CARPENTERS PENSION TRUST FUND – DETROIT & VICINITY 

SECOND APPLICATION FOR APPROVAL OF SUSPENSION OF BENEFITS UNDER THE 

MULTIEMPLOYER PENSION REFORM ACT OF 2014 

CHECKLIST 

Response Item 

number 

Description of item Page number 

in 

application 

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. 

Cover Letter 

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. 

CPTF 

000001 

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. 

CPTF 

000042 

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. 

CPTF 

000042 

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. 

CPTF 

000043 

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. 

CPTF 

000049 

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. 

CPTF 

000046 
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. 

CPTF 

000097 

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. 

CPTF 

000049 

Yes 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 representativeunder 

§ 432I(9)(B)(v)(I).) See section 4.02(2) of this revenue procedure. 

CPTF 

000119 

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. 

CPTF 

000125 

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€(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€(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. 

CPTF 

000132 

Yes 13. Does the application include a copy of the notices (excluding personally 

identifiable information) that meet the requirements under § 432€(9)(F)? See 

section 4.05(1) of this revenue procedure. 

CPTF 

000148 

000155 

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. 

CPTF 

000023 
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. 

CPTF 

000023 

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. 

CPTF 

000195 

Yes 17. Does the application include information on past and current measures taken to 

avoid insolvency? See section 5.01 of this revenue procedure. CPTF 

000289 

Yes 18. Does the application include information regarding the plan factors described in § 

432©(9)©(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. 

CPTF 

000272 

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. 

CPTF 

000010 

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 activeparticipants 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. 

CPTF 

000010 

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. 

CPTF 

000010 

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. 

CPTF 

000215 

N/A 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. 

CPTF 

000024 

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 

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. 

CPTF 

000222 
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. 

CPTF 

000272 

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. 

CPTF 

000274 

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. 

CPTF 

000285 

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€(9)€, 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. 

CPTF 

000288 

N/A 30. Does the application indicate whether the plan is a plan described in 

§ 432€(9)(D)(vii) and, if it is, how that is reflected in the proposed benefit 

suspension? See section 6.08. 

CPTF 

000031 

Yes 31 Does the application include a narrative statement of the reasons the plan is in 

critical and declining status? 

See section 6.09. 

CPTF 

000289 

Yes 32. Does the application include the required plan sponsor identification and 

contact information? See section 7.01 of this revenue procedure. CPTF 

000031 

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

section 7.02 of this revenue procedure. CPTF 

000031 

Yes 34. Does the application include the required retiree representative information (if 

applicable)? See section 7.03 of this revenue procedure. CPTF 

000031 
Yes 35. Does the application include the required enrolled actuary information? See 

section 7.04 of this revenue procedure. CPTF 

000032 

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. 

CPTF 

000307 

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. 

CPTF 

000308 

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. 

CPTF 

000449 

Yes 39. Does the application include the required excerpts from the most recently filed 

Form 5500? See section 7.08 of this revenue procedure. CPTF 

000742 

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

section 7.09 of this revenue procedure. CPTF 

000787 

Yes 41 Does the application include the two most recent actuarial valuation 

reports? See section 7.10 of this revenue procedure. CPTF 

000792 

Yes 42. Does the application include this checklist, completed and placed on top of the 

application? See section 7.11 of this revenue procedure and this 

Appendix D. 

0 

N/A 43. If the application is being submitted for resubmission review, does the 

application include: 

• cross-references to information in the prior application with 

respect to information that has not changed from the prior 

application, 

• a statement that the application is being submitted for 

resubmission review, and 

• the date on which the Treasury Department indicated that the 

application is a candidate for resubmission review? 

See section 8 of this revenue procedure. 

N/A 
MICHIGAN REGIONAL COUNCIL OF CARPENTERS 

FRINGE BENEFIT FUNDS 

P.O. Box 4540 • Troy, MI. 48099-4540 

Telephone: (248) 641-4950 800-572-2525 

To be submitted by: September 30, 2020 

Electronic Submission to: www.lreasurv .gov/mpra 

The Hon. Steven T. Mnuchin 

Secretary of the Treasury 

Department of the Treasury 

1500 Pennsylvania Avenue, NW 

Washington, DC 20220 

Re: Carpenters Pension Trust Fund - Detroit & Vicinity 

Application for Suspension of Benefits Under the Multiemployer 

Pension Reform Act of 2014 

Dear Secretary Mnuchin: 

The Board of Trustees of the Carpenters Pension Trust Fund - Detroit & Vicinity as the 

Plan Sponsor respectfully submits this application for approval of a proposed suspension of 

benefits pursuant to Internal Revenue Code Section 432(e)(9) and Section 305(e)(9) of the 

Employee Retirement Income Security Act of 1974. The Board hereby confirms that it has 

designated its Chairman, Mr. Tom Lutz and its Secretary, Mr. Robert Halik, as its Authorized 

Representative Trustees for the purpose of executing all documents necessary for the application. 

Signed: September~1o-20 

PMN/ldm.W:\FUNDS\mrcc\DB-PENS\MPRA\Covcr Letter to Application. on letterhead.doc 
CARPENTERS PENSION TRUST FUND – DETROIT & VICINITY

________________________________________________

SECOND APPLICATION FOR APPROVAL OF

SUSPENSION OF BENEFITS

UNDER THE

MULTIEMPLOYER PENSION REFORM ACT OF 2014

________________________________________________

SEPTEMBER 30, 2020

NOVARA, TESIJA & CATENACCI, PLLC

CPTF000001 CPTF - 
SECTION 1. BACKGROUND AND PROCEDURE

The Board of Trustees of the Carpenters Pension Trust Fund – Detroit & Vicinity (the 

“Plan”) submits this second application and the accompanying Exhibits to the Secretary of the 

Treasury for approval of a proposed suspension of benefits. The application is made pursuant to 

Internal Revenue Procedure 2017-43 (the “Revenue Procedure”) and the Department of the 

Treasury’s final regulations issued under §432(e)(9) of the Internal Revenue Code of 1986, as 

amended, (the “Code”) as published in the Federal Register on April 28, 2016 (the “Regulations”). 

Under §432(e)(9)(G) of the Code the Secretary of the Treasury shall approve an application 

for the suspension of benefits upon finding that the Plan is eligible and has satisfied the criteria of 

subparagraphs (C), (D), (E) and (F) of §432(e)(9) of the Code. As set out in detail below, the Plan 

is eligible to suspend benefits and has satisfied each of the criteria under the Code and the

Regulations. 

SECTION 2. APPLICATION PROCEDURES

2.01 Application submitted by plan sponsor.

This Application for Approval of Suspension of Benefits under the Multiemployer Pension 

Reform Act of 2014 (Application) is submitted by the Plan Sponsor, as defined at §432(j)(9) of 

the Code, as required under the Regulations. The Application is signed by the current Chairman 

and Secretary of the Board of Trustees of the Plan who are so authorized under the Plan’s 

agreement and declaration of trust and the letter of authorization executed by the full Board of 

Trustees for purposes of the Application. 

2.02 Term of the plan’s proposed suspension of benefits.

(1) Effective date.

The Trustees of the Plan propose that the suspension be effective (the “Effective Date”),

after the application has been approved and the result of the participant vote has been determined, 

on July 1, 2021.

(2) Expiration date.

The proposed suspension shall remain in effect indefinitely. It will not expire by its own 

terms. 

(3) The proposed suspension.

An explanation of the Plan’s historical benefit formula is required for the Plan’s proposed 

suspension design to be fully described.

Historical Benefit Formula

Generally, the accrued benefit for a participant who terminated Active Participant status 

prior to May 1, 2004 is determined from the following table:

CPTF000002 CPTF - 
Plan Year of 

Termination 

Starting May 1, Formula

<=1976 2.75% of contributions, but not less than $35 per month or more than $650 

per month*

1977-1978 2.75% of contributions, but not less than $35 per month or more than $800 

per month*

1979

2.75% of the first $15,000 of contributions plus 3% of contributions in 

excess of $15,000, but not less $35 per month or more than $900 per 

month*

1980-1983 2.6% of contributions*

1984 2.9% of contributions*

1985 3.2% of contributions*

1986 3.4% (3.2% for PYB < 1985) of contributions

1987-1988 3.6% (3.4% for PYB < 1985) of contributions

1989 3.7% (3.4% for PYB < 1985) of contributions

1990-1991 3.85% of contributions

1992-1996 3.9% of contributions

1997-2003 4.3% of contributions

* Not less than 3.5% of the first $4,300 of total contributions plus 1.5% of the remaining contributions if participant 

on 4/30/1969

A participant who terminated or terminates Active Participant status on or after May 1, 

2004 will have his or her benefit determined as follows:

• 4.3% of contributions made or required to be made prior 5/1/2004, plus

• 3% of credited contributions made or required to be made from and after 5/1/2004 but prior 

to 5/1/2007 (78% of contributions related to work performed from 5/1/2005 through 

4/30/2007 is credited), plus

• 1% of credited contributions made or required to be made from and after 5/1/2007 (between 

84% and 39% of contributions related to work performed during this period is credited).

Description of Proposed Suspension

The proposed benefit suspension shall be accomplished by recalculating all accrued 

benefits and, for benefits that are in pay status, recalculating such benefit from the revised accrued 

benefit.

The accrued benefit earned prior to 5/1/2007 will be reduced by 32%. Any accrued benefit 

earned under the 1% multiplier will be untouched. 

Retirees Who Entered Pay Status between 9/1/2008 and 7/31/2013

CPTF000003 CPTF - 
As an adjustable benefit cut implemented as part of the plan’s rehabilitation plan, the early 

retirement factors were changed effective August 1, 2013 with application to any participant who 

retired on or after September 1, 2008. As a result, all participants who entered pay status between 

September 1, 2008 and July 31, 2013 had their benefit recalculated as if the new factors had been 

in place when they originally retired. However, the effect of the new early retirement formula was 

capped at a 5% reduction.

Post-suspension benefits for this group will be determined using the early retirement factor 

in effect when the participant initially retired. However, no benefit will be increased as a result of 

the suspension.

Disability-Based Limitation

The individual limitations will be applied as per statute. However, there are some special 

circumstances related to the application of the disability-based limitation. These are enumerated 

below:

• When the disability rules were changed in 2013, disabled retirees without a Social Security 

award were allowed one year to obtain such award. As a result of this change, some

previously disabled participants ceased to qualify under the plan rules. These participants

will not receive any special protection under the disability-based limitation.

• As the result of settlement of a class action lawsuit in October 2016, most disabled 

participants who were in pay status as of 8/1/2013 and had taken a cut due to the 2013 rule 

change, were restored to 95% of their pre-amendment disability benefit amount. After these 

participants retire, the disability-based limitation will be applied based on the 95% of preamendment disability amount.

• Also, as the result of the 2016 class action settlement, affected disabled participants who 

were:

o In pay status on 8/1/2013, and

o Converted to early retirement prior to October 2016, and

o Had an early retirement benefit that was less than 95% of their prior disability 

benefit,

were granted a benefit increase to 95% of their pre-amendment disability amounts payable 

until age 62, at which time their benefit will increase to an unreduced, early retirement

benefit. For purposes of the disability-based limitation, the benefit payable until normal 

retirement age for these participants will be treated as a disability benefit.

