Southwest Ohio Regional Council of Carpenters' 

Fringe Benefit Funds 

Health Fund: P.O. Box 1257, Troy, Ml 48099 

Pension Fund: 33 Fitch Blvd., Austintown, OH 44515 

Phone: 330-779-8862 

Website: www.ocbenefits.org 

ToileSubmitted: Jun~29,20l8 

Electronic Submission to www.treasurv.gov/mpn1 

The Honorable Steven T. Mnuchin 

Secretary ofthe Treasury 

Department of the Treasury 

1500 Pennsylvania Avenue, NW 

Washington, DC 20220 

Re: Southwest Ohio ~~_g_i_911~LC011ncil of Carpenters Pension Plan - Application for Suspension of 

Benefits Under the Mullkmplovcr Pi;;nsion Relief ~.fl_of2014 

Dear Secretary Mnuchin: 

As an aulhori:1.ed Trustee orthe Hoard ofTrustees for the Southwest Ohio Regional Council ofCarpenters 

Pension Plan as the Plan Sponsor, I respectfully submit this application for approval of a proposed 

suspension of benefits pursuant to the Internal Revenue Code §432(e)(9) and the Employee Retirement 

Income Security Act of 1976 ~305(c)(9). 

Respectfully Submitted By: 

Signed June 27, 20 I 8 

SWORCCPP2018-0000Q'..fJ 
Southwest Ohio Regional Council of Carpenters Pension Plan

EIN/Plan # 31-6127287/001

Checklist Item #2 – 2.02 Description of Proposed Benefit Suspension

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.

Attached as Document 2.1 is a description of the proposed benefit suspension. 

SWORCCPP2018-000002
Document #2.1

Southwest Ohio Regional Council of Carpenters Pension Plan

Document 2.1

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan proposes the 

following reduction in benefits effective on March 31, 2019. The reduction in benefits shall remain in 

effect indefinitely.

The proposed reduction in benefits shall be accomplished by the amendment of the Plan to recalculate all 

accrued benefits and all monthly benefits in pay status for all Participants, Beneficiaries and Alternate 

Payees with a separate interest pension benefit and to be effective for benefit payments on or after 

March 31, 2019.

The one-time recalculation set forth below is based on the basic premise that all accrued benefits and 

monthly benefits in pay status shall be subject to the same early retirement reduction factors that have 

been or will be applied pursuant to the Plan's provisions to benefits with an annuity starting date on or 

after January 1, 2013, and then all accrued benefits and monthly benefits in pay status shall be further 

subject to an additional flat percentage reduction.

The recalculation shall be applied to all Participants, Beneficiaries and Alternate Payees without regard to 

different categories or groups of individuals and shall not distinguish between individuals based on years 

of service, benefit credit or accrual rate, employer, or the amount of benefits received through the 

effective date of the reduction of benefits, March 31, 2019. The exception would be the extension of the 

application of the Disability-Based Limitation of Treas. Reg. §1.432(e)(9)-1(d)(4) to the Beneficiaries of 

Participants whose benefit is not subject to any suspension of benefits due to the Disability-Based 

Limitation.

The first step of the recalculation shall be applied to the monthly benefit of each Participant who retired 

with an annuity starting date prior to January 1, 2013. The Participant's monthly benefit shall be recalculated to apply the early retirement reduction factors that would have been applicable to the 

Participant's age at retirement had the Participant retired subject to the same Plan provisions that apply to 

monthly benefits with an annuity starting date on or after January 1, 2013. Similarly, Beneficiaries 

presently receiving monthly benefits shall have their benefits recalculated to apply the early retirement 

reduction factors that would have been applicable on or after January 1, 2013 to the accrued benefit of the 

Participant on whom the Beneficiary's benefit is based. Lastly, the monthly benefit of Alternate Payees 

with a separate interest pension benefit that commenced prior to January 1, 2013 shall be re-calculated to 

apply the early retirement reduction factors that would have been applicable to the Alternate Payee's age 

at the commencement of the Alternate Payee's monthly benefit had the Alternate Payee commenced his or 

her monthly benefits subject to the same Plan provisions that applied to benefits with an annuity starting 

date on or after January 1, 2013.

Although the first step of the recalculation is a uniform elimination of any and all early retirement 

subsidies, due to the fact that the amount of any available early retirement subsidy was modified a number 

of times prior to its final elimination effective January 1, 2013, the first step impacts those Participants 

(and their Beneficiaries) who retired prior to January 1, 2013 differently depending on a number of 

factors, including the age at which they retired, their years of service and the early retirement subsidy 

available when they retired. The supporting documentation in Checklist Item #12 illustrates this impact.

Thus, following the application of this first step, effectively, all Participants, Beneficiaries and Alternate 

Payees with a separate interest pension benefit shall have been subject to the application of a uniform set 

of early retirement reduction factors, if applicable due to the commencement of benefits prior to 

attainment of Normal Retirement Age (age 62). Pursuant to the Plan's provisions, as amended, those 

SWORCCPP2018-000003
Document #2.1

Participants, Beneficiaries and Alternate Payees with a separate interest pension benefit with an annuity 

starting date on or after January 1, 2013 were and are already subject to those same early retirement 

reduction factors, if applicable due to the commencement of benefits prior to attainment of Normal 

Retirement Age.

The second step of the recalculation shall be an eight percent (8%) reduction of the monthly benefit of 

every Participant, Beneficiary and Alternate Payee with a separate interest pension benefit. 

With respect to Alternate Payee's with a shared interest pension benefit, the proposed reduction of 

benefits would impact the Alternate Payee differently depending on whether the Alternate Payee's 

assigned benefit was expressed in the form of a percentage of the Participant's monthly benefit or a 

specified dollar amount. Simply, the Alternate Payee with a shared interest assigned benefit in the form of 

a percentage of the Participant's monthly benefit will continue to receive their assigned percentage of the 

Participant's recalculated monthly benefit.

An Alternate Payee with an assigned benefit in the form of a specified dollar amount shall continue to 

receive the specified dollar amount regardless of the reduction of the Participant's monthly benefit, unless 

the reduced benefit is insufficient to satisfy the Alternate Payee's assigned benefit. If the Participant's 

recalculated reduced benefit is insufficient to satisfy the Alternate Payee's assigned benefit, then the 

Alternate Payee shall receive all of the Participant's recalculated reduced benefit.

The recalculation shall not be applied to accrued benefits earned on or after March 31, 2019.

The recalculation of all accrued benefits and all monthly benefits shall be limited by Section 

432(e)(9)(D)(i),(ii), and (iii) of the Internal Revenue Code of 1986, as amended, as described in the 

response to Checklist Item #8.

In addition, the Board of Trustees elected to expand the application of the Disability Based Limitation as 

permitted and described in V.A.2 of the preamble to the Final Regulations, Treas. Reg. § 1.432(c)(9)-1, 

issued April 28, 2016, to include the Beneficiaries of Participants whose benefit is not subject to any 

suspension of benefits due to the Disability-Based Limitation.

SWORCCPP2018-000004
Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 316127287 

Checklist Item #3 – 2.03 Penalties of Perjury Statement 

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 Revenue Procedure 2017-43. 

Attached as Document 3.1 is a penalties-of-perjury statement signed by Mr. Steve Schramm, Authorized 

Trustee. 

SWORCCPP2018-000005
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 3.1 

PENALTY OF PERJURY STATEMENT 

Under penalties of perjury, I, Steve Schramm, Sccreta1y of the Board of Trustees for the Southwest Ohio 

Regional Council of Carpenters Pension Plan, declare that I have examined this request, including 

accompanying documents, and, to the best of my knowledge and belief, the request contains all relevant 

facts relatin to the re uest and such facts are true correct and com lete. 

Authorized Trustee Representative for the 

Southwest Ohio Regional Council of 

Carpenters Pension Plan 

Document #3 - 1 -

SWORCCPP2018-000006 
Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

Checklist Item #4 – 2.04 Public Disclosure Authorization 

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 Revenue Procedure 2017-43. 

Attached as Document 4.1 is a statement signed by Mr. Steve Schramm, Authorized Trustee, 

acknowledging that the application and the application's supporting material will be publicly disclosed on 

the Treasury Department's website. 

SWORCCPP2018-000007
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 4.1 

ACKNOWLEDGMENT OF PUBLIC DISCLOSURE 

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan, 

acknowledges that pursuant to §432(e)(9)(G)(ii) of the Internal Revenue Code of 1986, as amended, this 

application for approval ofthe proposed suspension of benefits and all accompanying supporting material, 

will be publicly disclosed through publication on the United States Department ofTreasury website. 

Authorized Trustee Representative for the 

Southwest Ohio Regional Council of 

Carpenters Pension Plan 

Document #4 - 1 -

SWORCCPP2018-000008 
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #5 – 3.01 Plan Actuary's Certification of Critical and Declining Status 

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 the Revenue Procedure 2017-43. 

The Plan actuary's certification of critical and declining status is attached as Document 5.1, titled 2018 

Actuarial Certification of Funded Status. The supporting illustrations requested by Section 3.01 are set 

forth in Exhibit IV of the Supplemental Actuarial Information document attached to the response to 

Checklist Item #6. 

SWORCCPP2018-000009
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 5.1 

The 2018 Actuarial Certification of Funded Status for the Southwest Ohio Regional Council of 

Carpenters Pension Plan is attached. 

Document #5.1 

SWORCCPP2018-000010
2018 ACTUARIAL CERTIFICATION OF FUNDED STATUS 

As Required under IRC § 432(b)(3) asAdded by the Pension Protection Act of2006 

Plan Identification 

Southwest Ohio Regional Council ofCarpenters Pension Plan ("Plan") 

700 Tower Drive, Suite 300 

Troy, MI 48098-2808 

(248) 813-9800 

EIN/PN: 31-6127287/001 

Plan Year. January 1, 2018 - December 31, 2018 

Information on Plan Status 

As of January 1, 2018, I hereby certify that the Plan is Critical and Declining as defined by the Pension 

Protection Act of 2006 (PPA) as amended by the Multiemployer Pension Reform Act of 2014 (MPRA) 

and is meeting the annual standards required under its updated Rehabilitation Plan which was designed to 

forestall the Plan's insolvency. 

This certification bas been prepared based on the Plan's January 1, 2017 Actuarial Valuation and 

unaudited December 31, 2017 financial statements. The January 1, 2017 Actuarial Valuation was 

projected to January 1, 2018 for determination ofthe Plan's funded percentage and additional projections 

oflater years were used to determine the Plan's year ofinsolvency. 

Anticipated future Plan contributions and liabilities are based on 2,150,000 hours worked per year and 

participants exiting the Plan are assumed to be replaced by new entrants. Future scheduled withdrawal 

liability payments are also reflected. All other assumptions used, along with the Plan Provisions reflected 

in this determination, are included with this certification. 

Actuarial Certification 

I hereby certify that our projection of the Plan's most recent Actuarial Valuation presents fairly the 

actuarial position ofthe Plan as ofJanuary 1, 2018. In my opinion, the assumptions used to determine the 

Plan's 2018 PPA funding status are individually reasonable based on Plan experience and represent my 

best estimate of anticipated future experience under the Plan. The projection of the January 1, 2017 

Actuarial Valuation has been performed in accordance with generally accepted actuarial principles and 

practices and the undersigned meets the qualification standards ofthe American Academy of Actuaries 

necessary to render an actuarial opinion. 

Respectfully submitted, 

~ . .... A 

Enrollment Number: 17-07856 

Cuni, Rust & Strenk 

4555 Lake Forest Drive, Suite 620 

Cincinnati, OH 45242 

(513) 891-0270 

March 29, 2018 

CUNI, RUST & ST RENK 

SWORCCPP2018-000011 
I - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - :============-========

I '----------------------------------------------------------- ~---------------

Illustration Supporting 2018 Pension Protection Act of 2006 (PPA) Actuarial Certification of StatusPlan Name: Southwest Ohio Regional Council of Carpenters Pension Plan EIN: 31-6127287PN: 0012018 PPA Funding Status = Critical and Declining.2018 PPA Funded Percentage < 80%, Projected Funding Deficiency in 2018, and Projected Insolvency in 2036.

