voting counts the same 

as a vote to approve the reduction. 

Your Right to See Plan Documents 

You may want to review Plan Documents to help you understand your rights and the proposed 

reduction to your benefits. The Plan Administrator must respond to your request for the 

following documents within 30 days: 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05 

Participant Notice Calculations (Checklist Item #13)

IBT730-0067
■ The Plan document (including any amendments adopted to reflect an authorized 

reduction of benefits), trust agreement, and other documents governing the Plan (such 

as collective bargaining agreements). 

■ The Plan’s most recent summary plan description (SPD or Plan brochure) and any 

summaries of material modifications. 

■ The Plan’s Form 5500 Annual Reports, including the accountant’s report and audited 

financial statements, filed with the U.S. Department of Labor during the last six years. 

■ The annual funding notices furnished by the Plan during the last six years. 

■ Actuarial reports, including reports prepared in anticipation of the benefit reductions, 

furnished to the Plan within the last six years. 

■ The Plan’s current rehabilitation plan, including contribution schedules, and, if the 

proposed benefit reduction goes into effect, annual Plan-sponsor determinations that all 

reasonable measures to avoid running out of money continue to be taken and that the 

Plan would run out of money if there were no benefit reductions. 

■ Any quarterly, semi-annual, or annual financial reports prepared for the Plan by an 

investment manager, fiduciary, or other advisor and furnished to the Plan within the last 

six years. 

The Plan Administrator may charge you the cost per page to the Plan for the least expensive 

method of coping documents, but cannot charge more than 25 cents per page. The Plan’s Form 

5500 Annual Return / Report of Employee Benefit Plan is also available free of charge at 

www.efast.dol.gov. Some of the documents also may be available for examination, without 

charge, at the Plan Administrator’s office or Union Hall. 

Your Right to Challenge Incorrect Calculations 

If you think the Plan miscalculated the reduction to your benefits, then you have the right to 

submit a claim to the Plan to have the calculation corrected. The Plan’s SPD tells you how to 

submit a claim. The SPD also describes your right to have a court review the Plan’s final decision 

on your claim. 

If you believe the information used to calculate your estimate at the end of this notice is wrong, 

please contact the Plan Office: 

911 Ridgebrook Road 

Sparks, MD 21152-9451 

800-730-7741 

730questions@associated-admin.com

Sincerely, 

BOARD OF TRUSTEES 

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05 

Participant Notice Calculations (Checklist Item #13)

IBT730-0068
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

In-Pay (Retiree - Level Income Option Payment Form)

Based on the form of payment you chose at retirement, your benefit will change over time. Below is a table 

showing what your benefit will be during each payment period. Your current monthly benefit is in the 

‘Current Benefit’ column. Under the proposed reduction your monthly benefit will be reduced to the 

amounts shown in the 'Proposed Reduced Benefit' column beginning on January 1, 2022. The proposed 

reduction is intended to be permanent. The proposed reduction is intended to be permanent. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The estimated amount of your monthly benefit guaranteed by PBGC is 

in the ‘PBGC Guaranteed Benefit’ column. 

Payment Period Current Benefit 

PBGC Guaranteed 

Benefit 

Proposed Reduced 

Benefit 

01/01/2022 

07/01/2025 

06/30/2025 $ 909.42 

$ 494.10 

$ 771.95 

$ 460.45 

$ 849.15 

$ 494.09 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 0.000 years of Credited Service under the Plan with a Current Contribution Employer, and

32.686 years with a Former Contributing Employer.1

 You will be 68 years and 8 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05a 

Participant Notice Calculations (Checklist Item #13)

IBT730-0069
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

In-Pay (Beneficiary)

Current benefits 

Your current monthly benefit is $980.28. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $773.13. 

Revised benefits under proposed reduction 

Under the proposed reduction your monthly benefit will be reduced to $850.44 beginning on January 1, 

2022. The proposed reduction is intended to be permanent. The proposed reduction is intended to be 

permanent. 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 Your spouse has earned 21.626 years of Credited Service under the Plan with a Current Contributing

Employer, and 0.000 years with a Former Contributing Employer.1

 You will be 71 years and 11 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05b 

Participant Notice Calculations (Checklist Item #13)

IBT730-0070
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

Not In-Pay (Active Participant)

If you start receiving your benefit on December 1, 2038 in the form of a level income option, your monthly 

benefit will change over time. Below is a table showing what your benefit, with no additional accruals 

beyond January 1, 2020, will be during each payment period. Your benefit without the proposed reduction 

would be the amounts in the ‘Current Benefit’ column. Under the proposed reduction your monthly benefit 

would be reduced to the amounts in the ‘Proposed Reduced Benefit’ column. The proposed reduction is 

intended to be permanent. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The estimated amount of your monthly benefit guaranteed by PBGC is 

in the ‘PBGC Guaranteed Benefit’ column. 

Payment Period Current Benefit 

PBGC Guaranteed 

Benefit 

Proposed Reduced 

Benefit 

12/01/2038 

12/01/2040 

12/01/2045 

12/01/2047 

11/30/2040 

11/30/2045 

11/30/2047 

$ 306.53 

$ 919.68 

$ 781.74 

$ 475.17 

$ 259.55 

$ 385.49 

$ 385.49 

$ 385.49 

$ 285.51 

$ 662.17 

$ 562.85 

$ 424.04 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 10.783 years of Credited Service under the Plan with a Current Contributing Employer,

and 0.000 years with a Former Contributing Employer.1

 You will be 43 years and 2 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05c 

Participant Notice Calculations (Checklist Item #13)

IBT730-0071
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

Not In-Pay (Term Vested)

If you start receiving your benefit on December 1, 2029 in the form of a level income option, your monthly 

benefit will change over time. Below is a table showing what your benefit, with no additional accruals 

beyond January 1, 2020, will be during each payment period. Your benefit without the proposed reduction 

would be the amounts in the ‘Current Benefit’ column. Under the proposed reduction your monthly benefit 

would be reduced to the amounts in the ‘Proposed Reduced Benefit’ column. The proposed reduction is 

intended to be permanent. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The estimated amount of your monthly benefit guaranteed by PBGC is 

in the ‘PBGC Guaranteed Benefit’ column. 

Payment Period Current Benefit 

PBGC Guaranteed 

Benefit 

Proposed Reduced 

Benefit 

12/01/2029 

12/01/2036 

11/30/2036 $ 124.20 

$ 62.10 

$ 107.99 

$ 61.42 

$ 118.79 

$ 62.10 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 0.000 years of Credited Service under the Plan with a Current Contributing Employer, and

5.397 years with a Former Contributing Employer.1

 You will be 54 years and 2 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05d 

Participant Notice Calculations (Checklist Item #13)

IBT730-0072
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

In-Pay (Retiree - J&S Payment Form)

Current benefits 

Your current monthly benefit is $2,086.17 (with a $1,391.48 monthly survivor benefit for your spouse). 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $1,203.31 (with a $1,136.17 monthly survivor benefit for your spouse). 

Revised benefits under proposed reduction

Under the proposed reduction your monthly benefit will be reduced to $1,638.34 (with a $1,282.85 monthly 

survivor benefit for your spouse) beginning on January 1, 2022. The proposed reduction is intended to be 

permanent. The proposed reduction is intended to be permanent. 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 33.659 years of Credited Service under the Plan with a Current Contributing Employer,

and 0.000 years with a Former Contributing Employer.1

 You will be 76 years and 2 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05e 

Participant Notice Calculations (Checklist Item #13)

IBT730-0073
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

In-Pay (Retiree - Single Life Payment From)

Current benefits 

Your current monthly benefit is $427.36. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $427.36. 