• In the case of separate interest alternate payees, the alternate payee will generally not

receive any portion of the disability-based limitation. The exception to this is in the case 

of an alternate payee who was assigned a portion of the participant’s disability benefit. In 

this case, such alternate payee will receive a disability-based limitation based on the portion 

of disability benefit assigned and the participant will not receive a disability-based 

limitation based on such portion.

CPTF000004 CPTF - 
• In the case of a shared interest alternate payee, any disability-based limitation will be 

shared in the same manner as the benefit itself.

• Surviving spouses and beneficiaries will not receive any disability-based limitation.

• A former disabled retiree who has converted to normal or early retirement will receive 

disability-based limitation protections based on the monthly disability benefit amount he 

or she was receiving immediately prior to conversion.

How the Proposed Suspension Affects Various Groups of Participants – Main Groups

Below is a listing of the various groups of participants that are treated differently under the 

suspension and a description of how each group is treated differently. The groups are designated 

by the letters A through D.

Group Description How Treated Differently

A Non-Retired

Non-retired participants will be subject to a 32% cut on pre5/1/2007 accruals. For active participants continuing to accrue 

benefits, the effect of any cut relative to the final accrued benefit at 

retirement will become less as time passes.

B

Retiree with 

8/1/2013 

Benefit 

Reduction

As described above, the benefits of the retirees in this group were 

reduced to reflect a new set of early retirement factors effective 

8/1/2013 (though the reduction was limited to 5% of the benefit in 

pay status immediately prior to 8/1/2013). This group is subject to 

a 32% cut on pre-5/1/2007 accruals, but the early retirement factor 

used for determining the post-suspension benefit in pay status will 

be the factor that was in effect when they initially retired. Thus, 

the reduction will be slightly less relative to the benefit in effect 

immediately prior to suspension when compared to a similarlysituated retiree who did not experience the 8/1/2013 benefit 

adjustment.

C

Beneficiary of 

October 2016 

Disability 

Lawsuit 

Settlement

This group is subject to a32% cut on pre-5/1/2007 accruals. 

However, as described above, the disability-based limitations are 

applied differently to this group as compared to a similarlysituated disabled or retired participant who was not a beneficiary 

of the lawsuit settlement.

D

Pay Status 

Participant Not 

In Groups B or 

C

This group is subject to a 32% cut on pre-5/1/2007 accruals, but 

does not receive the benefit of any of the special rules applicable to 

groups B and C.

CPTF000005 CPTF - 
How Suspension Affects Various Groups of Participants – Sub-groups

Because the proposed suspension does not affect any benefits accrued on or after May 1, 

2007 (those that accrued under the 1% multiplier), each of preceding groups must be sub-divided 

into 3 sub-groups: 

• Those with all accruals prior to May 1, 2007, 

• Those with all accruals on or after May 1, 2007, and 

• Those with accruals both before and after May 1, 2007. 

For simplicity, the 3 possible sub-groups are labeled 1, 2, and 3. The way in which each sub-group 

is treated differently is described below:

SubGroupDescription How Treated Differently

1

Pre-5/1/2007 

Accruals Only

The 32% reduction will apply to the entire accrued benefit

2

Post-5/1/2007 

Accruals Only

As there are no pre-5/1/2007 accruals, the accrued benefit will be 

unaffected by the suspension

3

Pre- And Post5/1/2007 

Accruals

The 32% reduction will only apply to the portion of the benefit 

accrued prior to 5/1/2007. Therefore, the overall reduction will be 

less than 32%.

Final Groups

Final groupings are referred to by starting with the letter representing the participant’s main 

group and appending the number representing the appropriate sub-group. For example, “A1,” 

“A2,” etc.

The final groupings are summarized below (note that a few of the final groups do not contain any 

participants):

Group Description

A1 Non-Retired, pre-5/1/2007 accruals only

A2 Non-Retired, post-5/1/2007 accruals only

A3 Non-Retired, pre- and post-5/1/2007 accruals

B1 Retiree with benefit reduction effective 8/1/2013, pre-5/1/2007 accruals only

B2 Retiree with benefit reduction effective 8/1/2013, post-5/1/2007 accruals only

B3 Retiree with benefit reduction effective 8/1/2013, pre- and post-5/1/2007 accruals

C1

Beneficiary of the October 2016 disability lawsuit settlement, pre-5/1/2007 accruals 

only

C2

Beneficiary of the October 2016 disability lawsuit settlement, post-5/1/2007 accruals 

only

CPTF000006 CPTF - 
C3

Beneficiary of the October 2016 disability lawsuit settlement, pre- and post-5/1/2007 

accruals

D1 Retiree not included in a C or D group, pre-5/1/2007 accruals only

D2 Retiree not included in a C or D group, post-5/1/2007 accruals only

D3 Retiree not included in a C or D group, pre- and post-5/1/2007 accruals

Note: In the table above, “retiree” includes beneficiaries and alternate payees. For above 

information and additional detail see, Application Exhibit 1.

2.03 Penalties of perjury statement. See, Application Exhibit 2.

2.04 Public disclosure statement. See, Application Exhibit 2.

SECTION 3. DEMONSTRATION THAT THE PLAN IS ELIGIBLE FOR SUSPENSION

3.01 Plan actuary’s certification of critical and declining status.

The Plan actuary’s required certification (issued July 29, 2020) is found at Application 

Exhibit 3 to the Application as required under Code §432(b)(3)(A). The Plan is certified as being 

in critical and declining status for the Plan Year beginning May 1, 2020. The certification is 

supported by the May 1, 2019 actuarial valuation report (issued March 9. 2020, and found at 

Application Exhibit 37) and the actuary’s supporting illustrations attached to the required 

certification which include a year-by-year projection of the Plan’s available resources and the 

benefits under the Plan demonstrating that the Plan is projected to become insolvent during the 

Plan Year ending April 30, 2032. The certification includes descriptions of the assumptions and 

methods applied, with reference to further detail in the May 1, 2019, actuarial valuation report. 

The year-by-year projection (Internal Exhibit I) separately identifies (items 1 and 7 respectively) 

the market value of assets as of the beginning and end of the Plan Years ending April 30, 2020, 

through April 30, 2032, and the following cash-flow items for those years: (2) employer 

contributions, (3) withdrawal liability payments, (4) benefit payments (further broken down by 

type at Internal Exhibit II), (5) expenses, and (6) investment income. Additionally, the supporting 

illustrations include projected total contribution base units and average contribution rates (Internal 

Exhibit III) for the period from Plan Year ending April 30, 2020, through April 30, 2032.

3.02 Plan actuary’s certification that the plan is projected to avoid insolvency.

Application Exhibit 4 is the Plan actuary’s certification that the Plan is projected to avoid 

insolvency. This certification includes the following supporting exhibits: Internal Exhibit I -

Value of Plan Assets at the Beginning and End of the “Initial Period”; Internal Exhibit II -

Deterministic Projection of Current Plan without Proposed Suspension; Internal Exhibit III –

Deterministic Projection with Proposed Suspension; Internal Exhibit IV – Breakdown of Benefit 

Payouts for Exhibit II; and Internal Exhibit V – Breakdown of Benefit Payments for Exhibit III.

The certification and supporting exhibits satisfy the requirements of Code §432(e)(9)(C)(i) by 

providing a year-by-year projection demonstrating that, with the proposed suspension taking effect 

on July 1, 2021, the Plan is projected to avoid insolvency within the meaning of Code §418E. The 

supporting exhibits also separately identify the available resources during each year and the market 

value of assets and changes in cash flow.

CPTF000007 CPTF - 
3.03 Plan sponsor’s determination of projected insolvency.

The Trustees of the Plan have made a prudent determination under Code §432(e)(9)(C)(ii), 

after consideration of all of the available information and all remaining possible Plan changes, that 

the Plan is projected to become insolvent unless benefits are suspended as proposed in the 

Application. The Trustees have determined this to be so even though they have taken all reasonable 

measures to avoid insolvency. The Trustees’ determination of projected insolvency includes 

consideration of all of the measures taken to avoid insolvency over the past 10 plan years, as 

discussed in Section 3.04 of this Application.

The funded status of the Plan had declined precipitously by plan year ending 2003, at which 

time, having experienced three consecutive years of negative returns, the Plan was 66% funded (in 

years 2002, 2001, and 2000 the Plan was 83%, 100% and 117% funded respectively). Faced with 

a deteriorating funded status and observing the growing “maturity” of the Plan’s participant 

population the Trustees took reasonable corrective actions available to them consistent with prePPA ERISA and the Code. Detail on the Trustees’ action is found in Section 3.04 of this 

Application, Consideration of Specific Plan Factors.

In addition to the pre-PPA actions available to them, once the Plan was determined by its 

actuary to be in critical status in the initial PPA status certification (2008 certification, funded 

percentage 55%) the Trustees adopted a Rehabilitation Plan as of September 27, 2008. From this 

point forward the Trustees made ample use of the additional tools available to them under the 

PPA to (a) reduce accruals of future benefits by reducing the monthly benefit multiplier, (b) further 

reduce future benefit accruals by “discounting” a portion of contributions so that the discounted 

portion was not benefit bearing, (c) imposing contribution schedules on the Plan’s contributing 

employers that included increases in hourly rates and also defining the discounted portion of those 

increases. While the non-benefit bearing portion of the contribution increases imposed under the 

Plan’s original and subsequently amended rehabilitation plans and August 1, 2013 all-reasonablemeasures (“ARM”) plan are variously referred to as “credited/non-credited” (rehabilitation plan), 

and “discounted contributions” (See, Application Exhibit 37 May 1, 2019, Actuarial Valuation 

Report, at p. A-3) the terminology is interchangeable. The history of the Plan’s imposition of 

uncredited contributions is summarized in the Sixth Amendment to the current Plan. See, 

Application Exhibit 25 as follows:

Contract

“Discount” by Time Period

6/1/06

to

5/30/07

6/1/07

to

5/30/08

6/1/08

to

5/30/09

6/1/09

to

5/30/10

6/1/10

to

5/30/11

6/1/11

to

5/30/12*

6/1/12

to

5/30/13

6/1/13

and 

Thereafter

Commercial 22% 16% 23% 37% 45% 52% 56.75% 61%

Display 22% 16% 23% 37% 45% 52% 56.75% 61%

Floorlayers 221⁄2% 16.5% 28% 42% 51% 56% 60.75% 61%

Millmen 22% 35% 45% 45% 50% 50% 55.00% 61%

Millwrights 23% 17% 231⁄2% 371⁄2% 46% 52% 57.50% 61%

Liberty 

Fabricating 23% 17% 231⁄2% 371⁄2% 46% 52% 57.50% 20%

Roadbuilders 23% 17% 231⁄2% 371⁄2% 46% 53% 57.75% 61%

All Others 22% 35% 45% 45% 50% 50% 55.00% 61%

Residential 22% 35% 45% 45% 50% 50% 55.00% 61%

CPTF000008 CPTF - 
Poured Wall 22% 35% 45% 45% 50% 50% 55.00% 61%

*No maximum non-credited contribution is in effect for benefits accrued on or after June 1, 2011. 

In addition to increasing contributions under rehabilitation and ARM plan schedules and 

limiting the amount of those increases that could be benefit bearing, the Trustees eliminated certain

“adjustable benefits” as defined under the PPA, consistent with the Plan’s rehabilitation and ARM

plans. Further discussion of actions taken to eliminate adjustable benefits is included in Section 

3.04(c) of this Application.