Actuarial PPA PPA Prior

1/1 Value of Accrued Funded 12/31 Hourly Minimum Expected 

Plan Assets Liability

% Credit Contribution Required Hours Expected 

Year (1) (2) (1) / (2) Balance Rate Contribution Worked Contribution

2017 $226,849,805 $460,087,441 49.3% ($448,392) $6.95 $30,230,666 2,505,946 $17,361,905 

2018 $219,267,902 $470,144,789 46.6% ($14,052,296) $6.95 $45,221,933 2,150,000 $14,907,144 

2019 $216,523,547 $391,202,045 55.3% ($31,269,819) $6.95 $62,821,254 2,150,000 $14,902,144 

2020 $213,949,741 $386,701,482 55.3% ($49,428,742) $6.95 $81,188,986 2,150,000 $14,897,144 

2021 $212,483,805 $387,087,823 54.9% ($68,380,284) $6.95 $99,593,299 2,150,000 $14,897,144 

2022 $208,686,895 $386,839,199 53.9% ($87,364,402) $6.95 $116,216,065 2,150,000 $14,897,144 2023 $201,355,639 $385,997,395 52.2% ($104,510,848) $6.95 $130,501,520 2,150,000 $14,897,144 

2024 $193,081,930 $384,559,799 50.2% ($119,246,348) $6.95 $146,298,051 2,150,000 $14,897,144 

2025 $183,890,593 $382,574,480 48.1% ($135,540,529) $6.95 $164,160,334 2,150,000 $14,897,144 

2026 $173,707,532 $380,014,505 45.7% ($153,965,541) $6.95 $182,125,929 2,150,000 $14,897,144 

2027 $162,602,580 $376,963,170 43.1% ($172,497,120) $6.95 $202,464,875 2,150,000 $14,897,144 

2028 $150,519,299 $373,368,550 40.3% ($193,476,819) $6.95 $223,788,796 2,150,000 $14,897,144 

2029 $137,471,621 $369,290,539 37.2% ($215,472,524) $6.95 $246,233,993 2,150,000 $14,897,144 

2030 $123,496,049 $364,791,792 33.9% ($238,624,829) $6.95 $269,201,427 2,150,000 $14,807,144 

2031 $108,500,219 $359,915,246 30.1% ($262,408,658) $6.95 $285,941,771 2,150,000 $14,797,144 

2032 $92,585,483 $354,703,923 26.1% ($279,686,701) $6.95 $302,133,088 2,150,000 $14,797,144 

2033 $75,757,290 $349,179,512 21.7% ($296,388,105) $6.95 $318,372,450 2,150,000 $14,797,144 

2034 $57,963,841 $343,339,747 16.9% ($313,139,068) $6.95 $334,108,606 2,150,000 $14,797,144 

2035 $39,225,269 $337,220,551 11.6% ($329,370,972) $6.95 $350,083,227 2,150,000 $14,797,144 

2036 $19,523,016 $330,847,233 5.9% ($345,848,854) $6.95 $367,619,509 2,150,000 $14,797,144 

(1) January 1, 2017 Actuarial Valuation results.(2) Estimated based on the Plan's December 31, 2017 financial statements.
Illustration Documenting Development of Anticipated Future Plan Contributions

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287

PN: 001

1/1 Total Average Withdrawal

Plan Total Base Contribution Contribution Liability

Year Contributions Contributions Base Units Rate Payments

2016 $17,502,825 $16,466,922 2,392,616 $6.88 $1,035,903

2017 $17,361,905 $17,246,905 2,505,946 $6.88 $115,000

2018 $14,907,144 $14,797,144 2,150,000 $6.88 $110,000

2019 $14,902,144 $14,797,144 2,150,000 $6.88 $105,000

2020 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2021 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2022 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2023 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2024 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2025 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2026 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2027 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2028 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2029 $14,897,144 $14,797,144 2,150,000 $6.88 $100,000

2030 $14,807,144 $14,797,144 2,150,000 $6.88 $10,000

2031 $14,797,144 $14,797,144 2,150,000 $6.88 $0

2032 $14,797,144 $14,797,144 2,150,000 $6.88 $0

2033 $14,797,144 $14,797,144 2,150,000 $6.88 $0

2034 $14,797,144 $14,797,144 2,150,000 $6.88 $0

2035 $14,797,144 $14,797,144 2,150,000 $6.88 $0

2036 $14,797,144 $14,797,144 2,150,000 $6.88 $0

SWORCCPP2018-000013
 

 

 

 

 

 

 

Summary of Plan Provisions 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

1. Effective Date: January 1, 1999. 

2. Plan Year: January 1st through December 31st 

. 

3. Covered Employees: All Employees covered by the Collective Bargaining 

Agreement. 

4. Eligibility: 500 Hours of Service (200 Hours if first Hour of 

Service was completed before December 31, 2001). 

5. Vesting Service: 1 Year for each Plan Year in which 1,000 or more 

Hours of Service are earned. 1

/10 of a Year is earned 

for each 100 Hours of Service less than 1,000 to a 

minimum of 100 Hours of Service. 

6. Credited Service: 1 Year for each Plan Year in which 1,500 Hours of 

Service are earned at the base journeyman rate 

prorated for Hours other than 1,500. 

7. Normal Retirement: 

a. Eligibility 

b. Monthly Benefit 

Age 62 and 5th anniversary of Plan participation. 

Credit per Year of Credited Service:

 Effective Date Credit

 01/01/1999 - 12/31/2001 $99 

 01/01/2002 - 05/31/2003 $80 

 06/01/2003 and later $50 

1 

SWORCCPP2018-000014
 

 

 

 

 

 

 

 

 

Summary of Plan Provisions 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

8. Early Retirement: 

a. Eligibility 

b. Monthly Benefit 

Age 55 and 5 Years of Vesting Service. 

Calculated as for Normal Retirement actuarially 

reduced from age 62. 

9. Vested Retirement: 

a. Eligibility 

b. Monthly Benefit 

5 Years of Vesting Service. 

Calculated as for Normal or Early Retirement. 

10. Total and Permanent Disability: 

a. Eligibility 

b. Monthly Benefit 

Total and Permanent Disability and 5 Years of 

Vesting Service. 

Calculated as for Early Retirement payable at 

commencement of Social Security disability benefits 

actuarially reduced from age 55. 

11. Trade Disability: 

a. Eligibility 

b. Monthly Benefit 

Trade Disability and 5 Years of Vesting Service. 

Calculated as for Normal Retirement payable 

immediately actuarially reduced for early 

commencement. 

2

SWORCCPP2018-000015
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Summary of Plan Provisions 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

12. Pre-Retirement Death: 

a. Eligibility Married and 5 Years of Vesting Service. 

b. Monthly Benefit Calculated as for Early Retirement reflecting a 50% 

Joint & Survivor Annuity payment form with death 

immediately after Early Retirement. 

13. Payment Forms: 

a. Normal Life Annuity for single participants and an 

Actuarially Equivalent 100% Joint & Survivor 

Annuity (QJSA) for married participants. 

b. Optional Actuarially Equivalent 50% or 75% Joint & 

Survivor Annuity (QOSA), or a 10-Year Certain & 

Life Annuity. 

14. Actuarial Equivalency: UP 1984 Mortality Table at 7.00%. 

15. Employer Contributions: Effective Date 

06/01/2009 

06/01/2010 

06/01/2011 

07/01/2012 

07/01/2013 

06/01/2014 

06/01/2015 

Hourly Rate 

$5.20 

$5.70 

$5.95 

$6.20 

$6.45 

$6.70 

$6.95 

16. Changes Since Last Year: None. 

3 

SWORCCPP2018-000016
 

 

 

 

 

 

 

 

 

 

 

 

Summary of Actuarial Assumptions and Methods 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

1. Interest Rates: 6.40%/3.05% (Funding/Current Liability). 

2. Mortality Rates: 

a. Funding 

i. Non-Disabled RP-2014 with Blue Collar adjustment. 

ii. Disabled RP-2014 Disabled Retiree. 

iii. Base Year Adjustment 2006 using Scale MP-2014. 

iv. Future Projections Projected generationally using Scale MP-2016. 

b. Current Liability 2017 Combined Static Mortality Table. 

3. Retirement Rates: 

a. Actives Age Rate

 55 0.20

 56-58 0.15

 59-60 0.10

 61 0.25

 62 0.35

 63 0.20

 64 0.25

 65-69 0.50

 70 1.00 

b. Terminated Vesteds Age Rate

 55-60 0.05

 61-62 0.30

 63-69 0.20

 70 1.00 

4

SWORCCPP2018-000017
 

 

 

 

 

 

 

 

 

 

Summary of Actuarial Assumptions and Methods 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

4. Disability Rates: Age 

25 

35 

45 

55 

65 

Rate 

0.0012

0.0020

0.0042

0.0110

0.0000 

5. Termination Rates: 

Age 

25 

35 

45 

55 

65 

< 3 Years 

of Service 

0.3500 

0.3500 

0.3500 

0.3500 

0.3500 

> 3 Years 

of Service 

0.1188

0.1190

0.1003

0.1461

0.0000 

6. Actuarial Cost Method: Unit Credit. 

7. Number of Hours Worked: 1,400 in 2018; 1,275 per year thereafter. 

8. Expense Load: $1,800,000 in 2018; $1,000,000

increased 3.0% per year thereafter. 

 in 2019 and 

9. Payment Form Selection: Payment Form % Electing 

Joint & 100% Survivor 32% 

Joint & 50% Survivor 16% 

Single Life Annuity 52% 

5 

SWORCCPP2018-000018
 

Summary of Actuarial Assumptions and Methods 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

10. Actuarial Value of Assets: Market Value of Assets minus a decreasing fraction 

(

4

/5 , 3/5 , 2/5 and 1/5 ) of each of the preceding 4 years’ 

gains and (losses). A gain/(loss) for a year is equal 

to the actual return minus the expected return using 

the funding interest rate. The Actuarial Value of 

Assets is adjusted to be within 80% and 120% of the 

Market Value of Assets. 

11. Changes Since Last Year: The retirement rates, hours worked and expense load 

were updated and the percent married assumption 

was changed to a payment form selection. 

6 

SWORCCPP2018-000019
 

 

 

 

 

Rationale for Selection of Significant Actuarial Assumptions 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

PN: 001 

1. Interest Rate: Based on the Plan’s target asset allocation, reflecting 

asset class future return expectations as determined 

by the Plan’s investment consultant and publically 

available inflation expectations, anticipated risk 

premiums, and associated long-term capital market 

assumptions. 

2. Mortality Rates: RP-2014 table used as base rates. Blue Collar 

adjustment used to reflect expected workforce 

mortality experience. RP-2014 Disabled Retiree 

table used to reflect expected disabled mortality 

experience. Both RP-2014 tables are adjusted to 

base year 2006 to reflect the mortality experience 

used to develop the RP-2014 table and for expected 

generational mortality improvement. Other 

adjustments are based on the Plan’s most recent 

experience study, Society of Actuaries mortality 

studies, and expected generational mortality 

improvement from 2006 base year using Scale MP2016. 

3. Retirement Rates: Based on the Plan’s most recent experience study. 

4. Hours Worked: The expected hours worked have been developed 

based on information provided by the Board of 

Trustees. 

5. Termination/Disability Rates: Based on the Plan’s most recent experience study. 

6. Payment Form Selection: Based on the Plan’s most recent experience study 

and anticipated changes in the payment forms 

available. 

7 

SWORCCPP2018-000020
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #6 – 3.02 Plan Actuary's Certification that the Plan is Projected to Avoid Insolvency 

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 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 3.02 of Revenue Procedure 2017-43. 