Revised benefits under proposed reduction 

Your monthly benefit would not change under the proposed reduction. The proposed reduction is intended 

to be permanent. 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 0.000 years of Credited Service under the Plan with a Current Contributing Employer, and

41.604 years with a Former Contributing Employer.1

 You will be 79 years and 10 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05f 

Participant Notice Calculations (Checklist Item #13)

IBT730-0074
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

In-Pay (Beneficiary)

Current benefits 

Your current monthly benefit is $682.62. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $569.72. 

Revised benefits under proposed reduction 

Under the proposed reduction your monthly benefit will be reduced to $659.31 beginning on January 1, 

2022. The proposed reduction is intended to be permanent. The proposed reduction is intended to be 

permanent. 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 Your spouse has earned 21.000 years of Credited Service under the Plan with a Current Contributing

Employer, and 0.000 years with a Former Contributing Employer.1

 You will be 77 years and 11 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05g 

Participant Notice Calculations (Checklist Item #13)

IBT730-0075
1

 Current Contributing Employers are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff.

 All other employers are considered Former Contributing Employers. 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED 

This estimate of the effect of the proposed reduction of benefits has been prepared for: 

Not In-Pay (Term Vested)

If you start receiving your benefit on January 1, 2022 in the form of a level income option, your monthly 

benefit will change over time. Below is a table showing what your benefit, with no additional accruals 

beyond January 1, 2020, will be during each payment period. Your benefit without the proposed reduction 

would be the amounts in the ‘Current Benefit’ column. Under the proposed reduction your monthly benefit 

would be reduced to the amounts in the ‘Proposed Reduced Benefit’ column. The proposed reduction is 

intended to be permanent. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than the 

amount guaranteed by the PBGC. The estimated amount of your monthly benefit guaranteed by PBGC is 

in the ‘PBGC Guaranteed Benefit’ column. 

Payment Period Current Benefit 

PBGC Guaranteed 

Benefit 

Proposed Reduced 

Benefit 

01/01/2022 

01/01/2030 

12/31/2029 $ 743.71 

$ 409.04 

$ 607.28 

$ 356.28 

$ 722.26 

$ 404.19 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a final 

benefit calculation. This estimate was prepared assuming that the proposed reduction starts on January 1, 

2022. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might be 

different. 

The estimate is based on the following information from Plan records: 

 You have 18.000 years of Credited Service under the Plan with a Current Contributing Employer,

and 0.000 years with a Former Contributing Employer.1

 You will be 78 years and 7 months old as of January 31, 2022.

 No portion of your benefit is based on a disability pension in this Plan.

Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 4.05h 

Participant Notice Calculations (Checklist Item #13)

IBT730-0076
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.01 

Sample Ballot (Checklist Item #22) 

Fund Office: 911 Ridgebrook Road  Sparks, MD 22102 

Phone: 800-730-7741 

BALLOT ON THE PROPOSED SUSPENSION OF BENEFITS FOR THE WAREHOUSE 

EMPLOYEES UNION LOCAL NO. 730 PENSION TRUST. 

The Trustees of the Warehouse Employees Union Local No. 730 Pension Trust sent a Notice to 

all participants, retirees and beneficiaries on March 1, 2021, setting forth a proposal to suspend 

benefits received by participants and beneficiaries on or after January 1, 2022. “Suspend” means 

that benefits will be reduced for an indefinite period of time. 

The notice sent in March 2021 described the proposed reduction in benefits, the effect of the 

reduction on those affected by the proposal and the factors considered by the Trustees in 

designing the proposal. The Trustees have taken this action because they have determined that a 

reduction in benefits is necessary for the Plan to avoid running out of money. 

This ballot is being provided to you because you are eligible to vote to approve or reject the 

suspension (reduction) of benefits. 

THE PROPOSED SUSPENSION 

An explanation of the proposed suspension and the individualized estimate detailing how the 

suspension will affect your benefit were included in the March 2021 Notice. A new copy of your 

individualized estimate is attached to this Ballot. If you need another copy of the March 2021 

Notice please contact the Fund Office. The proposed suspension is summarized below. 

Your benefit and service will be split between the amounts you earned during the time you 

worked for an employer that currently contributes to the Plan (Current Contributing Employer) 

and the amounts you earned during the time you worked for an employer that no longer 

contributes to the Plan (Former Contributing Employer(s)). The Current Contributing Employers 

are: Giant, Washington Food, Eight O’Clock Coffee, and Local 730 Union Staff. All other 

employers for whom you worked and accrued benefits under the Plan are Former Contributing 

Employers. 

Benefits earned based on service with Current Contributing Employers will be reduced by 28%. 

Benefits earned based on service with Former Contributing Employers will be reduced to the 

lesser of: 

a. 28% reduction, or 

b. 110% of the PBGC guaranteed benefit based on Former Contributing Employer(s) 

benefits and service. 

IBT730-0077
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.01 

Sample Ballot (Checklist Item #22) 

In no event will your total benefit be reduced below the legal limitation. 

The proposed suspension will remain in effect indefinitely and will not expire by its own terms. 

These reductions, combined with a partition, are projected to keep the Plan from running out of 

money. 

FACTORS CONSIDERED BY THE TRUSTEES IN DESIGNING THE BENEFIT 

SUSPENSIONS 

The Trustees considered a variety of factors including but not limited to the factors listed in 

Internal Revenue Code Section 432(e)(9)(D)(vi) in designing the benefit suspension and making 

them as fair as possible. Under Federal law, the Board of Trustees must apply the following rules 

to the proposed reduction: 

 The total reduction in everybody’s benefits must be estimated to be large enough to keep 

the Plan from running out of money but not larger than needed to do that. 

 Your monthly benefit and benefit of your beneficiary cannot be reduced below 110% of 

the amount guaranteed by PBGC. 

 The benefits of people who are at least 80 years old on January 31, 2022 and their 

beneficiaries cannot be reduced. 

 The benefits of people who are at least 75 years old on January 31, 2022, and their 

beneficiaries are partially protected, and the closer the person is to age 80 the less the 

benefits can be reduced. 

 The reduction of benefits must be spread fairly among the people who have a pension 

benefit under the Plan. 

IMPORTANT POINTS YOU SHOULD CONSIDER 

In considering how you will vote, here is some additional information that may be helpful to you 

in making your decision: 

1. The proposed benefit reduction will not reduce future accruals for service earned on or after 

January 1, 2022. 

2. The proposed reduction will remain in effect indefinitely. 

3. The plan Actuary has determined that if the benefits are not reduced as proposed, the Fund 

will run out of money in the year 2032. Conversely, the Plan Actuary has certified that the 

Plan is projected to avoid running out of money if these reductions are approved and 

implemented. The Plan Actuary’s projections are, in part, based on assumptions about future 

contribution levels and investment rates of return, and therefore these projections are subject 

to some degree of uncertainty. 

IBT730-0078
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.01 

Sample Ballot (Checklist Item #22) 

4. If the Fund runs out of money, the Fund will not be able to pay all of the benefits promised 

and benefits paid would be less than the benefits under the proposed suspension. 

5. The PBGC acts as a guarantor of benefits provided by plans like this one, but only to a 

certain level. The benefits that would be paid under the Trustees’ proposal are greater than 

the benefits guaranteed by the PBGC. In addition, should the PBGC itself run out of money, 

the PBGC would not be able to pay the guaranteed benefits and whatever it could pay would 

be less than what would otherwise be paid if the Plan runs out of money. 

6. The proposed suspension will go into effect unless a majority of all eligible voters vote to 

reject the suspension. Therefore, a failure to vote has the same effect on the outcome of the 

vote as a vote in favor of suspension. 

SUPPORT, APPROVAL AND OPPOSITION 

1. The Board of Trustees strongly and unanimously supports these proposed benefit 

reductions. The Trustees believe all reasonable measures have been taken to avoid benefit 

reductions, including reductions in active participants’ benefits and future accruals as 

well as increases in Employer contributions to the Plan. The Trustees have determined 

that despite these measures the benefit reductions are required to reasonably ensure that 

the Plan will not run out of money. 