Like virtually all multiemployer plans, the Plan suffered a sharp decline in contribution 

hours following the market collapse of August 2008. Hours, which had exceeded 14 million per 

year in the early 2000’s, bottomed out at about 5.8 million in plan year ended 2010. The decline 

in hours was much more severe, and the recovery much slower, than Trustees had predicted. 

Please see table of historic of work hours below:

PYE 

4/30:

Work 

Hours

PYE 

4/30:

Work 

Hours

2020 7,212,686 2010 5,796,364

2019 7,795,753 2009 8,454,305

2018 8,332,526 2008 10,500,468

2017 7,478,853 2007 10,020,514

2016 7,446,260 2006 11,118,510

2015 6,965,968 2005 11,830,720

2014 6,386,096 2004 12,130,239

2013 6,689,107 2003 13,131,324

2012 7,131,329 2002 14,156,290

2011 6,572,509 2001 14,551,472

In the years following 2010, work hours started to increase (though not as quickly as then

forecast) and it was thought that this trend would continue into the future. Based on these 

projections of continued improvement, the actions taken as described here and in other parts of 

this Application were expected, at the time they were adopted, to provide a viable path forward 

avoiding insolvency and restoring Plan financial health. 

Beginning in 2017, the Trustees observed that many of the large construction projects that 

had been fueling the recovery were going to end with no source of replacement hours on the 

horizon. This situation, combined with state-level legislative changes (“right to work” and a repeal 

of the requirement for project labor agreements (“PLAs”) on state-funded projects), and a dramatic 

scale-back of the Detroit Auto Show, caused the Trustees to change their outlook. They now saw 

a temporary peak followed by a decline in hours to about 7 million per year. The actuary projected 

that this new level of hours (approximately half of the levels seen in the early 2000’s) would not 

be sufficient to support the Plan as currently in effect.

Notwithstanding the actions taken as described here and in other parts of this Application, 

the Plan’s funded status has continued to decline. As reported in the 2020 actuarial PPA status 

certification, the Plan’s 2020 PPA funded ratio is 33.4% with a projected year of insolvency of 

CPTF000009 CPTF - 
2032. It should be noted that the 33.4% funded ration is down from the 34.5% certified at the time 

the Plan filed its first application for approval of suspension of benefits last year.

The Trustees have now reasonably and prudently determined that notwithstanding their

past and possible future actions, the Plan cannot be projected to avoid insolvency if the proposed 

suspension of benefits is not approved and applied to the Plan.

3.04 Consideration of Specific Plan Factors.

(1) The determination that all reasonable measures have been taken to avoid insolvency 

includes the consideration of the Plan factors specified in Section 432(e)(9)(C)(ii)

for the 10 plan years immediately preceding 2020.

(a) Current and past contribution levels.

Beginning in 2006, the bargaining parties began making consistent contribution rate 

increases in an attempt to improve the Plan’s funding. These increases were typically noncredited/non-benefit bearing. During the period 2006-2014, the average hourly contribution rate 

increased from about $4 to over $15, and the percentage credited dropped from 100% to about 

39%. See, Application Exhibit 17 Pension Plan’s Ten-Year Experience for Certain Critical 

Assumptions, which documents the Plan’s contribution rates from plan year ending April 30, 2011

(average hourly rate $9.95) to April 30, 2020 (average hourly rate $15.12). 

As noted in Section 3.03 of this Application, the Trustees voted on August 1, 2013 to adopt 

the “all reasonable measures” option under the PPA. Since that time there have been no negotiated

contribution increases (though the average contribution rate does fluctuate based on the changing 

distribution of work among the various collective bargaining agreements). 

The Trustees and bargaining parties believe that the high contribution rate coupled with a

low accrual rate (see, subsection (b) immediately below) make it difficult to attract and retain 

quality workers and to add new contributing employers to the Plan. This is because the high 

contribution rates make it difficult for contractors to compete in the construction project bidding 

process. Therefore, the Trustees believe that future contribution rate increases would be 

detrimental to the Plan.

(b) Levels of benefit accruals including any prior reductions in the rate of benefit 

accruals. 

In 2004 the Plan’s monthly benefit multiplier was reduced from 4.3% to 3.0% of 

contributions. In 2007, the monthly benefit multiplier was reduced to 1%, although that figure 

itself is effectively reduced to 0.39% by virtue of the non-credited contribution rates shown in the 

table reproduced at Section 3.03 of this Application. 

(c) Prior reductions of adjustable benefits under Section 432(e)(8).

The benefit reductions in the Plan’s rehabilitation plan include substantially all permissible 

adjustable benefit reductions and all reasonable benefit reductions. In 2013 the Plan’s ARM plan 

raised the unreduced early retirement from index 85 to age 62, regardless of service. 

CPTF000010 CPTF - 
(d) Prior suspension of benefits under Section 432(e)(9).

This factor is not applicable as the Plan has not had a prior suspension of benefits under 

Section 432(e)(9).

(e) Measures taken to retain or attract contributing employers.

At present, any current or prospective contributing employer is faced with participation in 

a Plan that is projected to become insolvent, that imposes a substantial contribution rate, and for 

which new participants will accrue (functionally less than) a 1% future Plan benefit 

notwithstanding the past wage increases that were foregone by participants to generate 

contribution rate increases required by the various rehabilitation plans. Additionally, any 

prospective employer who commences participation in the Plan could face withdrawal liability 

(although the Plan is a construction industry plan for purposes of the construction industry 

exemption to employer withdrawal liability, which serves to substantially lessen the harshness of 

withdrawal liability as compared to non-construction industry plans). Under these circumstances 

the Trustees believe that any rational employer faces a difficult decision in determining whether 

to sign a CBA that requires contributions to the Plan. 

There are other factors that support signing or continuing to sign CBAs under which 

contributions are made to the Plan. Factors supporting continued Plan participation include the 

access to a highly skilled, safety trained workforce whose members enjoy valuable CBA-provided 

fringe benefits in addition to the Plan. As a result, the ability to provide employees the promise of 

contributions to (and continued accruals under) the Michigan Regional Council of Carpenters’ 

Annuity Fund, or for Millwrights, the Millwrights’ Local 1102 Supplemental Pension Fund, 

quality healthcare and access to post-retirement health benefits under the Michigan Regional 

Council of Carpenters Employee Benefits Fund as well as training (including journeyman 

upgrades) from the Michigan Statewide Carpenters and Millwrights Joint Apprenticeship and 

Training Fund still allow employers to offer attractive benefits to potential new employees and to 

retain skilled carpenters and related craft workers. 

While the financial position of the Plan, standing alone, makes it more difficult to attract 

new long term participating employers, consideration of other advantages conferred by using 

highly skilled workers who continue to be attracted by other CBA-required fringe benefits, the 

Plan continues to maintain a broad base of contributing employers (see, Application Exhibit 12

(list of contributing employers) and the contribution obligation is well-distributed (see, 

Application Exhibit 14)(description of actuarial assumptions). For example, since May 1, 2015 

no single employer has accounted for more than 5% of total plan contributions. Id.

It should also be noted that under current CBAs the Union and employers have agreed to 

market recovery provisions by which the employers (or associations of employers) and Union 

agree to more employer-friendly wage and fringe benefit packages when appropriate to permit 

contributing employers to effectively compete on specific projects. Market recovery rates are 

negotiated on a job-by-job or area-by-area basis. These market recovery initiatives provide 

appropriate flexibility and allow contributing employers to enhance their ability to compete with 

non-union competitors for targeted work, to the benefit of the Plan.

CPTF000011 CPTF - 
The Trustees of the Plan are committed to retaining and making appropriate efforts to 

expand the Plan’s contribution base. This commitment is demonstrated by their determination not 

to seek additional contribution rate increases from existing contributing employers, which could 

foreseeably lead to employer bankruptcies and possible uncollectible withdrawals, particularly 

with respect to display industry contractors (who are generally not beneficiaries of the construction 

industry exemption to employer withdrawal liability). The fact that there have been new employers

signatory to the CBAs since the Plan’s future benefit accrual rate was reduced to 1% and 

notwithstanding the contribution rate increases imposed by the Plan’s rehabilitation and ARM 

plans is objective evidence of the prudence of the Trustees’ approach to the issue. 

(2) The impact on plan solvency of the subsidies and ancillary benefits available to 

active participants.

As noted above, substantially all adjustable benefits have been eliminated under the 

rehabilitation and ARM plans. The Trustees have reasonably and prudently determined that 

elimination of additional benefits would make it impossible to maintain sufficient employee 

participation to staff upcoming work, which otherwise would lead to a further decline in 

contribution hours, hastening the Plan’s insolvency.

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

industry generally.

The 2019 median pay for Carpenters in the United States is $48,330 per year, reflecting an 

average hourly wage of $23.24 per hour. U.S. Bureau of Labor Statistics, Carpenters: Occupational 

Outlook Handbook, https://www.bls.gov/ooh/construction-and-extraction/print/carpenters.htm

The current wage rates for Carpenters ($32.70 per hour) and Millwrights ($31.50 per hour) 

compare favorably to the median. See, Application Exhibit 16.

(4) Competitive and other economic factors facing contributing employers.

(See, Application Exhibit 21, Narrative Statement). Significant contribution increases 

have been made by signatory employers since 2010. This has resulted in significant wage 

deferments by members. These contribution increases have increased the pressure on signatory 

contractors to remain competitive in the Detroit regional market, as they must bid against nonUnion employers who do not carry the same contribution burdens.

How Plan factors were taken into account/other factors considered

- The impact of benefit and contribution levels on retaining active participants and 

bargaining groups under the plan.

With reference to the description above, the Trustees observe that current active 

participants are making significant wage package allocations to the Plan but are accruing future 

pension benefits at a fraction of 1%. Any further increase in the contribution rate would likely 

result in employer withdrawals and a loss of bargaining unit members for whom Plan contributions 

will be required.

CPTF000012 CPTF - 
- The impact of past and anticipated contribution increases under the plan on 

employer attrition and retention levels.

With reference to the description above, there is no intention to increase the required 

contribution rate in the foreseeable future, as such an action is reasonably anticipated to have a 

significant detrimental impact on the Plan’s future funding. 

SECTION 4. DEMONSTRATION THAT THE PLAN’S PROPOSED SUSPENSION 

SATISFIES THE STATUTORY REQUIREMENTS

4.01 Demonstration that limitations on individual suspensions are satisfied.

Application Exhibit 6 contains sample calculations that demonstrate how the proposed 

suspension satisfies the limitations described in Code §432(e)(9)(D)(i), (ii) and (iii). Section 4.01 

of the Revenue Procedure requires information demonstrating that certain statutory limitations 

with respect to the proposed suspension are satisfied. The limitations set forth in Section 4.01 are 

satisfied based upon the following (summarized) individual demonstrations.

Guarantee-based Limitation

The proposed suspension does not reduce the benefit of any participant or beneficiary to 

an amount that is less than 110% of the PBGC guarantee. 

If a participant’s benefit has been split with an alternate payee under the terms of a qualified 

domestic relations order (QDRO), the determination of the guaranteed level for both parties is 

based on the terms of the QDRO. Generally, if the QDRO provides the alternate payee a shared 

interest with the participant, the participant’s total benefit is used for purposes of determining the 

guaranteed amount for both parties. If the QDRO provides a separate interest for the alternate 

payee, the alternate payee’s separate benefit level is used to determine the guaranteed amount. If 

there are multiple QDROs with multiple alternate payees, this determination is made separately 

with respect to each QDRO.