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 insolvency 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 

is attached as Document 6.1. The assumptions on which the certification is based are described in 

Exhibit XIV of the Supplemental Actuarial Information document attached as Document 6.1. 

SWORCCPP2018-000021
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 6.1 

Supplemental Actuarial Information for the Southwest Ohio Regional Council of Carpenters Pension Plan 

application for Suspension of Benefits under the Multiemployer Pension Reform of Act of 2014, effective 

as of March 31, 2019, is attached. 

Document #6.1 

SWORCCPP2018-000022
Southwest Ohio Regional Council of Carpenters 

Pension Plan 

Supplemental Actuarial Information 

Suspension ofBenefits Under the Multiemployer Pension Reform Act of2014 

Effective as ofMarch 31, 2019 

CUNI, RUST & STRENK 

SWORCCPP2018-000023 
CUNI, RUST & STRENK 

ACTUARIAL CONSULTING 

June 28, 2018 

Board ofTrustees 

Southwest Ohio Regional Council ofCarpenters Pension Plan 

Dear Trustees: 

As requested, this Report provides the Supplemental Actuarial Information outlined in Revenue 

Procedure 2017-43 for submission of an application to suspend benefits under the Multiemployer 

Pension Reform Act of2014 (MPRA). This information has been prepared based on our understanding 

ofthe Trustees' Pension Recovery Plan effective March 31, 2019 submitted on behalfofthe Southwest 

Ohio Regional Council ofCarpenters Pension Plan ("Plan") and IR.C §432(e)(9). 

The methods employed and the results developed are intended solely for the purpose of demonstrating 

that the proposed benefit suspensions outlined in the application are reasonably estimated to enable the 

Plan to avoid insolvency. The Plan provisions, assumptions and methods used in this application, 

except where otherwise stated, are summarized in Exhibit XIll. Determinations for purposes other than 

those expressly stated may be significantly different from the results shown in this Report. 

The information presented in this Report is based on the Plan's participant data as ofJanuary 1, 2017 

(summarized in Exhibit XII) and unaudited financials as of March 31 , 2018. In preparing this Report, 

we have relied on the Plan Administrator's representations that the information that they have supplied 

is both accurate and complete. The expected contribution base units have been developed based on 

information provided by the Board of Trustees. If any of this information is inaccurate or incomplete, 

the results shown in this Report could materially change. 

Based on the information available, the proposed benefit suspensions effective March 31, 2019 

outlined in the Trustee's Pension Recovery Plan are reasonably estimated to enable the Plan to avoid 

insolvency within the meaning ofIR.C §4l 8E assuming the proposed suspensions continue indefinitely. 

I hereby certify that the Plan's most recent Actuarial Valuation and Actuarial Certification of Plan 

Status fairly present the actuarial position of the Plan. In my opinion, the assumptions used to 

determine Plan liabilities and costs are individually reasonable based on Plan experience and represent 

my best estimate of anticipated future experience under the Plan. The projections and calculations 

shown in this Report have been performed in accordance with generally accepted actuarial principles 

and practices and the undersigned meets the qualification standards of the American Academy of 

Actuaries necessary to render an actuarial opinion. 

Respectfully submitted, 

Jason C. Birkle, EA, MAAA, ASA M. R. Rust, EA, MAAA, ASA 

Consulting Actuary President 

TELEPHONE (513) 891-0270 4555 LAKE FOREST DRIVE SUITE 620 

CINCINNATI, OH 45242 

FAX (513) 792-3082 

® 

SWORCCPP2018-000024 
Table of Contents 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Exhibit I Past Experience for Certain Critical Assumptions Exhibit II Development of Projected December 31, 2018 Market Value of Assets Exhibit III Projected Total Contribution Base Units and Average Contribution Rates Exhibit IV Deterministic Projection of Current Plan without Proposed Suspension Exhibit V Deterministic Projection of Proposed Suspension Exhibit VI Deterministic Projection of Similar But Smaller Proposed Suspension Exhibit VII Deterministic Projection of Proposed Suspension: Assuming 1.00% Lower Annual Rate of Return Exhibit VIII Deterministic Projection of Proposed Suspension: Assuming 2.00% Lower Annual Rate of Return Exhibit IX Deterministic Projection of Proposed Suspension: Assuming Negative 1.83% Trend in Annual Contribution BExhibit X Deterministic Projection of Proposed Suspension: Assuming Negative 2.83% Trend in Annual Contribution BExhibit XI Deterministic Projection of Funded Percentage of Proposed Suspension Exhibit XII Participant Information Exhibit XIII Plan Provisions, Assumptions & Methods 
Exhibit I: Past Experience for Certain Critical Assumptions 

Southwest Ohio Regional Council of Carpenters Pension Plan 

1/1 Total Average Withdrawal 

Plan Total Contribution Contribution Liability Rate of Return 

Year Contributions Base Units Rate Payments on Plan Assets 

2008 $18,925,867 2,928,547 $5.98 $1,402,501 (25.9%) 2009 $12,225,138 2,423,298 $4.79 $607,864 14.9% 

2010 $11,205,337 1,966,833 $5.57 $247,051 10.6% 

2011 $13,040,000 2,092,816 $5.80 $894,188 0.8% 

2012 $14,614,870 2,305,944 $6.18 $357,833 10.1% 

2013 $13,712,995 2,091,252 $6.34 $458,286 14.2% 

2014 $15,436,128 2,239,505 $6.76 $301,582 7.2% 

2015 $17,760,186 2,544,244 $6.88 $263,450 2.8% 

2016 $17,502,825 2,392,616 $6.88 $1,035,903 9.8% 2017 $17,172,581 2,479,566* $6.88 $107,233 12.4% 

Average Base Unit Trend (2008-2017): (1.83%) 

* Estimated based on contributions provided by the Plan's Auditor as of December 31, 2017. 
 

 

 

 

 

 

 

 

 

 

 

Exhibit II: Development of Projected December 31, 2018 Market Value of Assets 

Southwest Ohio Regional Council of Carpenters Pension Plan 

The table below shows the actual change in the Market Value of Assets from January 1, 2016 through 

March 31, 2018 and projects the Market Value of Assets from April 1, 2018 to December 31, 2018. The 

projection incorporates the following information: 

 The Market Value of Assets as of January 1, 2016 and January 1, 2017 are based on the financial 

statements as of those dates from the Plan’s auditor. The January 1, 2018 asset value is based on cash flows 

from the unaudited financial statements provided by the Plan Administrator. 

 Cash flow items through December 31, 2016 are from the financial statements from the Plan’s Auditor. 

Cash flow items through March 31, 2018 are from the unaudited financial statements provided by the Plan 

Administrator. Withdrawal liability payments and 2017 contribution amounts are based on information 

provided by the Plan’s Auditor. 

 Investment returns from January 1, 2016 through March 31, 2018 are the net total of income on 

investments in the period shown. 

 Estimated employer contributions from April 1, 2018 through December 31, 2018 are the total expected 

contributions of $14,797,144 (based on an hours assumption of 2,150,000 and average 2016 contribution 

rate of $6.88) reduced by the contributions already received between January 1, 2018 and March 31, 2018. 

 Estimated benefit payments from April 1, 2018 through December 31, 2018 are the total expected benefit 

payments of $31,665,681 for the 2018 Plan Year reduced by actual benefit payments already made between 

January 1, 2018 and March 31, 2018. 

 Estimated administrative expenses from April 1, 2018 through December 31, 2018 are based on the total 

expected administrative expenses for the 2018 Plan Year ($1,800,000) reduced by the administrative 

expenses already incurred between January 1, 2018 and March 31, 2018. 

 Investment returns from April 1, 2018 through December 31, 2018 are based on the assumed net 

investment return of 6.64% during that period. 

January 1, 2016 to January 1, 2017 to January 1, 2018 to April 1, 2018 to 

December 31, 20161 December 31, 20172 March 31, 20182 December 31, 20183 

1. Market Value of Assets 

(Beginning of Period) $ 213,252,642 $ 218,949,354 $ 229,662,167 $ 222,727,391 

2. Employer Contributions 16,466,922 17,065,348 3,953,060 10,844,084 

3. Withdrawal Liability 

Payments 1,035,903 107,233 27,500 82,500 

4. Benefit Payments (30,693,089) (30,831,426) (7,784,857) (23,880,824) 

5. Administrative Expenses (1,302,554) (1,751,108) (291,683) (1,508,317) 

6. Investment Returns 20,189,530 26,122,766 (2,838,796) 10,649,315 

7. Market Value of Assets 

(End of Period) $ 218,949,354 $ 229,662,167 $ 222,727,391 $ 218,914,149 

1

 Audited Financials 

2

 Unaudited Financials 

3

 Projected 

SWORCCPP2018-000027
Exhibit III: Projected Total Contribution Base Units and Average Contribution Rates 

Southwest Ohio Regional Council of Carpenters Pension Plan 

1/1 Total Average 1/1 Total 

Plan Total Contribution Contribution Plan Total Contribution 

Year Contributions Base Units Rate Year Contributions Base Units 

2017 $17,065,348* 2,479,566** $6.88 2036 $14,797,144 2,150,000 

2018 $14,797,144 2,150,000 $6.88 2037 $14,797,144 2,150,000 2019 $14,797,144 2,150,000 $6.88 2038 $14,797,144 2,150,000 2020 $14,797,144 2,150,000 $6.88 2039 $14,797,144 2,150,000 2021 $14,797,144 2,150,000 $6.88 2040 $14,797,144 2,150,000 2022 $14,797,144 2,150,000 $6.88 2041 $14,797,144 2,150,000 2023 $14,797,144 2,150,000 $6.88 2042 $14,797,144 2,150,000 2024 $14,797,144 2,150,000 $6.88 2043 $14,797,144 2,150,000 2025 $14,797,144 2,150,000 $6.88 2044 $14,797,144 2,150,000 2026 $14,797,144 2,150,000 $6.88 2045 $14,797,144 2,150,000 2027 $14,797,144 2,150,000 $6.88 2046 $14,797,144 2,150,000 2028 $14,797,144 2,150,000 $6.88 2047 $14,797,144 2,150,000 2029 $14,797,144 2,150,000 $6.88 2048 $14,797,144 2,150,000 2030 $14,797,144 2,150,000 $6.88 2049 $14,797,144 2,150,000 2031 $14,797,144 2,150,000 $6.88 2050 $14,797,144 2,150,000 2032 $14,797,144 2,150,000 $6.88 2033 $14,797,144 2,150,000 $6.88 2034 $14,797,144 2,150,000 $6.88 2035 $14,797,144 2,150,000 $6.88 

* Contributions from the unaudited financials as of December 31, 2017. ** Estimated based on contributions provided by the Plan's Auditor as of December 31, 2017. 
Exhibit IV: Deterministic Projection of Current Plan without Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning January 1, 2017 through December 31, 2036. 