2. The Secretary of the Treasury, in consultation with PBGC and the Secretary of Labor, has 

approved the Trustees’ proposal. 

3. Statement of Opposition [TBD] 

IBT730-0079
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

The Exhibit details the information on actuarial assumptions and methods that, pursuant to 

Section 6.03 of Revenue Procedure 2017-43, must be described in an application for approval of 

a proposed benefit suspension. 

Part 1 – Actuarial assumptions and methods used for projections. 

Investment returns 

 Net investment return for deterministic projections: 

o 6.53% per year for the plan years ending December 31, 2021 thru December 31, 2030 

o 7.34% per year for the plan years ending December 31, 2031 and each year thereafter 

 Assumptions used for stochastic projections (if applicable): Not applicable 

Mortality assumptions 

 Healthy Lives: RP-2014 adjusted to 2006 Blue Collar Tables with separate rates for nonannuitants and annuitants and separate rates for males and females. Mortality 

improvement: MP-2019 projection scale beginning in 2006 

 Disabled Lives: RP-2014 adjusted to 2006 Disabled Mortality Tables with separate rates 

for males and females. Morality improvement: MP-2019 projection scale beginning in 

2006 

 Participants can have multiple benefit commencement dates. Benefits earned prior to the 

implementation of the Rehabilitation Plan have a normal retirement age of 60, while 

benefits earned after the Rehabilitation Plan have a normal retirement age of 62. In 

general the mortality tables switch from pre-commencement to post-commencement at 

the first benefit commencement date. However, as discussed during a pre-application call 

with PBGC and Treasury, there is a limitation within ProVal for the post termination 

death benefit of active participants (REA). For the piece of the benefit that commences at 

participant’s age 62 the mortality switches to post-commencement mortality at age 62 

Other demographic assumptions 

 Exhibit 6.03a contains the complete list of withdrawal and retirement decrement rates 

Assumptions regarding form and commencement age of benefits 

 Form of payment election assumptions for active and terminated vested participants: 

o 65% of all participants elect the level income annuity 

o 15% of all participants elect the straight life annuity 

o 20% of all participants elect the 50% joint and survivor annuity 

 Assumptions regarding the probability of benefit commencement by age for participants 

who have terminated with deferred benefits or who are assumed to terminate with 

deferred benefits in the future: 

IBT730-0080
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

o Exhibit 6.03a contains the retirement age assumptions for current terminated vested 

participants. Participants that terminate in the future are assumed to retire at their 

normal retirement age

 Assumptions regarding the probability of commencement by age for participants who 

have become disabled or who are assumed to become disabled in the future: 

o does not apply 

Assumptions regarding missing or incomplete data 

 Assumptions regarding terminated vested participants beyond normal retirement age 

who, because they have not commenced receiving benefit payments, could be considered 

missing: 

o All terminated vested participants are valued. Those beyond normal retirement age 

are assumed to retire immediately and receive an actuarial adjustment for late 

retirement. Late retirement adjustments are disregarded for purposes of PBGC 

Guaranteed benefits 

 Assumptions to fill in other missing data: 

o Wives of participants not yet in-pay are assumed to be three years younger than 

husbands 

o 61% of participants not yet in-pay status are assumed to be married 

New entrant profile 

 The following is a description of the composition of the new hire profile, including the 

weight applicable to each assumed age of entry: 

o The 130 Participants who were first reported as Plan participants in the January 1, 

2015, January 1, 2016, January 1, 2017, January 1, 2018, January 1, 2019, or January 

1, 2020 valuations were included in the development of the new hire profile 

o Each participant was assigned an equal weight for purposes of assumed age of entry 

o The data was adjusted such that each new entrant’s age at hire, service, and accrued 

benefit as of each respective valuation date were preserved 

o New Entrants are assumed to work 1,900 hours per year 

Contribution rates 

 Each employer’s current contribution rate is assumed to increase by 4.9% annually 

through 2027, then 2% annually for the next five years. The contribution rate is expected 

to remain level thereafter. These contribution rate increases are not benefit bearing.

Contribution base units 

 The contribution base units are assumed remain level during the projection period. The 

headcount is assumed to stay at 294, and the CBUs are assumed to stay at 562,748 

IBT730-0081
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

Withdrawal Liability Payments 

Plan Year Beginning 

January 1,

Current Withdrawn 

Employers Future Withdrawals Total Withdrawal Liability Payments

2020 $ 663,674 - $ 663,674 

2021 $ 663,674 - $ 663,674 

2022 $ 663,674 - $ 663,674 

2023 $ 663,674 - $ 663,674 

2024 $ 663,674 - $ 663,674 

2025 $ 663,674 - $ 663,674 

2026 $ 663,674 - $ 663,674 

2027 $ 663,674 - $ 663,674 

2028 $ 663,674 - $ 663,674 

2029 $ 663,674 - $ 663,674 

2030 $ 663,674 - $ 663,674 

2031 $ 663,674 - $ 663,674 

2032 $ 663,674 - $ 663,674 

2033 $ 165,919 - $ 165,919 

2034 - - - 

2035 - - - 

2036 - - - 

2037 - - - 

2038 - - - 

2039 - - - 

2040 - - - 

2041 - - - 

2042+ - - - 

 Current Withdrawn Employers: There is 1 former employer (McKesson) who has been 

making payments since withdrawing in 2012. Based on the Fund’s experience with 

receiving withdrawal liability payments from this employer, it is assumed that they will 

continue to make the payments for the remainder of the required 80 quarterly installments 

 Future Withdrawals: As of January 2021, there were 5 employers contributing to the 

Fund. It is assumed they all will remain in the Fund 

Administrative expenses 

 2021 is assumed to be $652,000. This includes work related to this application 

 2022 is assumed to be $390,000 

 2023 and thereafter is assumed to increase by 2% per year 

Projection Methodology 

 No approximation or data grouping techniques were used in projections 

 No changes were made to the cash flow projections that would normally be provided by 

the actuarial software 

IBT730-0082
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

Part 2 – Supporting documentation for selection of certain assumptions. 

Investments Returns 

 Exhibit 6.03b contains the components of the target portfolio used in the projections 

(expressed in terms of the asset classes used for setting the Fund’s investment policy). 

Exhibit 6.03c contains the allocation of the components of the target portfolio among the 

asset classes, as listed in Appendix B of Revenue Procedure 2017-43. This information 

was provided by Investment Performance Services, LLC 

 The current mix of assets is not materially different from the target portfolio 

 The mix of assets is not expected to vary over time 

 Exhibit 6.03c contains the short-term and long-term investment return assumptions 

associated with the target portfolio. The following information is also provided: 

o The expected geometric and arithmetic expected returns, for each asset class 

o The standard deviation of returns for each asset class 

o The correlations for the returns among the asset classes 

o The inflation rate inherent in the net investment return

Demographic experience 

 Exhibit 6.03e and 6.03f contain recent demographic experience, due to the small nature 

of this plan there isn’t enough credibility to warrant more large expensive experience 

studies 

 Exhibit 6.03d contains the liability gain or loss analyses performed over the last ten years 

 Marital information was available, through the fund administrator, for participants in the 

Plan. 61% of Plan participants are married 

 Exhibit 6.03e contains the distribution of each optional form of benefit selected at 

retirement for the last five years 

 Exhibit 6.03f contains the retirement rates by age for benefit commencements during the 

last 5 years, separately for active and terminated vested participants 

Mortality assumptions 

 The assumed mortality rates used for Healthy participants are those from the RP-2014 

adjusted to 2006 Blue Collar sex-distinct tables 

 The assumed mortality rates used for Disabled participants are those from the RP-2014 

adjusted to 2006 Disabled Retiree sex-distinct tables 

 Tables issued by the Society of Actuaries (available at https://www.soa.org/experiencestudies/2014/research-2014-rp/) 