Age-Based Limitation

The proposed suspension does not affect any participant or beneficiary who will be age 80 

or older as of July 31, 2021 (the end of the month in which the July 1, 2021 effective date of the 

proposed suspension occurs). The proposed suspension only partially affects any participant or 

beneficiary who will be age 75-79 as of July 31, 2021 (with proportionally more of the current 

benefit being protected the closer the participant or beneficiary is to age 80). 

In the event that the age-based limitation applies to a participant that has a QDRO, then the 

type of QDRO will determine whether the Pension Plan uses the participant’s or alternate payee’s 

age. If the QDRO provides the alternate payee a shared interest with the participant, then the 

participant’s age is used for purposes of applying the age-based limitation as of the proposed 

suspension’s effective date. Alternatively, if the QDRO provides a separate interest for the 

alternate payee, then the alternate payee’s age is used to determine the application of the age-based 

limitation. If there are multiple QDROs with multiple alternate payees, the determination of whose 

age to use is determined separately for each applicable QDRO.

CPTF000013 CPTF - 
The application of the age-based limitation for a participant who elected a joint and 

survivor benefit is based on the age of the participant as of July 31, 2021, unless he or she is 

deceased, in which case the surviving spouse’s age is used to determine the application of the agebased limitation.

Section 4.01(3) of revenue procedure 2017-43 requires submission of sample calculations 

for each group defined in Checklist Item #2 that includes an individual who is over age 75 (as of 

July 31, 2021). Note that no calculations are included for groups that have a sub-group designation 

of “2” as these the individuals in these groups have only post-5/1/2007 accruals and will not be 

affected by the suspension.

Section 4.01(3)(c) of revenue procedure 2017-43 requests submission of sample 

calculations on individuals who are between age 75 and 79 but have not commenced benefits. 

However, all plan participants satisfying the preceding criteria are past their IRC section 401(a)(9) 

required beginning date and ARE treated as being in pay status retroactive to such date. Therefore, 

no such calculations are included for the “A” group.

The “B groups” and “C groups” do not contain anyone over the age of 75, so no calculations 

are included for these groups.

Based on the preceding, sample age-based limitation calculations are submitted on the 

following groups:

• D1

• D3

Disability-based Limitation

The proposed suspension does not affect any disability benefit that is in pay status as of 

July 1, 2021. Furthermore, if a disabled participant has converted to a retirement benefit on or 

prior to July 1, 2021, such participant’s benefit will not be reduced below the amount of the 

disability benefit he or she was receiving immediately prior to conversion.

There are currently 3 types of disability benefits paid to an individual under the Plan. 

1. Basic Disability Benefit – To be eligible for this benefit, the participant must be under age 

62, have at least 5 credit years, and have a disability award from the Social Security 

Administration (SSA). The benefit is paid in the form of a temporary life annuity generally 

ending at age 62. The benefit amount is equal to the greater of: (a) 75% of the vested 

accrued benefit, or (b) $280, but is subject to a cap pursuant to the following table:

Number of 

Credit 

Years

Cap on 

Disability 

Benefit

5-9 $525

10-15 $625

16-19 $725

CPTF000014 CPTF - 
Number of 

Credit 

Years

Cap on 

Disability 

Benefit

20-24 $1,050

25+ $1,350

1. Lump Sum Disability Benefit - If a participant is disabled with an SSA award but has less 

than 5 credit years (the plan uses 3-7 year graded vesting), then he or she is eligible for a 

lump sum cash-out equal to the actuarial present value of his or her vested accrued benefit.

2. Lawsuit-related Disability Benefit – As the result of the October 2016 class action lawsuit

settlement, the disability benefits of most disabled participants who were in pay status as 

of 8/1/2013 and had taken a cut due to the 2013 Plan amendment implementing the servicebased cap described above were restored to 95% of their pre-amendment disability benefit 

amount. After these participants retire, the disability-based limitation will be applied based 

on the 95% of pre-amendment disability amount.

The following special rules apply to the application of the disability-based limitation:

• When the Plan was amended in 2013 to require a disability award from the SSA, disabled 

retirees without such an award were allowed one year to obtain one. As a result of this 

change, some previously disabled participants ceased to qualify under the plan rules. These 

participants will not receive any special protection under the disability-based limitation.

• As the result of the 2016 class action settlement, affected disabled participants who were:

a. In pay status on 8/1/2013, and

b. Converted to early retirement prior to October 2016, and

c. Had an early retirement benefit that was less than 95% of their prior disability 

benefit,

were granted a benefit increase to 95% of their pre-amendment disability amounts payable 

until age 62, at which time their benefit will increase to an unreduced, early retirement 

benefit. For purposes of the disability-based limitation, the benefit payable until normal 

retirement age for these participants will be treated as a disability benefit.

If a participant’s benefit is split with an alternate payee under the terms of a QDRO, then 

the determination of the amount of the disability-based limitation for both parties is based on the 

terms of the QDRO. In the case of a separate interest QDRO, the alternate payee will generally not

receive any portion of the disability-based limitation. The exception is an alternate payee who was 

assigned a portion of the participant’s disability benefit, who will receive a disability-based 

limitation based on the portion of disability benefit assigned and the participant will not receive a 

disability-based limitation based on such portion.

In the case of a shared interest QDRO, any disability-based limitation will be shared in the 

same manner as the benefit itself.

Surviving spouses and beneficiaries will not receive any disability-based limitation.

CPTF000015 CPTF - 
Sample Calculations

The sample calculations required by Section 4.01 of the Revenue Procedure are found at 

Application Exhibit 6 (Internal Exhibits I – XVI). Note that:

• There are no ERISA 4022A(a) forfeitable benefits,

• There are no ERISA 4022A(b)(1)(A) benefit increases that have been in effect for less than 

60 months,

• The limitations contained in ERISA 4022A(c)(2) have been reflected in the guaranteebased calculations,

• There have been no ERISA 4022A(d) benefit reductions made pursuant to Code section 

411(a)(3)(E) (related to service with an employer rendered prior to such employer’s 

obligation to contribute to the plan where such employer subsequently ceases to have an 

obligation to contribute), and

• The ERISA 4022A(e) exclusion does not apply as the Secretary of the Treasury has not

determined that the plan fails to satisfy the requirements of Code sections 401(a) or 

404(a)(2).

A list of the required exhibits appears below:

Exhibit #

Relevant 

Section of Rev. 

Proc. 2017-43 Description

I 4.01(1) Guarantee-based limitation for an individual currently receiving 

benefits

II 4.01(1) Guarantee-based limitation for the contingent beneficiary of an 

individual currently receiving benefits

III 4.01(1) Guarantee-based limitation for a future retiree

IV 4.01(2)

Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability 

benefit)

V 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit)

VI 4.01(2) Disability-based limitation for a future retiree who is currently 

receiving a temporary annuity disability benefit

VII 4.01(2)

Disability-based limitation for an individual currently receiving 

retirement benefits (who previously received a disability benefit 

that was equal to 95% of his or her pre-8/1/2013 disability 

benefit due to the October 2016 settlement)

VIII 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual currently receiving retirement benefits (who 

previously received a disability benefit that was equal to 95% of 

his or her pre-8/1/2013 disability benefit due to the October 

2016 settlement)

CPTF000016 CPTF - 
IX 4.01(2)

Disability-based limitation for a future retiree who is currently 

receiving a disability benefit equal to 95% of his or her pre8/1/2013 disability benefit due to the October 2016 settlement

X 4.01(2)

Disability-based limitation for an individual who had previously 

received a retirement benefit that is treated like a disability

benefit due to the October 2016 settlement

XI 4.01(2)

Disability-based limitation for the contingent beneficiary of an 

individual who had previously received a retirement benefit that 

is treated like a disability benefit due to the October 2016 

settlement

XII 4.01(2)

Disability-based limitation for an individual who is currently 

receiving a retirement benefit that is treated like a disability 

benefit due to the October 2016 settlement

XIII 4.01(3) Group D1 retiree who is between age 75 and 79 as of 7/31/2021

XIV 4.01(3) Beneficiary of a group D1 retiree who is between age 75 and 79 

as of 7/31/2021

XV 4.01(3) Group D3 retiree who is between age 75 and 79 as of 7/31/2021

XVI 4.01(3) Beneficiary of a group D3 retiree who is between age 75 and 79 

as of 7/31/2021

4.02 Demonstration that the proposed suspension is reasonably estimated to enable the plan to 

avoid insolvency.

(1) Deterministic Illustrations

Application Exhibit 4 is the Plan Actuary’s Certification that the Plan is Projected to 

Avoid Insolvency under IRC §432(e)(9)(C)(i) as of the Proposed Benefit Suspension Effective 

Date of July 1, 2021. This certification includes a demonstration pursuant to Code 

§432(e)(9)(D)(iv) that the proposed suspension is reasonably estimated to enable the Plan to avoid 

insolvency. 

The Certification contains a year-by-year projection demonstrating that the Plan is 

projected to avoid insolvency within the meaning of Code §418E for the extended period with the 

proposed suspensions going into effect on July 1, 2021. It also contains illustrations as to the Plan’s 

solvency ratio and available resources for each year of the extended period. Document 6.2 contains

Internal Exhibits I – V which provide supporting illustrations for this Actuarial Certification. This 

includes Internal Exhibit II, which is a year-by-year solvency projection which demonstrates that, 

absent the Proposed Benefit Suspensions, the Pension Fund will become insolvent in the plan year 

ending April 30, 2033. Internal Exhibit III demonstrates that the Pension Fund will avoid 

insolvency with the Proposed Benefit Suspensions taking effect July 1, 2021. These Exhibits each 

separately identify the market value of assets, contributions, investment earnings, benefit payments 

and plan expenses. The Actuarial Certification in Document 6.1 and the supporting exhibits in 

Document 6.2 are based upon the actuary’s interpretation of the requirements under Revenue 

Procedure 2017-43, Section 3.02.

(2) Stochastic Illustrations

CPTF000017 CPTF - 
Application Exhibit 7 summarizes the results of 5,000 stochastic trials. Each trial consists 

of a projection of the market value of Plan assets for the plan years ending April 30, 2021 through 

2052.

Probability of maintaining positive assets over the extended period: 66.08%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are 

shown below in graphical format in Internal Exhibit I and in tabular format in Internal Exhibit II. 

In order to account for the Plan’s future cash flow needs the Trustees charged their ERISA

§3(21) investment consultant to establish a set of “dynamic” asset allocation targets which operate 

by setting “trigger points” based on specific liquidity metrics that will automatically alter the 

Plan’s allocation targets based on five pre-defined portfolios (Portfolios A, B, etc.). Although not 

strictly required under the Revenue Procedure, attached as Application Exhibit 5 are the Plan’s 

current Statement of Investment Policy and a separate pacing study with regard to the Plan’s 

alternative/illiquid portfolios. These are submitted to provide more detail on cash flow from 

investments over the extended period in keeping with non-binding pre-submission discussions 

between the Plan, Treasury, and the PBGC.

The capital market assumptions used for stochastic modeling assume a fixed transition 

from Portfolio A to Portfolio B on May 1, 2033 and a transition from B back to A on May 1, 2046. 

These assumed dates are based on the results of our deterministic modeling.

