DEPARTMENT OF THE TREASURY 

WASHINGTON, D.C.

August 3, 2018

Mr. Michael Parmelee

Ms. Suzanne Mode

Board of Trustees for the Western States 

Office and Professional Employees Pension Fund

PMB 116, 5331 SW Macadam Ave, Suite 258

Portland, OR 97239

Re: Western States Office and Professional Employees Pension Fund (Fund) 

Application for Reduction of Benefits

Dear Mr. Parmelee and Ms. Mode:

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

(Treasury) on May 15, 2018, to reduce benefits pursuant to the Multiemployer Pension Reform 

Act of 2014 (MPRA) has been reviewed to determine whether it satisfies the requirements 

established by Congress under MPRA. In consultation with the Secretary of Labor (DOL) and 

the Pension Benefit Guaranty Corporation (PBGC), Treasury has determined that the Plan is 

eligible to reduce benefits under MPRA and that your application satisfies the requirements of 

subparagraphs (C), (D), (E), and (F) of section 432(e)(9) of the Internal Revenue Code (Code), 

as added by MPRA.

This notification is not a final authorization to implement the benefit reduction described in your 

application. Pursuant to Code section 432(e)(9)(H), no reduction of benefits can take effect 

before a vote of the participants and beneficiaries of the Plan with respect to the proposed 

reduction. MPRA requires Treasury, in consultation with DOL and PBGC, to administer this 

vote. Accordingly, Treasury, in consultation with DOL and PBGC, will administer a vote of the 

participants and beneficiaries of the Plan.

Pursuant to the regulations under MPRA, the Trustees must submit the following to Treasury or 

its designated vendor no later than August 10, 2018:

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

MPRA, including all Plan participants (active participants, deferred vested participants, 

and retirees) and beneficiaries of deceased participants;

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

Treasury to verify the identity of each eligible voter;
Board of Trustees 

Western States Office and Professional Employees Pension Fund 

August 3, 2018

Page 2

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

identified through reasonable efforts);

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

electronically; and

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

participant and beneficiary in the Plan.

1

The Trustees are responsible for making reasonable efforts to identify the mailing addresses for 

those eligible voters whose ballot packages are returned as undeliverable (upon notice of such 

returns by Treasury).2 Please review the regulations under MPRA for further details regarding 

these requirements. If you fail to satisfy the applicable requirements, it may not be possible 

to timely administer, and certify the results of, the vote. In that case, it may not be possible 

to issue a final authorization permitting implementation of the proposed reduction.3

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

Sincerely,

Sam J. Alberts

Special Master

cc: Joseph Reinhart

Paul Graf

 

 1 Treas. Reg. § 1.432(e)(9)-1(h)(2)(iii)(B)(2). 2 Treas. Reg. § 1.432(e)(9)-1(h)(2)(iii)(B)(3). 3 See Treas. Reg. § 1.432(e)(9)-1(a)(4)(iii)(D). (The effective date of a benefit reduction may not precede the date 

on which a final authorization to reduce benefits is issued.)