 Mortality rates were not based on plan experience study data but were instead taken from 

the SOA tables noted above. A description of the process that was used to construct these 

mortality rates can be found in the RP-2014 Mortality Tables Report 

IBT730-0083
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

 The assumed mortality improvement rates are those published in the SOA MP-2019 

improvement scale. These mortality improvement rates are applied to the mortality rates 

starting with the 2006 year 

 No adjustments have been made to the published mortality tables with improvements 

New entrant profile 

 Information and analysis used in the selection of the new entrant profile provided below: 

o A distribution of ages of all new active entrants for each of last five years is shown 

below. A new entrant for purposes of the table below is someone who was an active 

participant as of the valuation date shown but who was not a Plan participant as of the 

prior valuation date 

Age Range Percentage of New Entrants 

1/1/2015 1/1/2016 1/1/2017 1/1/2018 1/1/2019 1/1/2020 

Below 20 3% 0% 0% 0% 13% 14% 

20 – 24 6% 23% 20% 25% 20% 23% 

25 – 29 31% 18% 0% 13% 27% 5% 

30 – 34 13% 14% 27% 21% 13% 14% 

35 – 39 6% 9% 0% 25% 7% 27% 

40 – 44 6% 0% 7% 4% 0% 9% 

45 – 49 13% 23% 40% 4% 13% 5% 

50 – 54 9% 5% 7% 4% 0% 5% 

55 – 59 13% 9% 0% 4% 0% 0% 

60 and Over 0% 0% 0% 0% 7% 0% 

o 10 of the 130 new entrants had prior benefit service. Of these 10, their average 

benefit service is 2.01 years of service. 5 of the 130 new entrants had prior eligibility 

service 

Contribution base units and employer withdrawals 

 Exhibit 6.03g contains for each of the last 10 years a table of employers that contributed 

5% or more of the annual contributions to the Fund. The Exhibit includes the number of 

contribution base units, the average contribution rate, and the total contribution for each 

employer 

 The historical experience of the Fund with respect to contribution base units can be found 

in Section 6.04 and the historical contribution rates are documented in Section 5.01 

 The rationale for the contribution base units (i.e., hours of covered employment) 

assumption is as follows: 

o Giant Warehouse – Is a regional retail grocer operating in the Mid-Atlantic region 

and is a subsidiary of Koninklijke Ahold Delhaize N.V. In 2010 the company sold 

off the grocery side of its warehouse operation to a wholesaler who subsequently 

IBT730-0084
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

withdrew from the fund. The 2010 hours shown below have been adjusted to 

remove that sale. 

The drop in the early part of the decade was caused primarily by automation and a 

push by the company to contract-out warehousing. Following the merger of Ahold 

and Delhaize in 2016 Giant’s focus has shifted away from contracting-out 

warehousing operations, and in recent years the hours have stabilized 

o Giant Recycling – this operation has seen a level pattern of hours over most of the 

ten year period. The drop in 2012 was the result of less work following the 

closure of the contracted-out grocery warehouse operation 

o Eight O’Clock Coffee – Is a coffee roaster with a roasting operation based in 

Landover MD. It is a subsidiary of Tata Consumer Products 

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Giant Warehouse 740,626 667,005 503,797 492,958 520,811 477,973 459,547 426,408 433,729 429,956

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

History of Giant Warehouse Hours

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Giant Recycling 43,938 52,322 42,626 35,531 37,753 40,815 37,354 34,578 37,558 39,675

0

10,000

20,000

30,000

40,000

50,000

60,000

History of Giant Recycling Hours

IBT730-0085
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

o Washington Foods – Is a wholesaler grocer based in Maryland serving local 

restaurants and convenience stores. In 2016 it moved its operation from DC’s 

Union Market to Landover MD which accounts for the drop in hours in 2016. The 

operation has shown level hours since the move 

 

o Local 730 – Is the union which represents the warehouse workers of the above 

employers. The employment level declined with employers going non-union 

(notably the purchaser of the Giant Warehouse operation). The union participates 

in the fund via a participation agreement and there is no labor contract. The union 

does not anticipate a reduction in staffing 

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Washington Food 13,160 12,996 12,995 12,342 11,343 9,429 1,688 7,425 7,185 7,285

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

History of Washington Food Hours

IBT730-0086
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

 The rationale for the contribution rate assumption is as follows: The current MOA 

includes future contribution rate increases of 4.9% per year through 2027, at which point 

the rate will be $10.11/hour for Giant. Beyond this point contribution rate increases 

above inflation may not be sustainable; however modest increases are likely as the 

members and employers continue to show support for the Fund. It is assumed that 

contribution rates will increase in-line with inflation (2%) for the following five years 

 Over the last 5 years the plan has experienced 1 employer withdrawal. This employer 

paid their withdrawal liability 

Take-up rate with respect to selection of benefit/contribution schedules 

 All Employers elected to decrease their benefit schedule and increase their contribution 

rate under the preferred schedule of the Rehabilitation Plan. See section 5.01 for more 

detail 

Projection methodology 

 There were no approximation techniques used in the projections 

 No changes were made to the cash flow projections that would normally be generated by 

the actuarial software 

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

L730 Union Staff 14,832 11,580 9,404 6,716 6,900 7,832 7,176 6,160 7,536 7,208

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

History of Local 730 Hours

IBT730-0087
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03 

Information on Actuarial Assumptions and Methods (Checklist Item #25) 

Part-3 Additional disclosures relating to use of different assumptions 

 The following differences from the assumptions shown above were used for deterministic 

projections in various illustrations under the revenue procedure: 

o Exhibits 3.01a and 3.01b of the Suspension of Benefits Application use the 

assumptions detailed with Exhibit 3.01a – the certification for the January 1, 2020 

plan year 

o Exhibits 3.02, 6.05(1), 6.05(2), 6.05(3), and 6.05(4) use the assumptions detailed in 

this Exhibit 6.03. The following assumptions differ from the January 1, 2020 

certification. They were revised to reflect the most recent data available and the 

details outlined in the American Academy of Actuaries MPRA Discussion Notes: 

 Form of Payment Assumptions 

 New Entrant Profile 

 Investment Return 

 Marriage assumption 

 Retirement age assumption 

 Mortality 

 Stochastic projections were not used in this application 

IBT730-0088
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03a 

Complete Decrement Tables - Termination (Checklist Item #25) 

Termination 

Age Rates 

15 0.000000 

16 0.305478 

17 0.291044 

18 0.276608 

19 0.262170 

20 0.247728 

21 0.236986 

22 0.226238 

23 0.215490 

24 0.204736 

25 0.193976 

26 0.180168 

27 0.166354 

28 0.152532 

29 0.138704 

30 0.124866 

31 0.116326 

32 0.107778 

33 0.099218 

34 0.090646 

35 0.082058 

36 0.076178 

37 0.070278 

38 0.064356 

39 0.058414 

40 0.052448 

41 0.047290 

42 0.042026 

43 0.036664 

44 0.031204 

45 0.025656 

46 0.020678 

47 0.015620 

48 0.010486 

49 0.005276 

>=50 0.000000 

IBT730-0089
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03a 

Complete Decrement Tables - Retirement (Checklist Item #25) 