In order to provide additional information on the sensitivity of these projections to the 

assumed portfolio transition dates in keeping with non-binding pre-submission discussions 

between the Plan, Treasury, and the PBGC, we have included Internal Exhibits III and IV. Internal 

Exhibit III provides a frequency distribution of the date that negative cash flow first exceeds 7.5% 

of assets (which would trigger a transition to Portfolio B) and develops a median date for this 

transition of May 1, 2031. Internal Exhibit IV provides additional stochastic results.

Application Exhibit 14 describes the actuarial assumptions and methodology used in the 

reports filed with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

4.03 Demonstration that the proposed suspension is reasonably estimated to not materially 

exceed the level necessary to avoid insolvency

Application Exhibit 8 contains the Plan actuary’s demonstration pursuant to Code 

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

exceed the level necessary to avoid insolvency. 

(1) Deterministic Illustrations

As required by the Revenue Procedure, Section 4.03, the application must include a 

deterministic projection demonstrating that, if the dollar amount of the proposed suspension for 

each participant and beneficiary was reduced by the greater of:

• 5% of the reduction in payment proposed for that participant or beneficiary, or 

CPTF000018 CPTF - 
• 2% of that participant’s or beneficiary’s payment determined without regard to the 

proposed reduction,

the Plan would not be reasonably estimated to avoid insolvency. For purposes of this checklist 

item, the Plan’s actuary has interpreted the phrase “avoid insolvency” to mean that the plan 

satisfies the requirements of sub-paragraphs (1)-(3) of Regulation 1.432(e)(9)-1(d)(5)(ii)(A).

Internal Exhibit I provides plan-year-by-plan-year projections demonstrating that, under 

the reduced suspension as described above, the plan would not satisfy the requirements of subparagraph (3) of Regulation 1.432(e)(9)-1(d)(5)(ii)(A), requiring that, 

Unless the plan’s projected funded percentage (within the meaning of section 

432(j)(2)) at the end of the extended period using the deterministic projection 

described in paragraph (d)(5)(ii)(A)(1) of this section exceeds 100 percent, that 

projection shows that, during each of the last five plan years of that period, neither 

the plan’s solvency ratio nor its available resources (as defined in section 

418E(b)(3)) is projected to decrease.

and therefore does not “avoid insolvency.” Available resources are separately identified for each 

year. The illustration is based on the actuary’s interpretation of the requirements under Revenue 

Procedure 2017-43, Section 4.03. 

Application Exhibit 14 describes each of the assumptions used, as required under Revenue 

Procedure 2017-43, Section 4.02(3).

(2) Stochastic Illustrations

As required by the Revenue Procedure, Section 4.03, the application must include an 

illustration of the probability the plan will avoid insolvency utilizing stochastic projections and 

assuming the alternate, reduced suspension (as described above) was implemented.

Internal Exhibit I provides a projection demonstrating that, under the reduced suspension 

as described above, the plan would not satisfy the requirements of sub-paragraph (3) of Regulation 

1.432(e)(9)-1(d)(5)(ii)(A). Since the reduced suspension does not satisfy sub-paragraph (3), 

it cannot “avoid insolvency” regardless of the results of stochastic projections.

Internal Exhibit II summarizes the results of 5,000 stochastic trials. Each trial consists 

of a projection of the market value of Plan assets for the plan years ending April 30, 2021 through 

2052 assuming implementation of the alternate reduced suspension as outlined above. The actuary 

calculated the percentage of trials that resulted in fund assets remaining above $0 during the entire 

extended period as follows:

The probability of positive assets over the entire extended period is: 57.14%

The 5th, 25th, 50th, 75th and 95th percentiles of the projected market value of plan assets are shown 

below in graphical format in Internal Exhibit I and in tabular format in Internal Exhibit II. 

CPTF000019 CPTF - 
Application Exhibit 14 describes the actuarial assumptions and methodology used in the 

reports filed with this application, as required under Revenue Procedure 2017-43, Section 4.02(3). 

4.04 Demonstration that the proposed benefit suspension is distributed equitably.

The proposed benefit suspension provides for different treatment of participants and 

beneficiaries and is distributed in an equitable manner across the Plan’s participant and beneficiary 

population as required pursuant to Code §432(e)(9)(D)(vi). Application Exhibit 9 contains:

• information on the effect of the suspension on the Plan in the aggregate,

• information on the effect of the suspension on the Plan on a group-by-group basis.

• a list of the factors taken into account,

• an explanation of why none of the factors listed in Code §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 Code

§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,

as required by section 4.04 of the Revenue Procedure.

(1) Effect of Proposed Suspension on the Plan in the Aggregate

Internal Exhibit I provides the information on the effect of the suspension required by 

sub-section 4.04(1)(a) of the Revenue Procedure on an aggregate basis. 

Internal Exhibit II provides the distribution of participants by benefit reduction 

percentage on an aggregate basis as required by sub-section 4.04(1)(b) of the Revenue Procedure.

(2) Effect of Proposed Suspension on the Plan on a Group-by-Group Basis

Internal Exhibit III provides information on the effect of the suspension described in subsection 4.04(1)(a) of the Revenue Procedure broken out according to the groups described in 

Section 2.02 of this Application, as required by sub-section 4.04(2)(a) of the Revenue Procedure. 

Internal Exhibits IV through XIII provide the distribution of participants by benefit 

reduction percentage described in sub-section 4.04(1)(b) of Revenue Procedure 2017-43 on a 

group-by-group basis, as required by sub-section 4.04(2)(a) of Revenue Procedure 2017-43. Note 

that groups B2 and C2 do not include any participants, so there are no exhibits included for these 

groups.

Please refer to the following table:

Group Description Exhibit

A1 Non-Retired, pre-5/1/2007 accruals only IV

A2 Non-Retired, post-5/1/2007 accruals only V

CPTF000020 CPTF - 
Group Description Exhibit

A3 Non-Retired, pre- and post-5/1/2007 accruals VI

B1

Retiree with benefit reduction effective 8/1/2013, pre-5/1/2007 accruals 

only VII

B2

Retiree with benefit reduction effective 8/1/2013, post-5/1/2007 accruals 

only n/a

B3

Retiree with benefit reduction effective 8/1/2013, pre- and post-5/1/2007 

accruals VIII

C1

Beneficiary of the October 2016 disability lawsuit settlement, pre5/1/2007 accruals only IX

C2

Beneficiary of the October 2016 disability lawsuit settlement, post5/1/2007 accruals only n/a

C3

Beneficiary of the October 2016 disability lawsuit settlement, pre- and 

post-5/1/2007 accruals X

D1 Retiree not included in a C or D group, pre-5/1/2007 accruals only XI

D2 Retiree not included in a C or D group, post-5/1/2007 accruals only XII

D3 Retiree not included in a C or D group, pre- and post-5/1/2007 accruals XIII

(3) Identification of Statutory Factors Taken into Account

The proposed suspension establishes a difference in treatment among different categories 

or groups of participants. That different treatment results from reasonable application of specific 

relevant statutory factors. 

The suspension design applies the same benefit reduction – 32% – to all participants (other 

than statutorily protected groups) regardless of their status as active, deferred vested, or retired

under the terms of the Plan. The Trustees perceive the “flat” nature of the reduction as being the 

most reasonable starting point from which to refine the suspension so that it is not only equitable 

on its face but equitable by specific reference to relevant statutory factors. Additionally, a design 

element was introduced - distinguishing between benefits accrued before and after May 1, 2007 -

that creates discrete “groups” based upon whether a participant accrued only pre-May 1, 2007, 

only after that date, of both before and after. 

The choice of the May 1, 2007 date as a line of demarcation for the establishment of 

“groups” of participants is not random but is tied to the Plan’s benefit accrual rate history, of which 

the Trustees and Participants are keenly aware. After May 1, 2007, all future benefits are accrued 

at the rate of 1% (less a non-credited fraction which, as a practical matter, reduces the actual 

accrual rate on new contributions to about 0.39%). 

This current, nominal benefit accrual rate is substantially less than that enjoyed by 

Participants who accrued benefits prior to 2007. For example, any Participant who was active on 

or after May 1, 1997 will receive a 4.3% accrual rate on all of his or her contributions related to 

work prior to May 1, 2004 (even on money contributed prior to 1997). This is approximately 11 

times greater than the current effective accrual rate of 0.39% (which has been in effect for the past 

7 years). 

CPTF000021 CPTF - 
By applying the 32% cut only to pre-May 1, 2007 accruals, the suspension methodology 

cuts deeper against benefits accrued at more generous rates, not at all against those accrued only 

at an effective accrual rate of 1% or less, and in a shallower blended manner against those accrued 

at both. The Trustees concluded that this approach serves to avoid an “unbalanced” suspension so 

that no particular group shall bear an arguably disproportionate burden of sacrifice. The Trustees 

believe that this is a nuanced (in that the variable that governs benefit reduction historical accrual

rates rather than some other less objective variable) and narrowly tailored approach that accords 

with the statutory requirements.

In approving the design of the proposed suspension, the Board of Trustees considered and 

has determined that the difference in treatment of various Participant groups is based on a 

reasonable application of following statutory factors described in IRC §432(e)(9)(D)(6)(ii)(B):

(III) The amount of benefits. As discussed above, a participant (whether active, retired, 

or deferred vested as of the date of the suspension) who accrued all of his or her benefit pre-May 

1, 2007, will have accrued a much greater benefit as a percentage of contributions than will a 

participant with the same number of credited years all of which fall after May 1, 2007, or of which 

some are pre and some post that date. By reducing the pre-2007 accruals more aggressively than

post or blended accruals, the resulting benefits are drawn closer to being “equalized” postsuspension across the three main groups. Application of this factor is a reasonable basis for the 

grouping under the facts and circumstances presented.

(VII) The Plan’s history of benefit increases or reductions. This factor is the principal 

one upon which the reasonableness of the suspension lies. The history of defined benefit plan 

accrual changes – including the increases that many plans were required to grant, even 

retroactively, in order to preserve deductibility – are well known and are seen clearly in the accrual 

rate history of the Plan (see Table, Section 2.02). Regardless of the requirements that drove the 

increases, the effect was to create a period of time in which participants accrued benefits at a 

substantially higher rate than before or after that period. For the Plan, the accrual increases 

accelerated and reached generous levels in the late 1980s, eventually reaching a high point of 4.3% 

of contributions (applicable to all contributions made prior to May 1, 2004 provided the Participant 

was active on or after May 1, 1997). As described above and throughout this application, after that 

high point the accrual rate has been incrementally reduced until bottoming out at the current 

fraction-of-1% rate. This is such a substantial element of the Plan’s history that to fail to make it a 

prominent element of the suspension design would be unreasonable. It follows then that 

application of this factor is a reasonable basis for determining the affected “groups” of participants 

and the relative impact of the suspension design under all the facts and circumstances.

(X) The extent to which active participants are reasonably likely to withdraw support 

for the Plan, accelerating employer withdrawals from the Plan and increasing the risk of 

additional benefit reductions for participants in and out of pay status. Since May 1, 2004, and 

“peaking” in 2007, participants have experienced multiple reductions in the accrual rate. At the 

same time, the contribution rate paid by their employers has increased substantially, indeed to the 

point where on an “all reasonable measures” basis it has long been recognized by the Trustees that 

additional increases are not tenable and would in fact be detrimental to the Plan. While such 

reductions were necessary as part of the effort to forestall insolvency, these accrual rate reductions

may have a chilling effect on the active participants’ support for the Plan, which could accelerate 

CPTF000022 CPTF - 
the rate of employer Plan withdrawals. It is also notably difficult to sign up new employers to 

CBAs requiring contributions to an underfunded plan with a nominal future benefit. 