2017 * 2018 2019 20

1. Market Value at beginning of year $218,949,354 $229,662,167 $218,914,149 $214,

2. Contributions 17,065,348 ** 14,797,144 14,797,144 14,

3. Withdrawal liability payments *** 107,233 110,000 105,000 

4. Benefit payments 

a. Current retirees and beneficiaries 29,779,123 29,446,477 28,894,128 28,

b. Terminated vested participants 622,068 1,040,552 1,519,524 2,c. Current actives 430,235 1,178,652 1,922,070 2,

d. New entrants 0 0 0 

e. Total 30,831,426 31,665,681 32,335,722 32,

5. Administrative expenses 1,751,108 1,800,000 1,000,000 1,

6. Investment earnings 26,122,766 7,810,519 13,933,739 13,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $229,662,167 $218,914,149 $214,414,310 $208,

8. Available resources: (1)+(2)+(3)-(5)+(6) $260,493,593 $250,579,830 $246,750,032 $241,

9. Solvency Ratio: (8)÷(4e) 8.45 7.91 7.63 

2022 2023 2024 20

1. Market Value at beginning of year $202,627,667 $195,350,180 $187,114,106 $177,

2. Contributions 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments *** 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 26,534,194 25,698,653 24,834,975 23,

b. Terminated vested participants 3,126,973 3,688,183 4,206,149 4,c. Current actives 4,219,398 4,918,180 5,598,685 6,

d. New entrants 0 3,091 12,381 

e. Total 33,880,565 34,308,107 34,652,190 35,

5. Administrative expenses 1,092,727 1,125,509 1,159,274 1,

6. Investment earnings 12,798,661 12,300,398 11,741,180 11,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $195,350,180 $187,114,106 $177,940,966 $167,

8. Available resources: (1)+(2)+(3)-(5)+(6) $229,230,745 $221,422,213 $212,593,156 $202,

9. Solvency Ratio: (8)÷(4e) 6.77 6.45 6.14 

* Based on unaudited December 31, 2017 Financials ** Estimated based on contributions provided by the Plan's Auditor as of December 31, 2017 *** All withdrawal liability payments are from prior withdrawals; no assumed future withdrawals 
Exhibit IV: Deterministic Projection of Current Plan without Proposed Suspension (continued) 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning January 1, 2017 through December 31, 2036. 

2027 2028 2029 20

1. Market Value at beginning of year $156,635,357 $144,501,182 $132,024,997 $118,

2. Contributions 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments *** 100,000 100,000 100,000 4. Benefit payments 

a. Current retirees and beneficiaries 22,169,722 21,250,473 20,322,548 19,

b. Terminated vested participants 5,732,726 6,198,264 6,614,032 7,c. Current actives 7,453,313 8,006,250 8,513,849 8,

d. New entrants 96,531 145,424 201,601 e. Total 35,452,292 35,600,411 35,652,030 35,

5. Administrative expenses 1,266,770 1,304,773 1,343,916 1,

6. Investment earnings 9,687,743 9,531,855 8,639,124 7,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $144,501,182 $132,024,997 $118,565,319 $104,

8. Available resources: (1)+(2)+(3)-(5)+(6) $179,953,474 $167,625,408 $154,217,349 $139,

9. Solvency Ratio: (8)÷(4e) 5.08 4.71 4.33 

2032 2033 2034 20

1. Market Value at beginning of year $88,476,244 $71,930,381 $54,321,631 $35,

2. Contributions 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments *** 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 17,507,282 16,565,911 15,624,774 14,

b. Terminated vested participants 7,627,534 7,918,315 8,141,920 8,c. Current actives 9,848,919 10,249,325 10,633,777 11,

d. New entrants 425,475 518,724 619,585 

e. Total 35,409,210 35,252,275 35,020,056 34,

5. Administrative expenses 1,468,533 1,512,589 1,557,967 1,

6. Investment earnings 5,534,736 4,358,970 3,110,012 1,7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $71,930,381 $54,321,631 $35,650,764 $15,

8. Available resources: (1)+(2)+(3)-(5)+(6) $107,339,591 $89,573,906 $70,670,820 $50,

9. Solvency Ratio: (8)÷(4e) 3.03 2.54 2.02 

*** All withdrawal liability payments are from prior withdrawals; no assumed future withdrawals 
Exhibit V: Deterministic Projection of Proposed Suspension

Southwest Ohio Regional Council of Carpenters Pension Plan

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049.

2018 * 2019 2020 2021 2022 

1. Market Value at beginning of year $222,727,391 $218,914,149 $219,549,498 $221,265,742 $222,526

2. Contributions 10,844,084 14,797,144 14,797,144 14,797,144 14,797

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 1004. Benefit payments

a. Current retirees and beneficiaries 22,336,856 24,113,082 21,908,485 21,206,611 20,467

b. Terminated vested participants 733,122 1,439,550 1,914,966 2,398,960 2,894c. Current actives 810,846 1,810,344 2,498,676 3,236,648 3,923

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,362,976 26,322,127 26,842,219 27,285

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1,092

6. Investment earnings 10,649,315 14,096,181 14,171,227 14,267,186 14,335

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $218,914,149 $219,549,498 $221,265,742 $222,526,953 $223,381

8. Available resources: (1)+(2)+(3)-(5)+(6) $242,794,973 $246,912,474 $247,587,869 $249,369,172 $250,666

9. Solvency Ratio: (8)÷(4e) 10.17 9.02 9.41 9.29 

2024 2025 2026 2027 2028 

1. Market Value at beginning of year $223,806,688 $223,839,585 $223,438,858 $222,680,818 $221,545

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,797

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 1004. Benefit payments

a. Current retirees and beneficiaries 18,962,731 18,204,149 17,418,617 16,644,563 15,857

b. Terminated vested participants 3,883,532 4,385,726 4,831,114 5,282,756 5,709c. Current actives 5,237,881 5,864,074 6,460,044 7,021,611 7,544

d. New entrants 12,542 29,980 58,577 99,078 148

e. Total 28,096,686 28,483,929 28,768,352 29,048,008 29,260

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1,304

6. Investment earnings 14,391,713 14,380,110 14,343,042 14,282,367 15,247

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $223,839,585 $223,438,858 $222,680,818 $221,545,551 $221,124

8. Available resources: (1)+(2)+(3)-(5)+(6) $251,936,271 $251,922,787 $251,449,170 $250,593,559 $250,3859. Solvency Ratio: (8)÷(4e) 8.97 8.84 8.74 8.63 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the application

 is submitted and ends with the last day of the plan year that includes that first day.
Exhibit V: Deterministic Projection of Proposed Suspension (continued)

Southwest Ohio Regional Council of Carpenters Pension Plan

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049.

2030 2031 2032 2033 2034 

1. Market Value at beginning of year $220,500,220 $219,615,257 $218,597,060 $217,493,941 $216,311

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,797

3. Withdrawal liability payments 10,000 0 0 0 4. Benefit payments

a. Current retirees and beneficiaries 14,287,511 13,509,311 12,738,364 11,976,591 11,225

b. Terminated vested participants 6,452,557 6,754,136 7,019,824 7,286,454 7,491c. Current actives 8,454,347 8,871,531 9,260,922 9,617,931 9,971

d. New entrants 272,986 348,659 433,660 528,230 629

e. Total 29,467,401 29,483,637 29,452,770 29,409,206 29,319

5. Administrative expenses 1,384,233 1,425,760 1,468,533 1,512,589 1,557

6. Investment earnings 15,159,527 15,094,056 15,021,040 14,942,371 14,859

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $219,615,257 $218,597,060 $217,493,941 $216,311,661 $215,091

8. Available resources: (1)+(2)+(3)-(5)+(6) $249,082,658 $248,080,697 $246,946,711 $245,720,867 $244,410

9. Solvency Ratio: (8)÷(4e) 8.45 8.41 8.38 8.36 

2036 2037 2038 2039 2040 

1. Market Value at beginning of year $213,877,246 $212,727,575 $211,698,330 $210,823,889 $210,194

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,797

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments

a. Current retirees and beneficiaries 9,786,153 9,078,541 8,388,570 7,717,823 7,068

b. Terminated vested participants 7,766,009 7,853,177 7,913,602 7,910,844 7,896c. Current actives 10,580,380 10,825,608 11,045,523 11,224,998 11,388

d. New entrants 855,759 985,844 1,123,938 1,268,465 1,420

e. Total 28,988,301 28,743,170 28,471,633 28,122,130 27,773

5. Administrative expenses 1,652,847 1,702,432 1,753,505 1,806,110 1,860

6. Investment earnings 14,694,333 14,619,213 14,553,553 14,501,606 14,467

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $212,727,575 $211,698,330 $210,823,889 $210,194,399 $209,824

8. Available resources: (1)+(2)+(3)-(5)+(6) $241,715,876 $240,441,500 $239,295,522 $238,316,529 $237,5989. Solvency Ratio: (8)÷(4e) 8.34 8.37 8.40 8.47 
Exhibit V: Deterministic Projection of Proposed Suspension (continued)

Southwest Ohio Regional Council of Carpenters Pension Plan

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049.

2042 2043 2044 2045 2046 

1. Market Value at beginning of year $209,775,668 $210,141,506 $210,971,245 $212,364,356 $214,376

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,797

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments

a. Current retirees and beneficiaries 5,843,716 5,268,970 4,723,183 4,208,037 3,724

b. Terminated vested participants 7,770,404 7,644,799 7,485,371 7,306,623 7,093c. Current actives 11,553,304 11,589,314 11,557,763 11,488,899 11,389

d. New entrants 1,753,387 1,935,524 2,124,163 2,322,254 2,532

e. Total 26,920,811 26,438,607 25,890,480 25,325,813 24,741

5. Administrative expenses 1,973,585 2,032,793 2,093,777 2,156,590 2,221

6. Investment earnings 14,463,090 14,503,995 14,580,224 14,697,134 14,858

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $210,141,506 $210,971,245 $212,364,356 $214,376,231 $217,069

8. Available resources: (1)+(2)+(3)-(5)+(6) $237,062,317 $237,409,852 $238,254,836 $239,702,044 $241,810

9. Solvency Ratio: (8)÷(4e) 8.81 8.98 9.20 9.46 

2048 2049

1. Market Value at beginning of year $220,491,722 $224,732,247

2. Contributions 14,797,144 14,797,144

3. Withdrawal liability payments 0 0

4. Benefit payments

a. Current retirees and beneficiaries 2,859,841 2,479,308

b. Terminated vested participants 6,610,366 6,339,460c. Current actives 11,079,992 10,871,747

d. New entrants 2,982,296 3,215,806

e. Total 23,532,495 22,906,321

5. Administrative expenses 2,356,565 2,427,262

6. Investment earnings 15,332,441 15,654,252

7. Market Value at end of year:

(1)+(2)+(3)-(4e)-(5)+(6) $224,732,247 $229,850,060

8. Available resources: (1)+(2)+(3)-(5)+(6) $248,264,742 $252,756,381

9. Solvency Ratio: (8)÷(4e) 10.55 11.03
Exhibit VI: Deterministic Projection of Similar but Smaller Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2018 * 2019 2020 2021 20

1. Market Value at beginning of year $222,727,391 $218,914,149 $219,123,632 $220,239,044 $220

2. Contributions 10,844,084 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 22,310,654 24,472,120 22,373,265 21,670,688 20,

b. Terminated vested participants 743,104 1,464,197 1,950,995 2,445,976 2,

c. Current actives 827,066 1,839,053 2,552,310 3,305,526 4,

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,775,370 26,876,570 27,422,190 27,

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1,

6. Investment earnings 10,649,315 14,082,709 14,124,838 14,180,068 14,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $218,914,149 $219,123,632 $220,239,044 $220,833,166 $220,

8. Available resources: (1)+(2)+(3)-(5)+(6) $242,794,973 $246,899,002 $247,115,614 $248,255,356 $248,

9. Solvency Ratio: (8)÷(4e) 10.17 8.89 9.19 9.05 

2024 2025 2026 2027 20

1. Market Value at beginning of year $220,572,210 $219,725,989 $218,369,258 $216,576,919 $214,

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 19,417,015 18,653,025 17,860,459 17,078,538 16,

b. Terminated vested participants 3,964,178 4,477,706 4,933,169 5,394,996 5

c. Current actives 5,346,199 5,984,298 6,591,435 7,163,394 7,

d. New entrants 12,627 30,161 58,896 99,567 

e. Total 28,740,019 29,145,190 29,443,959 29,736,495 29,

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1,

6. Investment earnings 14,155,928 14,085,367 13,984,350 13,854,578 14,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $219,725,989 $218,369,258 $216,576,919 $214,325,376 $212,

8. Available resources: (1)+(2)+(3)-(5)+(6) $248,466,008 $247,514,448 $246,020,878 $244,061,871 $242,

9. Solvency Ratio: (8)÷(4e) 8.65 8.49 8.36 8.21 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the application

 is submitted and ends with the last day of the plan year that includes that first day. 
Exhibit VI: Deterministic Projection of Similar but Smaller Proposed Suspension (continued) 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2030 2031 2032 2033 20