Active Retirement Rates for Individuals with Normal Retirement Age 60 

Years of Service 

Age 0 - 4 5 - 29 30 >=31 

<=59 0.000 0.000 0.350 0.150 

60 0.000 0.250 1.000 1.000 

61 0.000 0.150 1.000 1.000 

62 0.000 0.150 1.000 1.000 

63 0.000 0.150 1.000 1.000 

64 0.000 0.150 1.000 1.000 

>=65 0.000 1.000 1.000 1.000 

Active Retirement Rates for Individuals with Normal Retirement Age 62 

Years of Service 

Age 0 - 4 5 - 29 30 >=31 

<=59 0.000 0.000 0.350 0.150 

60 0.000 0.000 1.000 1.000 

61 0.000 0.000 1.000 1.000 

62 0.000 0.250 1.000 1.000 

63 0.000 0.150 1.000 1.000 

64 0.000 0.150 1.000 1.000 

>=65 0.000 1.000 1.000 1.000 

IBT730-0090
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03a 

Complete Decrement Tables - Retirement (Checklist Item #25) 

Term Vested Retirement Rates 

Age 

Individuals 

with Normal 

Retirement 

Age 60

Individuals 

with Normal 

Retirement 

Age 62

<=59 0.000 0.000 

60 0.500 0.000 

61 0.250 0.000 

62 0.250 0.500 

63 0.250 0.250 

64 0.250 0.250 

>=65 1.000 1.000 

IBT730-0091
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03b 

Components of Target Portfolio (Checklist Item #25) 

Asset Class Target Allocation 

Domestic Core Equity 32.0% 

Domestic Small/Mid Equity 10.0% 

International Equity 8.5% 

Fixed Income 14.5% 

Real Estate 22.5% 

Total Alternatives 12.5% 

Total Fund 100% 

IBT730-0092
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03c 

Investment Return Assumption (Checklist Item #25) 

Expected Returns

Target Standard Correlations Among Asset Classes

Asset Class Allocation Arith Geo Arith Geo Deviation 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

1 US Equity - Large Cap 32.0% 7.40% 6.16% 8.36% 7.06% 16.22% 1 0.89 0.84 0.73 0.15 0.14 0.63 0.12 0.48 -0.08 0.05 0.53 0.63 0.31 0.53 0.73 0.57

2 US Equity - Small/Mid Cap 10.0% 8.76% 6.85% 9.54% 7.56% 20.22% 0.89 1 0.76 0.69 0.08 0.07 0.62 0.06 0.44 -0.08 0.02 0.55 0.61 0.3 0.5 0.71 0.57

3 Non-US Equity - Developed 8.5% 8.33% 6.80% 9.09% 7.48% 18.05% 0.84 0.76 1 0.8 0.17 0.14 0.62 0.28 0.52 -0.07 0.09 0.49 0.63 0.39 0.56 0.67 0.53

4 Non-US Equity - Emerging 10.59% 7.85% 11.33% 8.42% 24.23% 0.73 0.69 0.8 1 0.16 0.11 0.62 0.23 0.62 -0.06 0.13 0.44 0.61 0.42 0.51 0.59 0.52

5 US Corporate Bonds - Core 7.0% 2.75% 2.60% 3.74% 3.56% 5.47% 0.15 0.08 0.17 0.16 1 0.86 0.38 0.53 0.44 0.23 0.67 0.22 0.15 0.08 0.25 0.04 0.11

6 US Corporate Bonds - Long Duration 3.13% 2.70% 4.11% 3.56% 10.16% 0.14 0.07 0.14 0.11 0.86 1 0.32 0.49 0.36 0.17 0.54 0.18 0.11 0.01 0.25 0.04 0.1

7 US Corporate Bonds - High Yield 7.5% 5.36% 4.90% 6.14% 5.62% 9.75% 0.63 0.62 0.62 0.62 0.38 0.32 1 0.24 0.62 -0.08 0.27 0.46 0.53 0.35 0.53 0.51 0.73

8 Non-US Debt - Developed 1.58% 1.39% 2.53% 2.26% 7.02% 0.12 0.06 0.28 0.23 0.53 0.49 0.24 1 0.41 0.21 0.45 0.19 0.13 0.21 0.28 0.07 0.01

9 Non-US Debt - Emerging 5.76% 5.16% 6.54% 5.85% 10.97% 0.48 0.44 0.52 0.62 0.44 0.36 0.62 0.41 1 0.06 0.36 0.36 0.43 0.3 0.45 0.36 0.4

10 US Treasuries (Cash Equivalents) 1.59% 1.56% 2.28% 2.25% 1.78% -0.08 -0.08 -0.07 -0.06 0.23 0.17 -0.08 0.21 0.06 1 0.22 -0.01 -0.06 0.03 -0.02 -0.06 -0.09

11 TIPS (Inflation-Protected) 2.16% 1.98% 2.94% 2.73% 6.05% 0.05 0.02 0.09 0.13 0.67 0.54 0.27 0.45 0.36 0.22 1 0.17 0.1 0.22 0.2 0.01 0.08

12 Real Estate 22.5% 7.15% 5.75% 7.91% 6.59% 16.84% 0.53 0.55 0.49 0.44 0.22 0.18 0.46 0.19 0.36 -0.01 0.17 1 0.37 0.23 0.4 0.46 0.39

13 Hedge Funds 5.08% 4.74% 6.10% 5.71% 8.00% 0.63 0.61 0.63 0.61 0.15 0.11 0.53 0.13 0.43 -0.06 0.1 0.37 1 0.37 0.49 0.6 0.52

14 Commodities 4.70% 3.19% 5.60% 4.04% 17.60% 0.31 0.3 0.39 0.42 0.08 0.01 0.35 0.21 0.3 0.03 0.22 0.23 0.37 1 0.36 0.3 0.34

15 Infrastructure 7.97% 6.94% 8.45% 7.30% 14.58% 0.53 0.5 0.56 0.51 0.25 0.25 0.53 0.28 0.45 -0.02 0.2 0.4 0.49 0.36 1 0.51 0.44

16 Private Equity 5.0% 11.42% 9.08% 12.54% 9.87% 21.99% 0.73 0.71 0.67 0.59 0.04 0.04 0.51 0.07 0.36 -0.06 0.01 0.46 0.6 0.3 0.51 1 0.56

17 Private Debt 7.5% 8.50% 7.75% 8.63% 7.85% 12.06% 0.57 0.57 0.53 0.52 0.11 0.1 0.73 0.01 0.4 -0.09 0.08 0.39 0.52 0.34 0.44 0.56 1

Inflation 1.98% 1.97% 2.17% 2.16% 1.70%

Total Portfolio 100% 7.36% 6.53% 8.18% 7.34% 12.91%

10 year 20 year

IBT730-0093
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03d 

Liability Gain / Loss Analysis (Checklist Item #25) 

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

BOY Accrued Liability $ 211,257,893 $ 226,995,188 $ 254,433,372 $ 257,767,995 $ 261,866,516 $ 265,418,883 $ 269,676,223 $ 272,099,196 $ 274,037,389 $ 275,242,089

EOY Accrued Liability 226,995,188 254,433,372 257,767,995 261,866,516 265,418,883 269,676,223 272,099,196 274,037,389 275,242,089 290,601,829

Liability Increase (Decrease) $ 15,737,295 $ 27,438,184 $ 3,334,623 $ 4,098,521 $ 3,552,367 $ 4,257,340 $ 2,422,973 $ 1,938,193 $ 1,204,700 $ 15,359,740

Change Due due to:

Plan Amendment $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0 $ 0

Assumption Change 15,004,427 0 0 0 0 0 0 0 14,691,479 0 Accrual of Benefits 6,159,099 6,178,721 2,321,401 1,349,119 1,265,527 1,332,847 1,304,648 1,178,147 1,163,200 1,091,725

Passage of Time (Interest less benefits paid) 4,269,211 2,188,795 2,658,644 2,622,973 2,840,946 3,012,950 3,639,984 2,696,613 1,863,898 731,956

Other Sources 0 0 0 0 0 0 0 0 0 0

Actuarial Liability (Gain) / Loss 5,308,985 4,066,241 (1,645,422) 126,429 (554,106) (88,457) (2,521,659) (1,936,567) (1,822,398) (1,155,420)