With these facts understood, the Trustees were confronted with the necessity to structure 

the suspension in such a way as to preserve what value the Plan does offer to active participants,

and that is why post-May 1, 2007, accruals – nominal though they are – had to be insulated. For a 

participant who only has accruals at an effective 0.39% rate, to further reduce that amount by 

almost 1/3 would be to render the earned benefit of vanishingly small utility to the point that the 

participant would rationally question the value of the Plan deduction from his wage package. 

Without active participants, whose associated contribution base units (discussed in the 

assumptions sections of the application) drive the actuarial future solvency of the Plan, there will 

be no solvency. 

It is therefore prudent to take steps to ameliorate the impact of the proposed suspension on 

the participants’ post-2007 accruals to the extent possible, and the suspension design reflects this 

goal. Application of this fact is a reasonable basis for determining the effected groups of 

participants and the relative impact of the suspension design under all of the facts and 

circumstances.

4.05 Notice.

The Trustees have satisfied the notice requirements of Code §432(e)(9)(F) as follows:

(1) Individual notices.

Application Exhibit 11 to the Application contain each type of notice that will be given 

to each participant and beneficiary under the Plan, as well as to each employer that has an 

obligation to contribute to Plan and to each employee organization representing participants in the 

Plan. 

The Plan has also established a website (http://www.detroitcarpentersprp.org/) containing 

frequently asked questions and other information useful to participants with regard to the proposed 

suspension.

(2) Efforts made to contact participants, beneficiaries and alternate payees.

The Board of Trustees has compiled complete and up-to-date records of the Plan’s 

participants and beneficiaries. If an address is found to be invalid, it will be referred to the Plan’s 

third-party administrator (BeneSys) which would refer the it to PBI, the entity used by BeneSys to 

monitor participant death records and locate missing participants. BeneSys also conducts searches 

using on-line search tools.

(3) Notices will not be delivered electronically.

(4) Lists of:

(a) Each employer that has an obligation to contribute to the Plan within the 

meaning of section 4212(a) of ERISA.

CPTF000023 CPTF - 
A list of the contributing employers that have an obligation to contribute to the Plan within 

the meaning of §4212(a) of ERISA is attached as Application Exhibit 12.

(b) Employee organization representing participants under the plan.

The employee organization representing participants under the Plan is the Michigan 

Regional Council of Carpenters and its subordinate affiliate Local Unions. 

SECTION 5. PLAN SPONSOR DETERMINATION RELATING TO REASONABLE 

MEASURES TAKEN TO AVOID INSOLVENCY

5.01 Measures taken to avoid insolvency.

See, discussion in Section 3.03 and 3.04, above, and the Narrative Statement (Application 

Exhibit 21).

5.02 Plan factors.

See, discussion in Section 3.03 and 3.04, above, and the Narrative Statement (Application 

Exhibit 21).

5.03 How plan factors were taken into account.

See, discussion in Section 3.03 and 3.04, above, and the Narrative Statement (Application 

Exhibit 21).

5.04 Other factors considered.

See, discussion in Section 3.03 and 3.04, above, and the Narrative Statement (Application 

Exhibit 21).

SECTION 6. OTHER REQUIRED INFORMATION

6.01 Ballot.

See, Application Exhibit 13 for a proposed ballot package intended to satisfy the 

requirements of Code §432(e)(9)(H)(iii). In keeping with the Revenue Procedure, the ballot 

package does not include the information described in Regulation §1.432(e)(9)-1(h)(3)(i)(E), (L) 

or (M) (the statement in opposition to the proposed benefit suspension, the individual estimate that 

will be provided as part of the notice, and the voting procedures, including the deadline for voting).

6.02 Partition.

The Plan is not requesting approval for a partition.

6.03 Description of assumptions used in projections.

CPTF000024 CPTF - 
Application Exhibit 14 fulfills the requirements of Section 6.03 of the Revenue Procedure 

by describing the assumptions used by the Plan’s actuary for performing projections required under 

sections 3.01, 3.02, 4.02(1), 4.02(2), and 4.03 of the Revenue Procedure. Internal Exhibit 

I/Document 25.1 (Actuarial Assumptions and Methods Used for Projections). The certification of 

critical and declining status described in section 3.01 was prepared before submission of this 

Application and includes assumptions that differ from those used to prepare other projections 

contained herein. These differences are noted. 

With regard to the contribution base units (CBU) assumption described in the exhibit, the 

Trustees were called upon, as they are with respect to future industry activity assumptions each 

year under the PPA of 2006, to make a subjective judgment. In effort to reduce subjectivity the 

Trustees have looked to three sources: 

(1) An independent analysis undertaken by an economist retained for the purpose.

(2) Economic activity forecasting for the construction industry and the carpentry subgroup 

within the southeastern Michigan geographic region as maintained by the Michigan Department 

of Technology, Management and Budget, Bureau of Labor Market Information and Strategic 

Initiatives.

(3) An inquiry to the employers and associations of employers that are signatory to Plan 

CBAs seeking their business modelling of future work. This item includes an assessment of the 

potential impact of the COVID-19 pandemic.

From these sources and in consultation with the Plan actuary, the CBU assumption for 

purposes of the suspension is:

Plan Year Ending Hours

2021 6.9 million

2022 7.0 million

2023 7.0 million

2024+ 6.9 million

(1) Independent economic analysis. Exhibit 15 is the report entitled Carpenters Pension 

Trust Fund – Detroit & Vicinity, 20-year Forecast (August 26, 2019). To provide the Secretary 

with additional objective support for the CBU assumption the Trustees retained the services of 

Employment Research Corporation and that entity’s President, Malcom S. Cohen, PhD. As Dr. 

Cohen’s states he:

was asked to make a projection of demand for unionized construction-industry 

carpenters in Michigan. I was provided with historical data on hours worked by 

members of the Carpenters Pension Trust Fund – Detroit and Vicinity (“the Fund”). 

Employer contributions to the Fund are related to each employee’s hourly rate. 

There are different kinds of projections. Economists look at past trends and current 

leading indicators and make projections based on these trends. These forecasts are 

intended to assist analysts in understanding broad trends and risks and are not 

CPTF000025 CPTF - 
intended to determine actual contribution rates that should be made to keep a 

pension plan solvent. These determinations are typically made by actuaries that 

have more experience with fund flows and understand risks to the solvency of the 

fund. They also have a better understanding of the specifics of the fund contributors 

as well as specific risks.

In other words, the purpose of inviting Dr. Cohen’s review was to determine if objective 

economic data was, independent of any input from the Plan’s actuary as to the basis of the 

assumptions utilized in this Application, supportive of the assumption applied by the actuary as to 

future CBUs. Dr. Cohen provided the following summary explanation of his methodology:

In order to project expected hours worked for future years, I compared the data on 

hours with measures related to industry activity such as Carpenters’ employment in 

the United States, Michigan and the Detroit Metropolitan Statistical Area. Figure 2 

shows Carpenter employment in Michigan and in the Detroit Metropolitan 

Statistical Area from 2003 to 2018.

Dr. Cohen further notes that:

The demand for Carpenters can fluctuate based on economic conditions. During an 

economic recession, it is not unusual to see a decrease in demand for many types 

of labor. The National Bureau of Economic Research (NBER) defines a recession 

as a “significant decline in economic activity spread across the economy, lasting 

more than a few months, normally visible in real GDP, real income, employment, 

industrial production, and wholesale-retail sales.”

From there, Dr. Cohen analyzes the impact of foreseeable recessionary periods on 

projected carpenter employment:

In the last 40 years there have been three major declines in Carpenter employment, 

occurring from 1979-1982, 1988-1992, and 2006-2010. From 2006 to 2010, 

Carpenter employment dropped by 33%. Over the same time period, hours worked 

by carpenters in Michigan declined by 47%, from 11,200,000 to 5,900,000. 

To estimate the impact of future declines, I have included a projection that assumes 

there will be two declines over the next 20 years that and that each will average 

30%. I assume that employment will decline 15% during the first year, and bottom 

at 30% in the second year, then return to the 4.2% growth rate experienced by 

Carpenter hours from 2010 to 2018. 

In this projection, shown in Figure 6 [reference is to chart in exhibit, not reproduced 

here], Carpenter hours will reach 7.7 million by 2038, but there is a 30% reduction 

in hours occurring over two years in 2021 and 2032.

As reasonably anticipated, the actuary’s CBU assumption and the projections made by Dr. 

Cohen from his independent examination of economic data are not identical, although they are not 

incompatible.

CPTF000026 CPTF - 
Year

Projected 

Hours Worked

2019 8,528,350

2020 8,886,541

2021 7,553,560

2022 6,220,579

2023 6,481,843

2024 6,754,080

2025 7,037,752

2026 7,333,337

2027 7,641,337

2028 7,962,274

2029 8,296,689

2030 8,645,150

2031 7,348,377

2032 6,051,605

2033 6,305,772

2034 6,570,615

2035 6,846,581

2036 7,134,137

2037 7,433,771

2038 7,745,989

If for the sake of illustration, one takes the first four years of the Plan actuary’s assumption 

(2021 – 2024) the average hours = 6.95 million. If one does the same with those four years using 

Dr. Cohen’s date the average hours = 6.70. The Trustees concluded that the Dr. Cohen’s study 

constitutes a valid metric of objective support for the selected CBU assumption. The Trustees 

recognize that this separate piece of analysis is not specifically required to be part of this 

Application under the Revenue Procedure, and appreciate the willingness of Treasury to receive it

and to give to it the weight deemed appropriate. The Trustees respectfully suggest that the objective 

nature of the analysis adds support to validity of the CBU assumption applied to the proposed 

suspension.

(2) The Trustees with their professionals have obtained and reviewed data reports issued 

by the Michigan Department of Technology, Management and Budget, Bureau of Labor Market 

Information and Strategic Initiatives, all of which are available at: 

http://milmi.mt.gov/datasearch/projections-excel

For the period 2018-2028, statewide in Michigan, the Bureau predicts an annual rate of 

employment change for the construction industry of .6% or, essentially flat. Within the 

construction sector the Bureau predicts an annual rate of change for non-residential building 

construction of .7% and for specialty trades of .6%. Again, essentially flat.

Within the carpentry occupation, the Bureau anticipates over the same period an annual 

rate of employment change of .3%. Again, essentially no growth.

CPTF000027 CPTF - 
Limited just to the Metro Detroit region, the Bureau’s long-term forecast is for annual 

change in the construction industry of 1.1%. For the carpentry occupation, .8%. Again, essentially 

flat.

The import of these figures to the Trustees was to suggest that employment in the relative 

industry and occupational categories are not expected to experience significant growth over a long 

term period that is essentially co-extensive with the relevant period for the suspension. That being 

understood, the Trustees turned to the ground-level source of data and made enquire of the 

contributing employers to the Plan and their associations.

(3) Report of Employers/MRCC. Attached as Application Exhibit 35 is a letter report of 

information received from contributing employers and associations and the MRCC with respect to 

projected work hours. The reports notes the anticipated essentially short term nature of COVID19 impacts, and concludes: “Other than short-term disruptions during the remaining two months 

of the 2020 fiscal year, we expect our work hours to level off in the seven to eight million per year 

range for the short term.”