1. Market Value at beginning of year $210,708,916 $208,390,857 $205,835,518 $203,086,282 $200

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments 10,000 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 14,690,400 13,899,723 13,115,333 12,340,300 11,

b. Terminated vested participants 6,591,134 6,899,503 7,171,170 7,443,769 7,

c. Current actives 8,621,895 9,046,335 9,442,337 9,805,327 10,

d. New entrants 274,069 349,976 435,228 530,067 

e. Total 30,177,498 30,195,537 30,164,068 30,119,463 30,

5. Administrative expenses 1,384,233 1,425,760 1,468,533 1,512,589 1,

6. Investment earnings 14,436,528 14,268,814 14,086,221 13,890,220 13,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $208,390,857 $205,835,518 $203,086,282 $200,141,594 $197,

8. Available resources: (1)+(2)+(3)-(5)+(6) $238,568,355 $236,031,055 $233,250,350 $230,261,057 $227,

9. Solvency Ratio: (8)÷(4e) 7.91 7.82 7.73 7.64 

2036 2037 2038 2039 20

1. Market Value at beginning of year $193,812,813 $190,518,198 $187,202,737 $183,892,393 $180,

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 10,102,628 9,377,855 8,670,265 7,981,548 7,

b. Terminated vested participants 7,934,104 8,023,243 8,085,039 8,082,266 8

c. Current actives 10,783,282 11,032,106 11,255,070 11,436,777 11,

d. New entrants 858,456 988,868 1,127,290 1,272,149 1,

e. Total 29,678,470 29,422,072 29,137,664 28,772,740 28,

5. Administrative expenses 1,652,847 1,702,432 1,753,505 1,806,110 1,

6. Investment earnings 13,239,558 13,011,899 12,783,681 12,558,596 12,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $190,518,198 $187,202,737 $183,892,393 $180,669,283 $177,

8. Available resources: (1)+(2)+(3)-(5)+(6) $220,196,668 $216,624,809 $213,030,057 $209,442,023 $205,

9. Solvency Ratio: (8)÷(4e) 7.42 7.36 7.31 7.28 
Exhibit VI: Deterministic Projection of Similar but Smaller Proposed Suspension (continued) 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2042 2043 2044 2045 20

1. Market Value at beginning of year $174,548,871 $171,785,821 $169,285,350 $167,134,310 $165

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14,

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 6,052,841 5,460,075 4,896,623 4,364,308 3,

b. Terminated vested participants 7,938,845 7,810,522 7,647,635 7,465,007 7,

c. Current actives 11,767,306 11,802,635 11,769,115 11,697,606 11,

d. New entrants 1,758,144 1,940,668 2,129,692 2,328,185 2,

e. Total 27,517,136 27,013,900 26,443,065 25,855,106 25,

5. Administrative expenses 1,973,585 2,032,793 2,093,777 2,156,590 2,

6. Investment earnings 11,930,527 11,749,078 11,588,658 11,453,689 11,

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $171,785,821 $169,285,350 $167,134,310 $165,373,447 $164,

8. Available resources: (1)+(2)+(3)-(5)+(6) $199,302,957 $196,299,250 $193,577,375 $191,228,553 $189,

9. Solvency Ratio: (8)÷(4e) 7.24 7.27 7.32 7.40 

2048 2049 

1. Market Value at beginning of year $163,193,663 $162,876,318 

2. Contributions 14,797,144 14,797,144 3. Withdrawal liability payments 0 0 4. Benefit payments 

a. Current retirees and beneficiaries 2,968,922 2,574,482 

b. Terminated vested participants 6,753,628 6,476,837 

c. Current actives 11,276,967 11,063,553 

d. New entrants 2,989,502 3,223,436 

e. Total 23,989,019 23,338,308 

5. Administrative expenses 2,356,565 2,427,262 

6. Investment earnings 11,231,095 11,228,789 

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $162,876,318 $163,136,681 

8. Available resources: (1)+(2)+(3)-(5)+(6) $186,865,337 $186,474,989 

9. Solvency Ratio: (8)÷(4e) 7.79 7.99 
Exhibit VII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 1.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2018 * 2019 2020 2021 2

1. Market Value at beginning of year $222,727,391 $217,327,837 $215,749,905 $215,132,079 $213

2. Contributions 10,844,084 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 22,336,856 24,113,082 21,893,698 21,192,265 20

b. Terminated vested participants 733,122 1,439,550 1,914,890 2,398,887 2

c. Current actives 810,846 1,810,344 2,498,676 3,236,648 3

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,362,976 26,307,264 26,827,800 27

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1

6. Investment earnings 9,063,003 11,882,900 11,822,294 11,772,112 11

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $217,327,837 $215,749,905 $215,132,079 $213,912,635 $212

8. Available resources: (1)+(2)+(3)-(5)+(6) $241,208,661 $243,112,881 $241,439,343 $240,740,435 $239

9. Solvency Ratio: (8)÷(4e) 10.10 8.88 9.18 8.97 

2024 2025 2026 2027 2

1. Market Value at beginning of year $209,774,456 $206,860,797 $203,348,450 $199,308,219 $194

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 18,949,909 18,191,907 17,406,989 16,633,583 15

b. Terminated vested participants 3,883,469 4,385,666 4,831,058 5,282,704 5

c. Current actives 5,237,881 5,864,074 6,460,044 7,021,611 7

d. New entrants 12,542 29,980 58,577 99,078 

e. Total 28,083,801 28,471,627 28,756,668 29,036,976 29

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1

6. Investment earnings 11,432,272 11,256,188 11,049,167 10,812,476 11

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $206,860,797 $203,348,450 $199,308,219 $194,714,093 $190

8. Available resources: (1)+(2)+(3)-(5)+(6) $234,944,598 $231,820,077 $228,064,887 $223,751,069 $219

9. Solvency Ratio: (8)÷(4e) 8.37 8.14 7.93 7.71 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the applic

 is submitted and ends with the last day of the plan year that includes that first day. 
Exhibit VII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 1.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2030 2031 2032 2033 2

1. Market Value at beginning of year $185,894,329 $180,769,880 $175,260,720 $169,400,800 $163

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 10,000 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 14,278,649 13,501,197 12,731,005 11,971,067 11

b. Terminated vested participants 6,452,518 6,754,101 7,019,793 7,286,427 7

c. Current actives 8,454,347 8,871,531 9,260,922 9,617,931 9

d. New entrants 272,986 348,659 433,660 528,230 

e. Total 29,458,500 29,475,488 29,445,380 29,403,655 29

5. Administrative expenses 1,159,274 1,425,760 1,468,533 1,512,589 1

6. Investment earnings 10,686,181 10,594,944 10,256,849 9,897,566 9

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $180,769,880 $175,260,720 $169,400,800 $163,179,266 $156

8. Available resources: (1)+(2)+(3)-(5)+(6) $210,228,380 $204,736,208 $198,846,180 $192,582,921 $185

9. Solvency Ratio: (8)÷(4e) 7.14 6.95 6.75 6.55 

2036 2037 2038 2039 2

1. Market Value at beginning of year $149,754,126 $142,615,230 $135,239,539 $127,638,263 $119

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 9,782,698 9,075,695 8,386,281 7,716,037 7

b. Terminated vested participants 7,765,992 7,853,163 7,913,591 7,910,834 7

c. Current actives 10,580,380 10,825,608 11,045,523 11,224,998 11

d. New entrants 855,759 985,844 1,123,938 1,268,465 1

e. Total 28,984,829 28,740,310 28,469,333 28,120,334 27

5. Administrative expenses 1,159,274 1,702,432 1,753,505 1,806,110 1

6. Investment earnings 8,208,063 8,269,907 7,824,418 7,367,408 6

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $142,615,230 $135,239,539 $127,638,263 $119,876,371 $111

8. Available resources: (1)+(2)+(3)-(5)+(6) $171,600,059 $163,979,849 $156,107,596 $147,996,705 $139

9. Solvency Ratio: (8)÷(4e) 5.92 5.71 5.48 5.26 
Exhibit VII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 1.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2042 2043 2044 2045 2

1. Market Value at beginning of year $103,865,148 $95,709,818 $87,490,048 $79,268,020 $71

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 5,843,096 5,268,627 4,723,070 4,208,107 3

b. Terminated vested participants 7,770,399 7,644,796 7,485,368 7,306,621 7

c. Current actives 11,553,304 11,589,314 11,557,763 11,488,899 11

d. New entrants 1,753,387 1,935,524 2,124,163 2,322,254 2

e. Total 26,920,186 26,438,261 25,890,364 25,325,881 24

5. Administrative expenses 1,159,274 2,032,793 2,093,777 2,156,590 2

6. Investment earnings 5,126,986 5,454,140 4,964,969 4,476,106 3

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $95,709,818 $87,490,048 $79,268,020 $71,058,799 $62

8. Available resources: (1)+(2)+(3)-(5)+(6) $122,630,004 $113,928,309 $105,158,384 $96,384,680 $87

9. Solvency Ratio: (8)÷(4e) 4.56 4.31 4.06 3.81 

2048 2049 

1. Market Value at beginning of year $54,737,504 $46,665,672 

2. Contributions 14,797,144 14,797,144 3. Withdrawal liability payments 0 0 4. Benefit payments 

a. Current retirees and beneficiaries 2,860,242 2,479,764 

b. Terminated vested participants 6,610,366 6,339,460 

c. Current actives 11,079,992 10,871,747 d. New entrants 2,982,296 3,215,806 

e. Total 23,532,896 22,906,777 

5. Administrative expenses 1,159,274 2,427,262 6. Investment earnings 1,823,194 2,542,452 

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $46,665,672 $38,671,229 

8. Available resources: (1)+(2)+(3)-(5)+(6) $70,198,568 $61,578,006 

9. Solvency Ratio: (8)÷(4e) 2.98 2.69 
Exhibit VIII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 2.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2018 * 2019 2020 2021 2

1. Market Value at beginning of year $222,727,391 $215,737,979 $211,978,639 $209,088,989 $205

2. Contributions 10,844,084 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 22,336,856 24,113,082 21,893,698 21,192,265 20

b. Terminated vested participants 733,122 1,439,550 1,914,890 2,398,887 2

c. Current actives 810,846 1,810,344 2,498,676 3,236,648 3

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,362,976 26,307,264 26,827,800 27

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1

6. Investment earnings 7,473,145 9,701,492 9,550,470 9,403,742 9

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $215,737,979 $211,978,639 $209,088,989 $205,501,175 $201

8. Available resources: (1)+(2)+(3)-(5)+(6) $239,618,803 $239,341,615 $235,396,253 $232,328,975 $228

9. Solvency Ratio: (8)÷(4e) 10.03 8.75 8.95 8.66 

2024 2025 2026 2027 2

1. Market Value at beginning of year $196,341,247 $190,776,498 $184,521,247 $177,647,529 $170

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 18,949,909 18,191,907 17,406,989 16,633,583 15

b. Terminated vested participants 3,883,469 4,385,666 4,831,058 5,282,704 5

c. Current actives 5,237,881 5,864,074 6,460,044 7,021,611 7

d. New entrants 12,542 29,980 58,577 99,078 

e. Total 28,083,801 28,471,627 28,756,668 29,036,976 29

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1

6. Investment earnings 8,781,182 8,513,284 8,215,680 7,889,465 8

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $190,776,498 $184,521,247 $177,647,529 $170,130,392 $162

8. Available resources: (1)+(2)+(3)-(5)+(6) $218,860,299 $212,992,874 $206,404,197 $199,167,368 $192

9. Solvency Ratio: (8)÷(4e) 7.79 7.48 7.18 6.86 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the applic

 is submitted and ends with the last day of the plan year that includes that first day. 
Exhibit VIII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 2.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2030 2031 2032 2033 2