Total Change $ 15,737,295 $ 27,438,184 $ 3,334,623 $ 4,098,521 $ 3,552,367 $ 4,257,340 $ 2,422,973 $ 1,938,193 $ 1,204,700 $ 15,359,740

(Gain)/Loss as a percent of

EOY Accrued Liability 2.34% 1.60% -0.64% 0.05% -0.21% -0.03% -0.93% -0.71% -0.66% -0.40%

Accrued Liability Gain/Loss Analysis

IBT730-0094
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03e 

Distribution of Optional Forms (Checklist Item #25) 

Percentage

Form Total Electing

Life Only 30 13%

5-Year Certain and Life 2 1%

10-Year Certain and Life 9 4%

50% Joint and Survivor 20 9%

67% Joint and Survivor 8 3%

75% Joint and Survivor 14 6%

Level Income Option 150 64%

Total 233 100%

IBT730-0095
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03f 

Retirement Rates by Age (Checklist Item #25) 

Retirement Terminated Terminated

Eligible Vesteds Vesteds

Terminated Count Percentage

Age Vesteds Retiring Retiring

60 262 118 45%

61 53 12 23%

62 36 7 19%

63 23 6 26%

64 16 2 13%

65 16 3 19%

66 13 1 8%

67 11 1 9%

68 11 1 9%

69 8 2 25%

70+ 36 2 6%

Terminated Vesteds Eligible at age 60

Retirement Rates

IBT730-0096
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03f 

Retirement Rates by Age (Checklist Item #25) 

Retirement Actives Actives

Eligible Count Percentage

60 58 12 21%

61 28 3 11%

62 23 3 13%

63 18 3 17%

64 15 3 20%

65 10 2 20%

66 6 3 50%

67 3 0 0%

68 2 0 0%

69 1 0 0%

70+ 0 0

Actives Retirement Rates Less than 30 years of 

Service

IBT730-0097
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03f 

Retirement Rates by Age (Checklist Item #25) 

 

Actives Retirement Rates 30 years of service

Retirement Actives Actives

Eligible Count Percentage

Age Actives Retiring Retiring

48 2 1 50%

49 6 3 50%

50 10 1 10%

51 10 1 10%

52 5 2 40%

53 8 4 50%

54 9 2 22%

55 9 3 33%

56 11 4 36%

57 7 5 71%

58 3 1 33%

59 3 2 67%

60 2 1 50%

61 0 0

62 2 1 50%

63 1 0 0%

64 0 0

65 0 0

66 1 0 0%

67 1 0 0%

68 0 0

69 0 0

70+ 0 0

Retirement Actives Actives

Eligible Count Percentage

Age Actives Retiring Retiring

48 0 0

49 1 0 0%

50 1 0 0%

51 3 0 0%

52 6 0 0%

53 5 3 60%

54 3 0 0%

55 7 0 0%

56 8 0 0%

57 9 3 33%

58 5 1 20%

59 3 1 33%

60 2 1 50%

61 4 1 25%

62 3 0 0%

63 3 0 0%

64 4 3 75%

65 0 0

66 0 0

67 0 0

68 1 0 0%

69 1 0 0%

70+ 1 1 100%

Actives Retirement Rates over 30 years of 

service

IBT730-0098
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.03g 

 Employers that Contributed 5% or More (Checklist Item #25) 

Contribution Total Contribution Total

Employer Name CBUs Rate Contributions Employer Name CBUs Rate Contributions

2009 2014

Giant of Maryland LLC 1,341,015 3.48 4,666,733 Giant Food LLC 521,496 5.43 2,831,725 McKesson Drug Corporation 149,790 3.48 521,268 Eight O'Clock Coffee 125,096 3.33 416,569 Eight O'Clock Coffee 126,066 3.48 438,710 Giant Food LLC 37,753 4.99 188,388 2010 2015

Giant of Maryland LLC 1,175,504 4.49 5,278,013 Giant Food LLC 494,569 5.70 2,819,043 McKesson Drug Corporation 205,166 2.66 545,742 Eight O'Clock Coffee 127,028 3.49 443,328 Eight O'Clock Coffee 192,672 2.75 529,849 Giant Food LLC 40,815 5.23 213,462 2011 2016

Giant Food LLC 769,304 4.51 3,469,560 Giant Food LLC 452,965 5.98 2,708,731 Jessup Logistics 327,706 4.71 1,543,495 Eight O'Clock Coffee 128,377 3.66 469,860 McKesson Drug Corporation 251,424 2.79 701,473 Giant Food LLC 78,102 5.49 428,778 Eight O'Clock Coffee 199,127 2.88 573,486 2017

2012 Giant Food LLC 525,049 5.76 3,024,280 Giant Food LLC 594,133 4.51 2,679,542 Eight O'Clock Coffee 110,491 3.84 424,287 Jessup Logistics 180,929 4.71 852,174 McKesson Drug Corporation 103,057 2.79 287,528 2018

Eight O'Clock Coffee 176,689 2.88 508,864 Giant Food LLC 491,230 6.58 3,232,296 Eight O'Clock Coffee 67,367 5.76 388,034 2013

Giant Food LLC 480,198 5.71 2,741,928 2019

Eight O'Clock Coffee 149,897 3.17 475,175 Giant Food LLC 463,499 7.24 3,355,730 Giant Food LLC 39,730 4.76 189,117 Eight O'Clock Coffee 106,375 4.23 449,968 

IBT730-0099
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.05(1) 

Sensitivity to Return on Market Value: Assumed Rate of Return Reduced by 1 Percentage Point (Checklist Item #27) Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 4,268,706 $ 663,674 $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 $ 21,401,972 - $ 5.53% 8,463,574 $ $ 152,835,948 $ 174,237,920 8.14 290,501,153 56%

2022 152,835,948 4,477,160 663,674 390,000 13,594,190 1,574,102 1,237,371 - 16,405,664 5.53% 8,133,908 149,315,026 165,720,690 10.10 214,666,426 71%

2023 149,315,026 4,696,712 663,674 397,800 13,151,957 2,091,952 1,574,545 16,818,464 9 5.53% 7,933,717 145,392,865 162,211,329 9.64 213,963,725 70%

2024 145,392,865 4,927,361 663,674 405,756 12,707,118 2,710,626 1,792,158 17,210,297 395 5.53% 7,712,208 141,080,055 158,290,352 9.20 212,781,934 68%

2025 141,080,055 5,168,712 663,674 413,871 12,173,243 3,379,238 2,026,285 17,580,213 1,447 5.53% 7,469,981 136,388,338 153,968,551 8.76 211,143,650 67%

2026 136,388,338 5,421,705 663,674 422,149 11,647,408 4,043,020 2,326,095 18,023,647 7,124 5.53% 7,205,108 131,233,029 149,256,676 8.28 209,021,665 65%

2027 131,233,029 5,686,341 663,674 430,592 10,965,401 4,677,468 2,677,266 18,335,597 15,463 5.53% 6,918,499 125,735,354 144,070,951 7.86 206,278,685 64%

2028 125,735,354 5,809,214 663,674 439,203 10,402,698 5,199,508 2,915,445 18,542,123 24,473 5.53% 6,611,960 119,838,876 138,380,999 7.46 202,982,683 62%

2029 119,838,876 5,927,091 663,674 447,987 9,699,636 5,723,110 3,150,127 18,606,828 33,955 5.53% 6,287,096 113,661,921 132,268,750 7.11 199,249,000 60%

2030 113,661,921 6,045,524 663,674 456,947 9,224,416 6,136,135 3,338,586 18,744,260 45,122 5.53% 5,944,748 107,114,660 125,858,920 6.71 195,186,820 58%