In preparing this second application the Trustees are cognizant that the impact of COVID19 is not only a matter of controversy and debate but simply not predictable over a long time 

horizon. But, as the disruption of the pandemic cannot be discounted, the Trustees determined that 

for 2021 and 2022 the CBU assumption as made for purposes of the 2019 application should be 

reduced by approximately 1 million hours. As of the date of the filing of this second application 

Michigan has stepped through all but one of the phases of its re-opening plan and it is anticipated 

that the initial drop off in work hours attributable to the economic shut down/quarantine regime 

has eased. Yet the possibility of a “second wave” exists, and the reduction to the CBU assumption 

for 2021 and 2022 is a prudent effort to account for the future impact of COVID-19 in a manner 

that neither overstates that impact (therefore potentially greater suspension) nor understates it 

(therefore reducing the likelihood that the proposed suspension will be adequate to avoid 

insolvency). 

Application Exhibit 14/Internal Exhibit II/Document 25.2 is the Plan actuary’s 

Supporting Documentation for Selection of Certain Assumptions, including the actuary’s rationale 

for the major assumptions.

Application Exhibit 14/Internal Exhibit III/Document 25.3 is the Plan actuary’s 

Additional Disclosures Relating to the Use of Different Assumptions, and provides the actuary’s 

explanation of the differences between assumptions used under section 4.02(1) and 3.01 of the

Revenue Procedure, utilizing deterministic and stochastic projections. Application Exhibit 11 and 

its internal exhibits are based on the Plan actuary’s interpretation of the requirements under the

Revenue Procedure, Section 6.03 and Appendix B. 

6.04 Ten-year experience for certain critical assumptions.

Application Exhibit 17 describes the Plan's experience for certain critical assumptions 

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

Application separately identifying, in accordance with Section 6.04 of the Revenue Procedure:

• Total contributions; 

CPTF000028 CPTF - 
• Total contribution base units; 

• Average contribution rates; 

• Withdrawal liability payments; and 

• Rate of return on plan assets.

6.05 Demonstration of sensitivity projections.

Application Exhibit 18 is the Plan actuary’s Demonstration of Sensitivity of Projections

as required under Section 6.05 of the Revenue Procedure, which requires inclusion of deterministic 

projections of the sensitivity of the Plan’s solvency ratio throughout the extended period by taking 

into account alternate assumptions of investment experience and future contribution base units 

than assumed in other parts of this Application. The Plan’s actuary notes that while Section 6.05 

of the Revenue Procedure and the attendant checklist description (Checklist # 27) speak to using 

more conservative assumptions for future contribution base units, assuming that the 10-year trend 

of CBU increases continues into the future is in fact more aggressive than the projection 

assumptions used in other parts of this Application. 

Internal Exhibits I, II, III, and IV provide separate, deterministic solvency ratio 

projections intended to help gauge the sensitivity of the projections to certain key assumptions as 

required by Section 6.05 of Revenue Procedure 2017-43. Each exhibit was prepared recognizing

the proposed suspension. As permitted by Section 6.05, Exhibits III and IV do not recognize any 

change in expected benefit payments that may result from using alternate assumptions regarding 

future contribution base units.

• Exhibit I projects the Pension Plan's solvency ratio using assumed rates of return reduced 

by one percentage point (beginning with the plan year ending April 30, 2022);

• Exhibit II projects the Pension Plan's solvency ratio using assumed rates of return reduced 

by 2 percentage points (beginning with the plan year ending April 30, 2022);

• Exhibit III projects the Pension Plan's solvency ratio using a 1.04% contribution base unit 

trend (beginning with the plan year ending April 30, 2022), which is equal to the trend that 

the Pension Plan experienced over the 10 plan years ending April 30, 2020; and

• Exhibit IV projects the Pension Plan's solvency ratio using a 0.04% contribution base unit 

trend (beginning with the plan year ending April 30, 2022), which is equal to the trend 

assumed in Exhibit III reduced by one percentage point.

The assumed rates of return for Exhibits I and II are as shown below:

Plan Years Ending 

4/30:

Assumed Rates of Return Used For:

Section 4.02(1) of 

Rev. Proc. 2017-43 Exhibit I Exhibit II

2022-2030 6.50% 5.50% 4.50%

2031-2033 7.35% 6.35% 5.35%

2034-2046 6.75% 5.75% 4.75%

2047+ 7.35% 6.35% 5.35%

The alternative rate of return assumptions above were assumed to first apply following the initial 

period. That is, the April 30, 2021 market value of plan assets is the same for all scenarios.

CPTF000029 CPTF - 
Hours (contribution base units) increased from 6,572,509 in plan year ending April 30, 2011 to 

7,212,686 in plan year ending April 30, 2020. This represents a compound annual increase of 

1.04% per year for the 10-year period.

Based on the preceding calculation, the assumed work hours for Internal Exhibits III and IV are as 

shown below:

Plan Year Ending 

4/30:

Assumed Work Hours Used For:

Section 4.02(1) of 

Rev. Proc. 2017-43 Exhibit III Exhibit IV

2022 7,000,000 7,363,4901 7,218,4572

2023 7,000,000 7,440,070 7,221,344 

2024 6,900,000 7,517,447 7,224,233 

2025 6,900,000 7,595,628 7,227,123 

2026 6,900,000 7,674,623 7,230,014 

2027+ 6,900,000 increases @1.04%/yr. increases @0.04%/yr.

The alternative work hours assumptions above were assumed to first apply following the initial 

period. That is, the same number of work hours for the plan year ending April 30, 2021 is assumed 

in all scenarios.

These demonstrations satisfy Section 6.05 of the Revenue Procedure.

6.06 Projection of funded percentage.

Application Exhibit 19 is the Deterministic Projection of Assets, Liabilities, and Funded 

Percentage prepared by the Plan’s actuary and includes a deterministic projection for each year in 

the extended period of the value of the Plan's assets, its accrued liability, and its funded percentage. 

The table produced at Internal Exhibit I/Document 28.1 projects the Plan's funded percentage 

using the value of Plan assets and accrued liabilities during the extended period of April 30, 2021

through 2052. The projection includes the impact of benefit suspensions and is made on the same 

basis as Internal Exhibit III of Application Exhibit 4. 

Note that, as the suspension is assumed to be effective July 1, 2021, the April 30, 2021 

liabilities do not reflect its impact. Liabilities and funded percentages were calculated using a 

discount rate of 7.50% (the discount rate utilized in the May 1, 2019 Actuarial Valuation Report).

This exhibit satisfies the requirements of Section 6.06 of the Revenue Procedure.

6.07 Plan sponsor certifications relating to Plan amendments.

See, Application Exhibit 20 for the Trustees’ certification that if they receive final 

authorization to implement the suspension of benefits as described in Code §432(e)(9)(H)(vi), and 

choose to implement the authorized suspensions they will adopt, in a timely manner, the following 

1 Hours for plan year ending April 30, 2020 (7,212,686) increased by 1.04% for 2 years (compounded)

2 Hours for plan year ending April 30, 2020 (7,212,686) increased by 0.04% for 2 years (compounded)

CPTF000030 CPTF - 
Plan amendments which shall not be modified at any time thereafter before the suspension of 

benefits expires:

(1) in accordance with Code §432(e)(9)(C)(ii) a Plan amendment providing that the 

benefit suspension will cease as of the first day of the first plan year following the plan year in 

which the Trustees fail to determine that both: (a) all reasonable measures to avoid insolvency 

continue to be taken during the period of benefit suspension; and (b) the Plan is projected to 

become insolvent unless benefits continue to be suspended; and

(2) a Plan amendment providing that any future benefit improvements must satisfy the 

requirements of Code §432(e)(9)(E).

6.08 Whether the Plan is a plan described in §432(e)(9)(D)(vii).

The Plan is not a plan described in Code §432(e)(9)(D)(vii).

6.09 Narrative statement.

See, Application Exhibit 21.

SECTION 7. IDENTIFICATION AND BACKGROUND INFORMATION ON THE PLAN

7.01 Plan sponsor.

The Plan sponsor is the Board of Trustees of the Carpenters Pension Trust Fund – Detroit 

& Vicinity. The address of the Board is P.O. Box 4540, Troy, MI 48099-4540. The Telephone 

number is (248) 641-4950. The Board does not have a separate Employer Identification Number 

(EIN).

7.02 Plan identification.

The name of the Plan is the Carpenters Pension Trust Fund – Detroit & Vicinity. The Plan 

has been assigned Plan Number 001. Its Employer Identification Number (EIN) is 38-6242188. 

The Plan is a multiemployer plan within the meaning of Code §414(f) and ERISA §3(37).

7.03 Retiree representative.

On September 10, 2020, the Trustees appointed Charles Tindall as the Retiree 

Representative consistent with Section 7.03 of the Revenue Procedure. See, Application Exhibit 

22. Contact information:

Charles Tindall

MPRA Retiree Representative

700 Tower Drive, Ste. 300

Troy, MI 48098

(T) (313) 570-1447

CPTF000031 CPTF - 
Email: Retiree.Rep@gmail.com

7.04 Plan’s enrolled actuary.

The Plan’s enrolled and certifying actuary for all actuarial calculations contained in this 

filing with the exception of Application Exhibit 3 is:

Name of Actuary: Erika L. Creager, EA, MAAA 

Enrollment Number: 20-07288

Contact Information:

Address: United Actuarial Services, Inc.

11590 North Meridian Street, Suite 610

Carmel, Indiana 46032-4529

Phone: (317) 580-8631

Fax: (317) 580-8651

Email: ecreager@unitedactuarial.com

The certifying actuary for Application Exhibit 3 (certification of critical and declining status) is:

Name of Actuary: Angela L. Jeffries, EA, MAAA 

Enrollment Number: 20-08511

Contact Information:

Address: United Actuarial Services, Inc.

11590 North Meridian Street, Suite 610

Carmel, Indiana 46032-4529

Phone: (317) 580-8668

Fax: (317) 580-8651

Email: ajeffries@unitedactuarial.com

7.05 Power of attorney.

See, Application Exhibit 23. The Plan’s representatives as attorney-in-fact are John I. 

Tesija and Paul M. Newcomer of Novara, Tesija & Catenacci, PLLC.

7.06 Plan documents.

See, Application Exhibit 24 for the Plan’s most recently restated plan document;

Application Exhibit 25 for Plan amendments 1 – 8; Application Exhibit 26 for the Plan’s current 

summary plan description; Application Exhibit 27 for a summary of material modifications; and 

Application Exhibit 28 for the most recent determination letter issued to the Plan by the IRS.

7.07 Collective bargaining and side agreements.

CPTF000032 CPTF - 
See, Application Exhibits 29 and 30, for excerpts from the collective bargaining 

agreements and side agreements pursuant to which the Plan is maintained, including language from 

any portions of a collective bargaining agreement or side agreement that are relevant to the Plan 

or proposed suspension.

7.08 Annual return.

See, Application Exhibit 31 for the following sections of the Plan’s most recently filed 

form 5500: (1) pages 1 and 2 of Form 5500, (2) Schedule MB, including attachments, (3) Schedule 

R, with attachments, and (4) accountant’s report under section 103(a)(3) of ERISA.