1. Market Value at beginning of year $154,928,495 $146,434,569 $137,434,653 $127,960,056 $117

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 10,000 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 14,278,649 13,501,197 12,731,005 11,971,067 11

b. Terminated vested participants 6,452,518 6,754,101 7,019,793 7,286,427 7

c. Current actives 8,454,347 8,871,531 9,260,922 9,617,931 9

d. New entrants 272,986 348,659 433,660 528,230 

e. Total 29,458,500 29,475,488 29,445,380 29,403,655 29

5. Administrative expenses 1,159,274 1,425,760 1,468,533 1,512,589 1

6. Investment earnings 7,316,704 7,104,188 6,642,172 6,156,067 5

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $146,434,569 $137,434,653 $127,960,056 $117,997,023 $107

8. Available resources: (1)+(2)+(3)-(5)+(6) $175,893,069 $166,910,141 $157,405,436 $147,400,678 $136

9. Solvency Ratio: (8)÷(4e) 5.97 5.66 5.35 5.01 

2036 2037 2038 2039 2

1. Market Value at beginning of year $96,695,546 $85,414,267 $73,754,130 $61,721,301 $49

2. Contributions 14,797,144 14,797,144 14,797,144 14,797,144 14

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 9,782,698 9,075,695 8,386,281 7,716,037 7

b. Terminated vested participants 7,765,992 7,853,163 7,913,591 7,910,834 7

c. Current actives 10,580,380 10,825,608 11,045,523 11,224,998 11

d. New entrants 855,759 985,844 1,123,938 1,268,465 1

e. Total 28,984,829 28,740,310 28,469,333 28,120,334 27

5. Administrative expenses 1,159,274 1,702,432 1,753,505 1,806,110 1

6. Investment earnings 4,065,680 3,985,461 3,392,865 2,783,089 2

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $85,414,267 $73,754,130 $61,721,301 $49,375,090 $36

8. Available resources: (1)+(2)+(3)-(5)+(6) $114,399,096 $102,494,440 $90,190,634 $77,495,424 $64

9. Solvency Ratio: (8)÷(4e) 3.95 3.57 3.17 2.76 
Exhibit VIII: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming 2.00% Lower Annual Rate of Return 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2042 2043 

1. Market Value at beginning of year $23,711,646 $10,474,370 

2. Contributions 14,797,144 14,797,144 3. Withdrawal liability payments 0 0 4. Benefit payments 

a. Current retirees and beneficiaries 5,843,096 5,268,627 

b. Terminated vested participants 7,770,399 7,644,796 

c. Current actives 11,553,304 11,589,314 d. New entrants 1,753,387 1,935,524 

e. Total 26,920,186 26,438,261 

5. Administrative expenses 1,159,274 2,032,793 6. Investment earnings 45,040 190,985 7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $10,474,370 Insolvent 

8. Available resources: (1)+(2)+(3)-(5)+(6) $37,394,556 $23,429,706 9. Solvency Ratio: (8)÷(4e) 1.39 0.89 
Exhibit IX: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 1.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2018 * 2019 2020 2021 2

1. Market Value at beginning of year $222,727,391 $218,914,149 $219,269,864 $220,428,739 $220

2. Contributions 10,844,084 14,526,356 14,260,523 13,999,556 13

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 22,336,856 24,113,082 21,893,698 21,192,265 20

b. Terminated vested participants 733,122 1,439,550 1,914,890 2,398,887 2

c. Current actives 810,846 1,810,344 2,498,676 3,236,648 3

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,362,976 26,307,264 26,827,800 27

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1

6. Investment earnings 10,649,315 14,087,335 14,135,616 14,186,026 14

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $218,914,149 $219,269,864 $220,428,739 $220,825,621 $220

8. Available resources: (1)+(2)+(3)-(5)+(6) $242,794,973 $246,632,840 $246,736,003 $247,653,421 $247

9. Solvency Ratio: (8)÷(4e) 10.17 9.01 9.38 9.23 

2024 2025 2026 2027 2

1. Market Value at beginning of year $219,392,758 $217,542,987 $214,883,681 $211,470,733 $207

2. Contributions 13,244,959 13,002,577 12,764,629 12,531,037 12

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 18,949,909 18,191,907 17,406,989 16,633,583 15

b. Terminated vested participants 3,883,469 4,385,666 4,831,058 5,282,704 5

c. Current actives 5,237,881 5,864,074 6,460,044 7,021,611 7

d. New entrants 12,542 29,980 58,577 99,078 

e. Total 28,083,801 28,471,627 28,756,668 29,036,976 29

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1

6. Investment earnings 14,048,345 13,903,796 13,708,965 13,464,351 14

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $217,542,987 $214,883,681 $211,470,733 $207,262,375 $203

8. Available resources: (1)+(2)+(3)-(5)+(6) $245,626,788 $243,355,308 $240,227,401 $236,299,351 $232

9. Solvency Ratio: (8)÷(4e) 8.75 8.55 8.35 8.14 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the applic

 is submitted and ends with the last day of the plan year that includes that first day. 
Exhibit IX: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 1.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2030 2031 2032 2033 2

1. Market Value at beginning of year $198,546,223 $193,060,544 $186,888,262 $180,042,337 $172

2. Contributions 11,855,596 11,638,638 11,425,651 11,216,562 11

3. Withdrawal liability payments 10,000 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 14,278,649 13,501,197 12,731,005 11,971,067 11

b. Terminated vested participants 6,452,518 6,754,101 7,019,793 7,286,427 7

c. Current actives 8,454,347 8,871,531 9,260,922 9,617,931 9

d. New entrants 272,986 348,659 433,660 528,230 

e. Total 29,458,500 29,475,488 29,445,380 29,403,655 29

5. Administrative expenses 1,159,274 1,425,760 1,468,533 1,512,589 1

6. Investment earnings 13,266,499 13,090,328 12,642,337 12,146,816 11

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $193,060,544 $186,888,262 $180,042,337 $172,489,471 $164

8. Available resources: (1)+(2)+(3)-(5)+(6) $222,519,044 $216,363,750 $209,487,717 $201,893,126 $193

9. Solvency Ratio: (8)÷(4e) 7.55 7.34 7.11 6.87 

2036 2037 2038 2039 2

1. Market Value at beginning of year $155,267,932 $145,611,207 $135,266,719 $124,214,952 $112

2. Contributions 10,611,973 10,417,774 10,227,128 10,039,972 9

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 9,782,698 9,075,695 8,386,281 7,716,037 7

b. Terminated vested participants 7,765,992 7,853,163 7,913,591 7,910,834 7

c. Current actives 10,580,380 10,825,608 11,045,523 11,224,998 11

d. New entrants 855,759 985,844 1,123,938 1,268,465 1

e. Total 28,984,829 28,740,310 28,469,333 28,120,334 27

5. Administrative expenses 1,159,274 1,702,432 1,753,505 1,806,110 1

6. Investment earnings 9,875,405 9,680,480 8,943,943 8,159,778 7

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $145,611,207 $135,266,719 $124,214,952 $112,488,258 $100

8. Available resources: (1)+(2)+(3)-(5)+(6) $174,596,036 $164,007,029 $152,684,285 $140,608,592 $127

9. Solvency Ratio: (8)÷(4e) 6.02 5.71 5.36 5.00 
Exhibit IX: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 1.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2042 2043 2044 2045 2

1. Market Value at beginning of year $86,863,065 $72,981,906 $58,368,630 $43,040,775 $26

2. Contributions 9,498,803 9,324,975 9,154,328 8,986,803 8

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 5,843,096 5,268,627 4,723,070 4,208,107 3

b. Terminated vested participants 7,770,399 7,644,796 7,485,368 7,306,621 7c. Current actives 11,553,304 11,589,314 11,557,763 11,488,899 11d. New entrants 1,753,387 1,935,524 2,124,163 2,322,254 2e. Total 26,920,186 26,438,261 25,890,364 25,325,881 24

5. Administrative expenses 1,159,274 2,032,793 2,093,777 2,156,590 26. Investment earnings 4,699,498 4,532,803 3,501,958 2,420,789 1

7. Market Value at end of year: $72,981,906 $58,368,630 $43,040,775 $26,965,896 $10

(1)+(2)+(3)-(4e)-(5)+(6) 

8. Available resources: (1)+(2)+(3)-(5)+(6) $99,902,092 $84,806,891 $68,931,139 $52,291,777 $349. Solvency Ratio: (8)÷(4e) 3.71 3.21 2.66 2.06 
Exhibit X: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 2.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2018 * 2019 2020 2021 2

1. Market Value at beginning of year $222,727,391 $218,914,149 $219,117,059 $219,967,298 $219

2. Contributions 10,844,084 14,378,384 13,971,476 13,576,083 13

3. Withdrawal liability payments 82,500 105,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 22,336,856 24,113,082 21,893,698 21,192,265 20

b. Terminated vested participants 733,122 1,439,550 1,914,890 2,398,887 2

c. Current actives 810,846 1,810,344 2,498,676 3,236,648 3

d. New entrants 0 0 0 0 

e. Total 23,880,824 27,362,976 26,307,264 26,827,800 27

5. Administrative expenses 1,508,317 1,000,000 1,030,000 1,060,900 1

6. Investment earnings 10,649,315 14,082,502 14,116,027 14,141,553 14

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $218,914,149 $219,117,059 $219,967,298 $219,896,234 $218

8. Available resources: (1)+(2)+(3)-(5)+(6) $242,794,973 $246,480,035 $246,274,562 $246,724,034 $246

9. Solvency Ratio: (8)÷(4e) 10.17 9.01 9.36 9.20 

2024 2025 2026 2027 2

1. Market Value at beginning of year $217,033,233 $214,211,835 $210,402,673 $205,655,527 $199

2. Contributions 12,455,785 12,103,286 11,760,763 11,427,934 11

3. Withdrawal liability payments 100,000 100,000 100,000 100,000 

4. Benefit payments 

a. Current retirees and beneficiaries 18,949,909 18,191,907 17,406,989 16,633,583 15

b. Terminated vested participants 3,883,469 4,385,666 4,831,058 5,282,704 5

c. Current actives 5,237,881 5,864,074 6,460,044 7,021,611 7

d. New entrants 12,542 29,980 58,577 99,078 

e. Total 28,083,801 28,471,627 28,756,668 29,036,976 29

5. Administrative expenses 1,159,274 1,194,052 1,229,874 1,266,770 1

6. Investment earnings 13,865,892 13,653,231 13,378,633 13,042,188 13

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $214,211,835 $210,402,673 $205,655,527 $199,921,903 $194

8. Available resources: (1)+(2)+(3)-(5)+(6) $242,295,636 $238,874,300 $234,412,195 $228,958,879 $223

9. Solvency Ratio: (8)÷(4e) 8.63 8.39 8.15 7.89 

* As required under revenue procedure 2017-43 3.02, the initial period shown here begins on the first day of the calendar quarter in which the applic

 is submitted and ends with the last day of the plan year that includes that first day. 
Exhibit X: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 2.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2030 2031 2032 2033 2

1. Market Value at beginning of year $187,462,790 $179,768,143 $171,146,834 $161,599,289 $151

2. Contributions 10,484,901 10,188,178 9,899,852 9,619,687 9

3. Withdrawal liability payments 10,000 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 14,278,649 13,501,197 12,731,005 11,971,067 11

b. Terminated vested participants 6,452,518 6,754,101 7,019,793 7,286,427 7

c. Current actives 8,454,347 8,871,531 9,260,922 9,617,931 9

d. New entrants 272,986 348,659 433,660 528,230 

e. Total 29,458,500 29,475,488 29,445,380 29,403,655 29

5. Administrative expenses 1,159,274 1,425,760 1,468,533 1,512,589 1

6. Investment earnings 12,428,226 12,091,761 11,466,516 10,775,878 10

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $179,768,143 $171,146,834 $161,599,289 $151,078,610 $139

8. Available resources: (1)+(2)+(3)-(5)+(6) $209,226,643 $200,622,322 $191,044,669 $180,482,265 $168

9. Solvency Ratio: (8)÷(4e) 7.10 6.81 6.49 6.14 

2036 2037 2038 2039 2

1. Market Value at beginning of year $127,062,725 $113,546,288 $99,009,369 $83,412,370 $66

2. Contributions 8,825,870 8,576,098 8,333,394 8,097,559 7

3. Withdrawal liability payments 0 0 0 0 

4. Benefit payments 

a. Current retirees and beneficiaries 9,782,698 9,075,695 8,386,281 7,716,037 7

b. Terminated vested participants 7,765,992 7,853,163 7,913,591 7,910,834 7

c. Current actives 10,580,380 10,825,608 11,045,523 11,224,998 11

d. New entrants 855,759 985,844 1,123,938 1,268,465 1

e. Total 28,984,829 28,740,310 28,469,333 28,120,334 27

5. Administrative expenses 1,159,274 1,702,432 1,753,505 1,806,110 1

6. Investment earnings 7,801,796 7,329,725 6,292,445 5,182,500 3

7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $113,546,288 $99,009,369 $83,412,370 $66,765,985 $48

8. Available resources: (1)+(2)+(3)-(5)+(6) $142,531,117 $127,749,679 $111,881,703 $94,886,319 $76

9. Solvency Ratio: (8)÷(4e) 4.92 4.44 3.93 3.37 
Exhibit X: Deterministic Projection of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Assuming Negative 2.83% Trend in Annual Contribution Base Units 

Projected Market Value of Assets and Solvency Ratio for the Plan Years beginning April 1, 2018* through December 31, 2049. 