2031 107,114,660 6,164,415 663,674 466,086 8,838,398 6,379,005 3,516,334 18,791,153 57,415 6.34% 6,403,120 101,088,631 119,879,783 6.38 190,678,524 56%

2032 101,088,631 6,287,877 663,674 475,408 8,454,789 6,544,745 3,608,388 18,683,988 76,066 6.34% 6,027,977 94,908,763 113,592,751 6.08 185,788,166 54%

2033 94,908,763 6,287,877 165,919 484,916 8,065,555 6,615,355 3,657,373 18,436,100 97,817 6.34% 5,628,078 88,069,621 106,505,721 5.78 180,658,547 53%

2034 88,069,621 6,287,877 - 494,614 7,672,183 6,609,829 3,798,895 124,285 18,205,192 6.34% 5,196,202 80,853,894 99,059,086 5.44 175,439,081 50%

2035 80,853,894 6,287,877 - 504,507 7,276,136 6,584,778 3,837,835 153,154 17,851,903 6.34% 4,749,443 73,534,804 91,386,708 5.12 170,078,230 48%

2036 73,534,804 6,287,877 - 514,597 6,878,769 6,443,229 3,968,290 186,844 17,477,132 6.34% 4,296,796 66,127,748 83,604,881 4.78 164,723,737 45%

2037 66,127,748 6,287,877 - 524,889 6,481,356 6,280,847 4,055,380 230,400 17,047,983 6.34% 3,840,262 58,683,016 75,730,999 4.44 159,355,966 41%

2038 58,683,016 6,287,877 - 535,386 6,085,135 6,120,063 4,069,262 276,982 16,551,442 6.34% 3,383,437 51,267,502 67,818,944 4.10 154,038,018 38%

2039 51,267,502 6,287,877 - 546,094 5,691,316 5,955,077 4,112,736 326,323 16,085,452 6.34% 2,927,504 43,851,337 59,936,789 3.73 148,875,471 34%

2040 43,851,337 6,287,877 - 557,016 5,301,107 5,785,252 4,183,239 378,834 15,648,432 6.34% 2,470,619 36,404,385 52,052,817 3.33 143,840,993 30%

2041 36,404,385 6,287,877 - 568,156 4,915,754 5,618,250 4,257,544 433,987 15,225,535 6.34% 2,011,334 28,909,906 44,135,440 2.90 138,891,053 26%

2042 28,909,906 6,287,877 - 579,519 4,536,567 5,445,291 4,208,814 494,367 14,685,039 6.34% 1,552,700 21,485,925 36,170,963 2.46 134,015,280 22%

2043 21,485,925 6,287,877 - 591,110 4,164,944 5,278,082 4,223,682 552,329 14,219,038 6.34% 1,096,203 14,059,857 28,278,895 1.99 129,380,105 17%

2044 14,059,857 6,287,877 - 602,932 3,802,383 5,109,052 4,219,409 615,426 13,746,270 6.34% 639,778 6,638,310 20,384,580 1.48 124,906,728 11%

2045 6,638,310 6,287,877 - 614,991 3,450,495 4,919,705 4,334,536 675,864 13,380,601 6.34% 180,289 - 12,491,485 0.93 120,601,572 6%

Benefit Payments

IBT730-0100
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.05(2) 

Sensitivity to Return on Market Value: Assumed Rate of Return Reduced by 2 Percentage Points (Checklist Item #27) Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 4,268,706 $ 663,674 $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 $ 21,401,972 - $ 4.53% 6,932,168 $ $ 151,304,541 $ 172,706,513 8.07 290,501,153 56%

2022 151,304,541 4,477,160 663,674 390,000 13,594,190 1,574,102 1,237,371 - 16,405,664 4.53% 6,593,038 146,242,749 162,648,413 9.91 214,666,426 70%

2023 146,242,749 4,696,712 663,674 397,800 13,151,957 2,091,952 1,574,545 16,818,464 9 4.53% 6,359,235 140,746,107 157,564,570 9.37 213,963,725 68%

2024 140,746,107 4,927,361 663,674 405,756 12,707,118 2,710,626 1,792,158 17,210,297 395 4.53% 6,106,449 134,827,537 152,037,835 8.83 212,781,934 66%

2025 134,827,537 5,168,712 663,674 413,871 12,173,243 3,379,238 2,026,285 17,580,213 1,447 4.53% 5,835,276 128,501,115 146,081,328 8.31 211,143,650 64%

2026 128,501,115 5,421,705 663,674 422,149 11,647,408 4,043,020 2,326,095 18,023,647 7,124 4.53% 5,544,238 121,684,936 139,708,584 7.75 209,021,665 61%

2027 121,684,936 5,686,341 663,674 430,592 10,965,401 4,677,468 2,677,266 18,335,597 15,463 4.53% 5,234,216 114,502,978 132,838,576 7.24 206,278,685 59%

2028 114,502,978 5,809,214 663,674 439,203 10,402,698 5,199,508 2,915,445 18,542,123 24,473 4.53% 4,906,807 106,901,347 125,443,470 6.77 202,982,683 56%

2029 106,901,347 5,927,091 663,674 447,987 9,699,636 5,723,110 3,150,127 18,606,828 33,955 4.53% 4,563,447 99,000,743 117,607,571 6.32 199,249,000 54%

2030 99,000,743 6,045,524 663,674 456,947 9,224,416 6,136,135 3,338,586 18,744,260 45,122 4.53% 4,204,923 90,713,657 109,457,918 5.84 195,186,820 51%

2031 90,713,657 6,164,415 663,674 466,086 8,838,398 6,379,005 3,516,334 18,791,153 57,415 5.34% 4,516,567 82,801,075 101,592,228 5.41 190,678,524 48%

2032 82,801,075 6,287,877 663,674 475,408 8,454,789 6,544,745 3,608,388 18,683,988 76,066 5.34% 4,099,867 74,693,097 93,377,085 5.00 185,788,166 45%

2033 74,693,097 6,287,877 165,919 484,916 8,065,555 6,615,355 3,657,373 18,436,100 97,817 5.34% 3,660,066 65,885,943 84,322,043 4.57 180,658,547 41%

2034 65,885,943 6,287,877 - 494,614 7,672,183 6,609,829 3,798,895 124,285 18,205,192 5.34% 3,191,221 56,665,234 74,870,427 4.11 175,439,081 38%

2035 56,665,234 6,287,877 - 504,507 7,276,136 6,584,778 3,837,835 153,154 17,851,903 5.34% 2,707,884 47,304,586 65,156,489 3.65 170,078,230 33%

2036 47,304,586 6,287,877 - 514,597 6,878,769 6,443,229 3,968,290 186,844 17,477,132 5.34% 2,217,636 37,818,370 55,295,503 3.16 164,723,737 29%

2037 37,818,370 6,287,877 - 524,889 6,481,356 6,280,847 4,055,380 230,400 17,047,983 5.34% 1,722,110 28,255,486 45,303,469 2.66 159,355,966 24%

2038 28,255,486 6,287,877 - 535,386 6,085,135 6,120,063 4,069,262 276,982 16,551,442 5.34% 1,224,261 18,680,796 35,232,238 2.13 154,038,018 18%

2039 18,680,796 6,287,877 - 546,094 5,691,316 5,955,077 4,112,736 326,323 16,085,452 5.34% 724,970 9,062,097 25,147,549 1.56 148,875,471 13%

2040 9,062,097 6,287,877 - 557,016 5,301,107 5,785,252 4,183,239 378,834 15,648,432 5.34% 222,561 - 15,015,519 0.96 143,840,993 6%

Benefit Payments

IBT730-0101
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.05(3) 

Sensitivity to Future CBUs: Assume CBUs decrease 11% per year (Checklist Item #27) Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 3,799,149 $ 663,674 $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 $ 21,401,972 - $ 6.53% 9,980,287 $ $ 153,883,103 $ 175,285,075 8.19 290,501,153 56%