7.09 Rehabilitation plan.

See, Application Exhibit 32 for a copy of the Plan’s most recently updated rehabilitation 

plan.

7.10 Valuation reports.

See, Application Exhibits 33 and 34 for the May 1, 2018, and May 1, 2019 Actuarial 

Valuation Reports for the Plan, respectively.

7.11 Completed checklist.

See, Application Exhibit 00 for the completed checklist of information required to be 

included in the Plan’s Application. 

CPTF000033 CPTF - 
The Tmstees appreciate Treasmy's review of this impo1tant matter for the Plan. Should 

you have any questions or require any additional info1mation please contact John I. Tesija or 

Paul M. Newcomer at T: (248) 354-0380. 

CPTF000034 

CARPENTERS PENSION TRUST FUND - DETROIT & VICINITY 

Robert Halik, Sefaetary 

Signed: September 29, 2020 

CPTF-
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.0

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 Revenue Procedure 2017-43.

Document 2.1 provides a description of the proposed benefit suspension under the Pension Plan. 

CPTF000035 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.1

Document 2.1

Description of the Proposed Benefit Suspension

Effective Date and Expiration

The Board of Trustees of the Pension Plan propose the following reduction of benefits, which will 

become effective on July 1, 2021 if approved, will remain in effect indefinitely, and will not expire 

by its own terms.

Historical Benefit Formula

The Board of Trustees believe that, in order to understand the proposed suspension formula, the 

reader must be aware of the historical benefit formula.

Generally, the accrued benefit for a participant who terminated prior to May 1, 2004 is 

determined from the following table:

Plan Year of 

Termination 

Starting May 1, Formula

<=1976 2.75% of contributions, but not less than $35 per month or more than 

$650 per month*

1977-1978 2.75% of contributions, but not less than $35 per month or more than 

$800 per month*

1979

2.75% of the first $15,000 of contributions plus 3% of contributions in 

excess of $15,000, but not less $35 per month or more than $900 per 

month*

1980-1983 2.6% of contributions*

1984 2.9% of contributions*

1985 3.2% of contributions*

1986 3.4% (3.2% for PYB < 1985) of contributions

1987-1988 3.6% (3.4% for PYB < 1985) of contributions

1989 3.7% (3.4% for PYB < 1985) of contributions

1990-1991 3.85% of contributions

1992-1996 3.9% of contributions

1997-2003 4.3% of contributions

* Not less than 3.5% of the first $4,300 of total contributions plus 1.5% of the remaining contributions if 

participant on 4/30/1969

A participant who terminates on or after May 1, 2004 will have his or her benefit determined as 

follows:

• 4.3% of contributions made or required to be made prior 5/1/2004, plus

CPTF000036 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.2

• 3% of credited contributions made or required to be made from and after 5/1/2004 but 

prior to 5/1/2007 (77.5%-78% of contributions related to work performed from 6/1/2006

through 5/1/2007 is credited), plus

• 1% of credited contributions made or required to be made from and after 5/1/2007 

(between 84% and 39% of contributions related to work performed during this period is 

credited).

Description of Proposed Suspension

The proposed benefit suspension shall be accomplished by recalculating all accrued benefits and, 

for benefits that are in pay status, recalculating such benefit from the revised accrued benefit.

The accrued benefit earned prior to 5/1/2007 will be reduced by 32%. Any accrued benefit 

earned under the 1% multiplier will be untouched. 

Retirees Who Entered Pay Status between 9/1/2008 and 7/31/2013

As an adjustable benefit cut implemented as part of the plan’s rehabilitation plan, the early 

retirement factors were changed effective August 1, 2013 with application to any participant who 

retired on or after September 1, 2008. As a result, all participants who entered pay status 

between September 1, 2008 and July 31, 2013 had their benefit recalculated as if the new factors 

had been in place when they originally retired. However, the effect of the new early retirement 

formula was capped at a 5% reduction.

Post-suspension benefits for this group will be determined using the early retirement factor in 

effect when the participant initially retired. However, no benefit will be increased as a result of 

the suspension.

Disability-Based Limitation

The individual limitations will be applied as per statute. However, there are some special 

circumstances related to the application of the disability-based limitation. These are enumerated 

below:

• When the disability rules were changed in 2013, disabled retirees without a Social Security 

award were allowed one year to obtain such award. As a result of this change, some 

previously disabled participants ceased to qualify under the plan rules. These participants

will not receive any special protection under the disability-based limitation.

• As the result of a settlement of a class action lawsuit in October 2016, most disabled 

participants who were in pay status as of 8/1/2013 and had taken a cut due to the 2013 

rule change, were restored to 95% of their pre-amendment disability benefit amount. 

After these participants retire, the disability-based limitation will be applied based on the 

95% of pre-amendment disability amount.

CPTF000037 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.3

• Also as the result of the 2016 class action settlement, affected disabled participants who 

were:

o In pay status on 8/1/2013, and

o Converted to early retirement prior to October 2016, and

o Had an early retirement benefit that was less than 95% of their prior disability 

benefit,

were granted a benefit increase to 95% of their pre-amendment disability amounts 

payable until age 62, at which time their benefit will increase to an unreduced, early

retirement benefit. For purposes of the disability-based limitation, the benefit payable 

until normal retirement age for these participants will be treated as a disability benefit.

• In the case of separate interest alternate payees, the alternate payee will generally not

receive any portion of the disability-based limitation. The exception to this is in the case 

of an alternate payee who was assigned a portion of the participant’s disability benefit. 

In this case, such alternate payee will receive a disability-based limitation based on the 

portion of disability benefit assigned and the participant will not receive a disability-based 

limitation based on such portion.

• In the case of a shared interest alternate payee, any disability-based limitation will be 

shared in the same manner as the benefit itself.

• Surviving spouses and beneficiaries will not receive any disability-based limitation.

• A former disabled retiree who has converted to normal or early retirement will receive 

disability-based limitation protections based on the monthly disability benefit amount he 

or she was receiving immediately prior to conversion.

How Suspension Affects Various Groups of Participants – Main Groupings

Below is a listing of the various groups of participants that are treated differently under the 

suspension and a description of how each group is treated differently. The groups are designated 

by the letters A through D.

CPTF000038 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.4

Group Description How Treated Differently

A Non-Retired

Non-retired participants will be subject to a 32% cut on pre5/1/2007 accruals. For active participants continuing to accrue 

benefits, the effect of any cut relative to the final accrued benefit 

at retirement will become less as time passes.

B

Retiree with 

8/1/2013 

Benefit 

Reduction

As described above, the benefits of the retirees in this group were 

reduced to reflect a new set of early retirement factors effective 

8/1/2013 (though the reduction was limited to 5% of the benefit 

in pay status immediately prior to 8/1/2013). This group is subject 

to a 32% cut on pre-5/1/2007 accruals, but the early retirement 

factor used for determining the post-suspension benefit in pay 

status will be the factor that was in effect when they initially 

retired. Thus, the reduction will be slightly less relative to the 

benefit in effect immediately prior to suspension when compared 

to a similarly-situated retiree who did not experience the 

8/1/2013 benefit adjustment.

C

Beneficiary of 

October 2016 

Disability 

Lawsuit 

Settlement

This group is subject to a 32% cut on pre-5/1/2007 accruals. 

However, as described above, the disability-based limitations are 

applied differently to this group as compared to a similarlysituated disabled or retired participant who was not a beneficiary 

of the lawsuit settlement.

D

Pay Status 

Participant Not 

In Groups B or 

C

This group is subject to a 32% cut on pre-5/1/2007 accruals, but 

does not receive the benefit of any of the special rules applicable

to groups B and C.

CPTF000039 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.5

How Suspension Affects Various Groups of Participants – Sub-groups

Because the proposed suspension does not affect any benefits accrued on or after May 1, 2007 

(those that accrued under the 1% multiplier), each of preceding groups must be sub-divided into 

3 sub-groups: 

• Those with all accruals prior to May 1, 2007, 

• Those with all accruals on or after May 1, 2007, and 

• Those with accruals both before and after May 1, 2007. 

For simplicity, the 3 possible sub-groups are labeled 1, 2, and 3. The way in which each sub-group 

is treated differently is described below:

SubGroupDescription How Treated Differently

1

Pre-5/1/2007 

Accruals Only

The 32% reduction will apply to the entire accrued benefit

2

Post-5/1/2007 

Accruals Only

As there are no pre-5/1/2007 accruals, the accrued benefit will be 

unaffected by the suspension

3

Pre- And Post5/1/2007 

Accruals

The 32% reduction will only apply to the portion of the benefit 

accrued prior to 5/1/2007. Therefore, the overall reduction will be 

less than 32%.

Final Groupings

Final groupings are referred to by starting with the letter representing the participant’s main 

group and appending the number representing the appropriate sub-group. For example, “A1,” 

“A2,” etc.

The final groupings are summarized below (note that a few of the final groups do not contain any 

participants):

Group Description

A1 Non-Retired, pre-5/1/2007 accruals only

A2 Non-Retired, post-5/1/2007 accruals only

A3 Non-Retired, pre- and post-5/1/2007 accruals

B1 Retiree with benefit reduction effective 8/1/2013, pre-5/1/2007 accruals only

B2 Retiree with benefit reduction effective 8/1/2013, post-5/1/2007 accruals only

B3 Retiree with benefit reduction effective 8/1/2013, pre- and post-5/1/2007 accruals

C1

Beneficiary of the October 2016 disability lawsuit settlement, pre-5/1/2007 accruals 

only

C2

Beneficiary of the October 2016 disability lawsuit settlement, post-5/1/2007 accruals 

only

CPTF000040 CPTF - 
Carpenters Pension Trust Fund – Detroit and Vicinity

EIN/Plan #: 38-6242188/001

Checklist Item #2 – 2.02 Description of the Proposed Benefit Suspension

2.6

Group Description

C3

Beneficiary of the October 2016 disability lawsuit settlement, pre- and post-5/1/2007 

accruals

D1 Retiree not included in a B or C group, pre-5/1/2007 accruals only

D2 Retiree not included in a B or C group, post-5/1/2007 accruals only

D3 Retiree not included in a B or C group, pre- and post-5/1/2007 accruals

Note: In the table above, “retiree” includes beneficiaries and alternate payees

CPTF000041 CPTF - 
P.O. Box 4540 • Troy, MI. 48099-4540 

Telephone: (248) 641-4950 800-572-2525 

SEPTEMBER 21, 2020 

CARPENTERS PENSION TRUST FUND, DETROIT & VICINlTY 

PENAL TY OF PERJURY STATEMENT/PUBLIC DISCLOSURE STATEMENT 

Pursuant to Sections 2.03 and 2.04 of IRS Revenue Procedure 2017-43, each of the 

undersigned authorized Trustees makes the following two statements: 

Under penalties of perjury I declare that I have examined this application, including the 

accompanying documents, and, to the best of my knowledge and belief, the application contains 

all of the relevant facts relating to this request, and such facts are true, correct and complete. 

I acknowledge that, pursuant to Section 432(e)(9)(G)(ii) of the Internal Revenue Code, 

the application for approval of the proposed suspension of benefits, and the application's 

supporting material, will be publicly disclosed through publication to the Treasury Department's 

website. 

Signed: September ~'1 2020 

PMN/ldmW:\FUNOS\mrcc\08-PENS\MPRA\Penalty of Perjury and Disclosure Statement.on letterhead.doc 

CPTF000042 CPTF-