2042 2043 

1. Market Value at beginning of year $30,082,893 $10,011,349 

2. Contributions 7,429,349 7,219,098 

3. Withdrawal liability payments 0 0 4. Benefit payments 

a. Current retirees and beneficiaries 5,843,096 5,268,627 

b. Terminated vested participants 7,770,399 7,644,796 

c. Current actives 11,553,304 11,589,314 d. New entrants 1,753,387 1,935,524 

e. Total 26,920,186 26,438,261 

5. Administrative expenses 1,159,274 2,032,793 6. Investment earnings 578,567 (30,779) 7. Market Value at end of year: 

(1)+(2)+(3)-(4e)-(5)+(6) $10,011,349 Insolvent 

8. Available resources: (1)+(2)+(3)-(5)+(6) $36,931,535 $15,166,875 9. Solvency Ratio: (8)÷(4e) 1.37 0.57 
Exhibit XI: Deterministic Projection of Funded Percentage of Proposed Suspension 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Projected Market Value of Assets and Funded Percentage for the Plan Years beginning January 1, 2018 through January 1, 2050. 

2018 2019 2020 2021 2022 

1. Value of plan assets $229,662,167 $218,914,149 $219,549,498 $221,281,090 $222,5

2. Unit credit accrued liability $470,351,320 $391,202,045 $386,701,482 $387,087,823 $386,8

3. Funded percentage: (1) ÷ (2) 48.8% 56.0% 56.8% 57.2% 

2024 2025 2026 2027 2028 

1. Value of plan assets $223,871,458 $223,921,961 $223,539,408 $222,800,110 $221,6

2. Unit credit accrued liability $384,559,799 $382,574,480 $380,014,505 $376,963,170 $373,3

3. Funded percentage: (1) ÷ (2) 58.2% 58.5% 58.8% 59.1% 

2030 2031 2032 2033 2034 

1. Value of plan assets $220,680,743 $219,817,865 $218,822,547 $217,743,155 $216,5

2. Unit credit accrued liability $364,791,792 $359,915,246 $354,703,923 $349,179,512 $343,3

3. Funded percentage: (1) ÷ (2) 60.5% 61.1% 61.7% 62.4% 

2036 2037 2038 2039 2040 

1. Value of plan assets $214,199,880 $213,076,807 $212,075,422 $211,230,248 $210,6

2. Unit credit accrued liability $330,847,233 $324,272,398 $317,531,284 $310,639,291 $303,6

3. Funded percentage: (1) ÷ (2) 64.7% 65.7% 66.8% 68.0% 

2042 2043 2044 2045 2046 

1. Value of plan assets $210,279,913 $210,682,351 $211,551,010 $212,985,577 $215,0

2. Unit credit accrued liability $289,520,568 $282,452,096 $275,433,222 $268,536,686 $261,7

3. Funded percentage: (1) ÷ (2) 72.6% 74.6% 76.8% 79.3% 

2048 2049 2050 

1. Value of plan assets $221,254,873 $225,549,395 $230,724,999 

2. Unit credit accrued liability $248,837,356 $242,697,337 $236,817,457 

3. Funded percentage: (1) ÷ (2) 88.9% 92.9% 97.4% 
 

 

 

 

 

 

 

Exhibit XII – Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan 

All Participants 

Monthly Benefit Monthly Benefit 

Age Number Before Suspension After Suspension 

Group of Lives Total Average Total Average 

< 19 0 $ 0 $ 0 $ 0 $ 0 

20-24 24 3,763 157 3,462 144 

25-29 102 22,507 221 20,724 203 

30-34 183 54,895 300 50,544 276 

35-39 282 111,531 395 102,653 364 

40-44 353 216,901 614 199,521 565 

45-49 450 366,007 813 336,650 748 

50-54 484 499,312 1,032 459,938 950 

55-59 605 664,976 1,099 607,193 1,004 

60-64 671 769,030 1,146 586,365 874 

65-69 597 674,667 1,130 468,489 785 

70-74 452 480,014 1,062 348,597 771 

75-79 456 419,947 921 374,787 822 

80 + 828 601,566 727 601,566 727 

Total 5,487 $ 4,885,117 $ 890 $ 4,160,490 $ 758 

SWORCCPP2018-000050
 

 

 

 

 

 

 

Exhibit XII – Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Active Participants 

Monthly Benefit Monthly Benefit 

Age Number Before Suspension After Suspension 

Group of Lives Total Average Total Average 

< 19 0 $ 0 $ 0 $ 0 $ 0 

20-24 24 3,763 157 3,462 144 

25-29 100 22,117 221 20,348 203 

30-34 158 48,723 308 44,825 284 

35-39 221 86,958 393 80,001 362 

40-44 231 144,334 625 132,793 575 

45-49 281 242,626 863 223,251 794 

50-54 264 307,115 1,163 282,553 1,070 

55-59 248 359,760 1,451 331,004 1,335 

60-64 140 205,949 1,471 189,478 1,353 

65-69 22 28,206 1,282 25,949 1,180 

70-74 1 1,911 1,911 1,758 1,758 

75-79 0 0 0 0 0 

80 + 0 0 0 0 0 

Total 1,690 $ 1,451,463 $ 859 $ 1,335,423 $ 790 

SWORCCPP2018-000051
 

 

 

 

 

 

 

 

Exhibit XII – Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Participants In Payment 

Monthly Benefit Monthly Benefit 

Age Number Before Suspension After Suspension 

Group of Lives* Total Average Total Average 

< 19 0 $ 0 $ 0 $ 0 $ 0 

20-24 0 0 0 0 0 

25-29 1 213 213 213 213 

30-34 2 426 213 426 213 

35-39 3 1,077 359 1,025 342 

40-44 2 770 385 673 336 

45-49 8 3,585 448 3,172 396 

50-54 22 13,190 600 12,698 577 

55-59 64 46,295 723 37,974 593 

60-64 318 385,631 1,213 233,625 735 

65-69 513 609,297 1,188 408,304 796 

70-74 442 474,045 1,072 343,086 776 

75-79 451 417,713 926 372,704 826 

80 + 818 600,504 734 600,504 734 

Total 2,644 $ 2,552,742 $ 965 $ 2,014,401 $ 762 

* Includes disabled participants and their beneficiaries. 

SWORCCPP2018-000052
 

 

 

 

 

 

 

Exhibit XII – Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Terminated Vested Participants 

Monthly Benefit Monthly Benefit 

Age Number Before Suspension After Suspension 

Group of Lives Total Average Total Average 

< 19 0 $ 0 $ 0 $ 0 $ 0 

20-24 0 0 0 0 0 

25-29 1 177 177 163 163 

30-34 23 5,746 250 5,293 230 

35-39 58 23,496 405 21,627 373 

40-44 120 71,797 598 66,056 550 

45-49 161 119,797 744 110,227 685 

50-54 198 179,008 904 164,687 832 

55-59 293 258,921 884 238,214 813 

60-64 213 177,451 833 163,262 766 

65-69 62 37,164 599 34,236 552 

70-74 9 4,059 451 3,753 417 

75-79 5 2,234 447 2,084 417 

80 + 10 1,062 106 1,062 106 

Total 1,153 $ 880,912 $ 764 $ 810,666 $ 703 

SWORCCPP2018-000053
 

 

 

 

 

 

 

Exhibit XIII: Plan Provisions 

Southwest Ohio Regional Council of Carpenters Pension Plan 

1. Effective Date: 

2. Plan Year: 

3. Covered Employees: 

4. Eligibility: 

5. Vesting Service: 

6. Credited Service: 

7. Normal Retirement: 

a. Eligibility 

b. Monthly Benefit 

January 1, 1999. 

January 1st through December 31st

. 

All Employees covered by the Collective Bargaining 

Agreement. 

500 Hours of Service (200 Hours if first Hour of 

Service was completed before December 31, 2001). 

1 Year for each Plan Year in which 1,000 or more 

Hours of Service are earned. 1

/10 of a Year is earned 

for each 100 Hours of Service less than 1,000 to a 

minimum of 100 Hours of Service. 

1 Year for each Plan Year in which 1,500 Hours of 

Service are earned at the base journeyman rate 

prorated for Hours other than 1,500. 

Age 62 and 5th anniversary of Plan participation. 

Credit per Year of Credited Service:

 Effective Date Credit

 01/01/1999 - 12/31/2001 $99 

 01/01/2002 - 05/31/2003 $80 

 06/01/2003 and later $50 

SWORCCPP2018-000054
 

 

 

 

 

 

 

 

 

 

 

Exhibit XIII: Plan Provisions 

Southwest Ohio Regional Council of Carpenters Pension Plan

 8. Early Retirement: 

a. Eligibility 

b. Monthly Benefit 

9. Vested Retirement: 

a. Eligibility 

b. Monthly Benefit 

10. Total and Permanent Disability: 

a. Eligibility 

b. Monthly Benefit 

11. Pre-Retirement Death: 

a. Eligibility 

b. Monthly Benefit 

Age 55 and 5 Years of Vesting Service. 

Calculated as for Normal Retirement actuarially 

reduced from age 62. 

5 Years of Vesting Service. 

Calculated as for Normal or Early Retirement. 

Total and Permanent Disability and 5 Years of 

Vesting Service. 

Calculated as for Early Retirement payable at 

commencement of Social Security disability benefits 

actuarially reduced from age 55 with an additional 

8% reduction after March 31, 2019. 

Married and 5 Years of Vesting Service. 

Calculated as for Early Retirement reflecting a 50% 

Joint & Survivor Annuity payment form with death 

immediately after Early Retirement. 

SWORCCPP2018-000055
 

 

 

 

 

 

 

 

 

 

Exhibit XIII: Plan Provisions 

Southwest Ohio Regional Council of Carpenters Pension Plan 

12. Payment Forms: 

a. Normal 

b. Optional 

13. Actuarial Equivalency: 

14. Employer Contributions: 

15. Proposed Benefit Suspension: 

Life Annuity for single participants and an 

Actuarially Equivalent 100% Joint & Survivor 

Annuity (QJSA) for married participants. 

Actuarially Equivalent 50% (QOSA). 

UP 1984 Mortality Table at 7.00%. 