2022 153,883,103 3,546,359 663,674 390,000 13,594,190 1,574,102 1,237,371 - 16,405,664 6.53% 9,644,144 150,941,615 167,347,279 10.20 214,666,426 72%

2023 150,941,615 3,311,036 663,674 397,800 13,151,957 2,091,952 1,574,545 16,818,464 9 6.53% 9,430,987 147,131,049 163,949,513 9.75 213,931,468 71%

2024 147,131,049 3,091,537 663,674 405,756 12,707,118 2,710,626 1,792,158 17,210,297 395 6.53% 9,162,257 142,432,464 159,642,761 9.28 212,596,290 69%

2025 142,432,464 2,886,239 663,674 413,871 12,173,243 3,379,238 2,026,285 17,580,213 1,447 6.53% 8,836,695 136,824,989 154,405,202 8.78 210,658,241 68%

2026 136,824,989 2,694,486 663,674 422,149 11,647,408 4,043,020 2,326,095 18,023,647 7,124 6.53% 8,449,850 130,187,203 148,210,850 8.22 208,090,168 66%

2027 130,187,203 2,515,144 663,674 430,592 10,965,401 4,677,468 2,677,266 18,335,597 15,463 6.53% 8,000,344 122,600,177 140,935,774 7.69 204,771,140 64%

2028 122,600,177 2,286,849 663,674 439,203 10,402,698 5,199,508 2,915,445 18,542,123 24,473 6.53% 7,490,662 114,060,035 132,602,159 7.15 200,799,051 61%

2029 114,060,035 2,076,594 663,674 447,987 9,699,636 5,723,110 3,150,127 18,606,828 33,955 6.53% 6,923,873 104,669,361 123,276,190 6.63 196,277,704 58%

2030 104,669,361 1,885,098 663,674 456,947 9,224,416 6,136,135 3,338,586 18,744,260 45,122 6.53% 6,299,805 94,316,731 113,060,991 6.03 191,326,046 55%

2031 94,316,731 1,710,732 663,674 466,086 8,838,398 6,379,005 3,516,334 18,791,153 57,415 7.34% 6,314,219 83,748,117 102,539,270 5.46 185,860,833 51%

2032 83,748,117 1,553,045 663,674 475,408 8,454,789 6,544,745 3,608,388 18,683,988 76,066 7.34% 5,536,325 72,341,765 91,025,754 4.87 179,967,423 47%

2033 72,341,765 1,382,210 165,919 484,916 8,065,555 6,615,355 3,657,373 18,436,100 97,817 7.34% 4,683,590 59,652,468 78,088,568 4.24 173,791,560 42%

2034 59,652,468 1,230,167 - 494,614 7,672,183 6,609,829 3,798,895 124,285 18,205,192 7.34% 3,748,707 45,931,536 64,136,729 3.52 167,469,966 36%

2035 45,931,536 1,094,849 - 504,507 7,276,136 6,584,778 3,837,835 153,154 17,851,903 7.34% 2,749,092 31,419,067 49,270,971 2.76 160,975,595 29%

2036 31,419,067 974,415 - 514,597 6,878,769 6,443,229 3,968,290 186,844 17,477,132 7.34% 1,692,682 16,094,436 33,571,568 1.92 154,430,352 20%

2037 16,094,436 867,230 - 524,889 6,481,356 6,280,847 4,055,380 230,400 17,047,983 7.34% 579,090 - 17,015,867 1.00 147,849,105 11%

Benefit Payments

IBT730-0102
Application for Approval of Benefit Suspension for 

Warehouse Employees Union Local No. 730 Pension Trust 

EIN/PN: 52-6124754 / 001 

Exhibit 6.05(4) 

Sensitivity to Future CBUs: Assume CBUs decrease 12% per year (Checklist Item #27) Withdrawal Terminated Future Total Liability Administrative Retirees and Vested New Benefit Investment Investment Available Solvency Funded Year BoY Assets Contributions Payments Expenses Beneficiaries Participants Actives Entrants Payments Rate Return EoY Assets Resources Ratio PVAB Percentage

2021 161,493,965 $ $ 3,756,462 $ 663,674 $ 652,000 $ 18,711,341 $ 1,500,509 $ 1,190,122 $ 21,401,972 - $ 6.53% 9,978,915 $ $ 153,839,044 $ 175,241,016 8.19 290,501,153 56%

2022 153,839,044 3,467,113 663,674 390,000 13,594,190 1,574,102 1,237,371 - 16,405,664 6.53% 9,638,720 150,812,887 167,218,551 10.19 214,666,426 72%

2023 150,812,887 3,200,678 663,674 397,800 13,151,957 2,091,952 1,574,545 16,818,464 9 6.53% 9,419,035 146,880,010 163,698,474 9.73 213,918,861 71%

2024 146,880,010 2,954,916 663,674 405,756 12,707,118 2,710,626 1,792,158 17,210,297 395 6.53% 9,141,474 142,024,021 159,234,318 9.25 212,559,666 69%

2025 142,024,021 2,727,694 663,674 413,871 12,173,243 3,379,238 2,026,285 17,580,213 1,447 6.53% 8,804,929 136,226,235 153,806,447 8.75 210,587,159 67%

2026 136,226,235 2,517,862 663,674 422,149 11,647,408 4,043,020 2,326,095 18,023,647 7,124 6.53% 8,405,076 129,367,051 147,390,698 8.18 207,976,358 66%

2027 129,367,051 2,323,869 663,674 430,592 10,965,401 4,677,468 2,677,266 18,335,597 15,463 6.53% 7,940,642 121,529,047 139,864,644 7.63 204,609,121 63%

2028 121,529,047 2,089,194 663,674 439,203 10,402,698 5,199,508 2,915,445 18,542,123 24,473 6.53% 7,414,366 112,714,954 131,257,077 7.08 200,586,641 61%

2029 112,714,954 1,875,796 663,674 447,987 9,699,636 5,723,110 3,150,127 18,606,828 33,955 6.53% 6,829,587 103,029,195 121,636,024 6.54 196,013,606 58%

2030 103,029,195 1,683,684 663,674 456,947 9,224,416 6,136,135 3,338,586 18,744,260 45,122 6.53% 6,186,230 92,361,576 111,105,836 5.93 191,012,675 54%

2031 92,361,576 1,510,780 663,674 466,086 8,838,398 6,379,005 3,516,334 18,791,153 57,415 7.34% 6,163,502 81,442,294 100,233,446 5.33 185,503,255 50%

2032 81,442,294 1,356,114 663,674 475,408 8,454,789 6,544,745 3,608,388 18,683,988 76,066 7.34% 5,359,978 69,662,664 88,346,652 4.73 179,570,924 45%

2033 69,662,664 1,193,380 165,919 484,916 8,065,555 6,615,355 3,657,373 18,436,100 97,817 7.34% 4,480,136 56,581,083 75,017,183 4.07 173,359,948 40%

2034 56,581,083 1,050,175 - 494,614 7,672,183 6,609,829 3,798,895 124,285 18,205,192 7.34% 3,516,779 42,448,230 60,653,422 3.33 167,004,800 34%

2035 42,448,230 924,154 - 504,507 7,276,136 6,584,778 3,837,835 153,154 17,851,903 7.34% 2,487,264 27,503,237 45,355,141 2.54 160,476,660 26%

2036 27,503,237 813,255 - 514,597 6,878,769 6,443,229 3,968,290 186,844 17,477,132 7.34% 1,399,450 11,724,214 29,201,346 1.67 153,896,108 18%

2037 11,724,214 715,665 - 524,889 6,481,356 6,280,847 4,055,380 230,400 17,047,983 7.34% 252,852 - 12,167,841 0.71 147,277,370 8%

Benefit Payments

IBT730-0103