Effective Date Hourly Rate 

06/01/2009 $5.20 

06/01/2010 $5.70 

06/01/2011 $5.95 

07/01/2012 $6.20 

07/01/2013 $6.45 

06/01/2014 $6.70 

06/01/2015 $6.95 

Described in detail in the Pension Recovery Plan. 

Benefits recalculated applying Early Retirement as it 

is determined after January 1, 2013 to age at 

retirement and then an additional 8% suspension of 

benefits to all Participants. 

SWORCCPP2018-000056
 

 

 

 

 

 

 

 

 

Exhibit XIII: Assumptions & Methods 

Southwest Ohio Regional Council of Carpenters Pension Plan

 1. Interest Rate: 

2. Investment Returns: 

2. Mortality Rates: 

a. Non-Disabled 

b. Disabled 

c.Base Year Adjustment 

d. Future Projections 

3. Retirement Rates: 

a. Actives

b. Terminated Vesteds

6.40%. 

6.64% for the first 10 years and 7.13% thereafter. 

RP-2014 with Blue Collar adjustment. 

RP-2014 Disabled Retiree. 

2006 using Scale MP-2014. 

Projected generationally using Scale MP-2016. 

Age Rate

 55 0.20

 56-58 0.15

 59-60 0.10

 61 0.25

 62 0.35

 63 0.20

 64 0.25

 65-69 0.50

 70 1.00 

Age Rate

 55-60 0.05

 61-62 0.30

 63-69 0.20

 70 1.00 

SWORCCPP2018-000057
 

 

 

 

 

 

 

 

 

 

 

Exhibit XIII: Assumptions & Methods 

Southwest Ohio Regional Council of Carpenters Pension Plan 

4. Disability Rates: Age 

25 

35 

45 

55 

65 

Rate 

0.0012

0.0020

0.0042

0.0110

0.0000 

5. Termination Rates: 

Age 

25 

35 

45 

55 

65 

< 3 Years 

of Service 

0.3500 

0.3500 

0.3500 

0.3500 

0.3500 

> 3 Years 

of Service 

0.1188

0.1190

0.1003

0.1461

0.0000 

6. Actuarial Cost Method: Unit Credit. 

7. Number of Hours Worked: 2,150,000 (1,275 per year per active participant). 

8. Expense Load: $1,800,000 in 2018; $1,000,000

increased 3.0% per year thereafter. 

 in 2019 and 

9. Payment Form Selection: Payment Form 

Joint & 100% Survivor 

Joint & 50% Survivor 

Single Life Annuity 

% Electing 

32% 

16% 

52% 

SWORCCPP2018-000058
 

 

Exhibit XIII: Assumptions & Methods 

Southwest Ohio Regional Council of Carpenters Pension Plan 

10. Proposed Benefit Suspension: Proposed Suspension summarized in the Pension 

Recovery Plan is effective March 31, 2019 and is 

applied to payments beginning April 1, 2018. All 

applicable age, guarantee and disability-based 

limitations have been applied based on our 

understanding of the Final Regulations for 

Suspension of Benefits under the Multiemployer 

Pension Reform Act of 2014. 

11. Rationale for Selection of Assumptions: Many actuarial assumptions used in this report are 

described in detail in the information included in 

response to Revenue Procedure 2017-43 Appendix 

B. The selection of other assumptions is based on 

the actuary's best estimate of future expectations 

based on the examination of recent actual results 

compared to expectations, periodic experience 

studies, industry materials, and any reasonably 

certain information available. 

. 

SWORCCPP2018-000059
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #7 – 3.03 Plan Sponsor's Determination of Projected Insolvency 

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 Revenue Procedure 2017-43. 

Attached as Document 7.1 is the Plan Sponsor's determination of projected insolvency that includes 

references to the portions of this application that include the documentation set forth in Section 5 of 

Internal Revenue Service Revenue Procedure 2017-43. 

SWORCCPP2018-000060
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 7.1 

After review of all available information and after undertaking all reasonable measures to avoid 

insolvency, the Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan 

determined that the Plan would not be projected to avoid insolvency unless benefits are suspended in 

accordance with Internal Revenue Code Section 432(e)(9)(C)(ii) as set forth in this application, and that 

such proposed suspension of benefits continues indefinitely. 

The Plan's actuary first certified that the Plan's funded status was "critical and declining" in accordance 

with Internal Revenue Code Section 432(b)(6) for the Plan Year beginning on January 1, 2015. The Plan's 

actuary certified to the Board of Trustees that the Plan would not be projected to avoid insolvency within 

the meaning of Internal Revenue Code Section 418E unless benefits are suspended in accordance with 

Internal Revenue Code Section 432(e)(9)(C)(ii) as set forth in this application, and that such proposed 

suspension of benefits continues indefinitely. The Plan actuary's certification was issued following 

continued reductions in adjustable benefits, increases in the Plan's hourly contribution rate, and 

eventually, a determination by the Board of Trustees that it had exhausted all reasonable measures to 

avoid insolvency. This application includes supporting documentation demonstrating the Plan's need to 

suspend benefits. 

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan has included 

the following documentation as required by Section 5 of Revenue Procedure 2017-43: 

1. A detailed description of the measures taken in order to avoid insolvency over the 10 

years immediately preceding the Plan Year in which this application is submitted. 

The responsive document is attached as Document 17.1 to Checklist Item #17. 

2. The following information with respect to the Plan: 

(1) For the past 10 Plan Years immediately preceding the Plan Year in which the 

application is submitted: 

(a) Contribution levels; 

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

benefit accruals; 

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

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

(e) Measures undertaken by the Plan Sponsor to retain or attract contributing 

employers. 

(2) The impact on plan solvency of the subsidies and ancillary benefits, if any, 

available to active participants. 

Document #7.1 

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

participants' industry generally. 

SWORCCPP2018-000061
 

 

 

 

 

 

 

 

 

 

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

The responsive document is attached as Document 18.1 in response to Checklist Item 

#18. 

3. A description how the factors set forth in Section 5.02 of the Revenue Procedure and the 

factors listed in §432(e)(9)(C)(ii)(VIII) (the impact of benefit and contribution levels on 

retaining active participants and bargaining groups under the plan) and 

§432(e)(9)(C)(ii)(IX) (the impact of past and anticipated contribution increases under the 

plan on employer attrition and retention levels) were taken into account (or why the 

factor was not taken into account) in the Plan Sponsor's determination that all reasonable 

measures have been taken to avoid insolvency. 

The responsive document is attached as Document 19.1 in response to Checklist Item 

#19. 

4. A description of any additional factors taken into account by the Plan Sponsor in its 

determination that all reasonable measures have been exhausted to avoid insolvency. 

The responsive document is attached as Document 19.1 in response to Checklist Item 

#19. 

Document #7.1 

SWORCCPP2018-000062
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #8 – 4.01 Demonstration that Limitations on Individual Suspensions Satisfied 

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 Revenue Procedure 2017-43. 

The demonstrations that the limitations on individual suspensions are satisfied, including 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 

are attached as Document 8.1, Demonstrations that Limitations on Individual Suspensions Are Satisfied. 

For purposes of applying the age-based and guarantee-based limitations in situations involving a 

Qualified Domestic Relations Order ("QDRO"), the calculation will depend on the terms of the QDRO. If 

the QDRO provides the Alternate Payee with a shared interest, then the age-based limitation will be based 

on the age of the participant as of the effective date of March 31, 2019. If the QDRO provides the 

Alternate Payee with a separate interest, then the age-based limitation will be based on the age of the 

Alternate Payee as of the effective date of March 31, 2019. If the QDRO provides the Alternate Payee 

with a shared interest, then the guarantee-based limitation will be based on the total benefit of the 

participant as of the effective date of March 31, 2019. If the QDRO provides the Alternate Payee with a 

separate interest, then the guarantee-based limitation will be based on the assigned benefit of the Alternate 

Payee as of the effective date of March 31, 2019. 

In addition, as required by Section 4.01(2)(a) of the Internal Revenue Service Revenue Procedure 2017-

43, the following is a description of the disability-based benefits of the Southwest Ohio Regional Council 

of Carpenters Pension Plan: 

SWORCCPP2018-000063
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Plan permitted participants who incurred a "Total and Permanent Disability" prior to July 1, 2010 and 

on whose behalf employer contributions were made to the Plan during the 12-month period immediately 

preceding the date of disability to retire with their unreduced monthly benefit. If the participant incurs a 

"Total and Permanent Disability" on or after July 1, 2010, and on whose behalf employer contributions 

were made to the Plan during the 12-month period immediately preceding the date of disability, the 

participant is entitled to retire with their monthly benefit, subject to actuarially equivalent reductions from 

his or her Normal Retirement Date (the first day of the month following attainment of age 62). Through 

July 31, 2018, "Total and Permanent Disability" means that, based on the medical evidence satisfactory to 

the Board of Trustees, a person is totally unable, as a result of bodily injury or disease, to engage in any 

further employment or gainful pursuit for the remainder of his or her life. A disability award from the 

Social Security Administration was deemed to satisfy the requirements of Total and Permanent Disability. 

The Plan was amended effective August 1, 2018 to change the definition of "Total and Permanent 

Disability" to mean that the person has been determined by the Social Security Administration to be 

totally and permanently disabled and entitled to a disability benefit under Old Age and Survivors 

Disability Insurance (OASDI) program. 

The Plan also provided for a "Trade Disability" benefit. If a participant incurred a "Trade Disability," the 

participant was entitled to commence their monthly benefit, subject to actuarially equivalent reductions 

from his or her Normal Retirement Date (the first day of the month following attainment of age 62). A 

"Trade Disability" meant that, based on medical evidence satisfactory to the Board of Trustees, a person 

is unable, as a result of bodily injury or disease, to perform any of the work described in the Collective 

Bargaining Agreement for the remainder of his or her life. The "Trade Disability" benefit was eliminated 

from the Plan effective August 1, 2018. 

Pursuant to the definition of the disability-based limitation set forth in 26 C.F.R. § 1.432(e)(9)-1(d)(4), 

and the provisions of the Southwest Ohio Regional Council of Carpenters Pension Plan, both the Total 

and Permanent Disability pension benefit and Trade Disability benefit are "benefits based on disability" 

and not subject to the proposed suspension of benefits. 

SWORCCPP2018-000064
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 8.1 

Demonstrations that Limitations on Individual Suspensions Are Satisfied 

Attached as Document 8.1 are the demonstrations that limitations on individual suspensions are satisfied. 

Document #8.1 

SWORCCPP2018-000065
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration that Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for Individual Currently Receiving Benefits 

Contingent 

Participant Beneficiary 

Date of Birth 7/9/1955 11/18/1950 

Date of Retirement 8/1/2005 8/1/2005 

Age at Retirement Date 50 years 0 months 54 years 8 months 

Age at Suspension Date 63 years 8 months 68 years 4 months 

Optional Form of Payment 50% Joint & Survivor 50% Joint & Survivor 

Annuity Annuity 

Type of Pension Early Unreduced Early Unreduced 

Current Monthly Benefit $2,302.42 $1,151.21 

Total Credited Service 27.76 27.76 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $2,302.42 $1,151.21 

Accrual Rate $82.94 $41.47 

PBGC Guaranteed Accrual Rate $35.75 $33.85 

PBGC Guaranteed Benefit $992.42 $939.75 

110% of PBGC Guaranteed Benefit $1091.66 $1033.72 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $2,302.42 $1,151.21 

Early Retirement Reduction Factor Applied at Retirement 0.00% 0.00% 

Early Retirement Reduction Factor based on Proposed 68.14% 68.14% 

Benefit Adjusted for Early Retirement $733.46 $366.73 

Base 8% Reduction $58.68 $29.34 

Benefit prior to Guarantee-Based Limitation $674.78 $337.39 

Benefit after Guarantee-Based Limitation $1,091.66 $1,033.72 

Final Monthly Benefit under Proposed Suspension $1,091.66 $1,033.72 

SWORCCPP2018-000066
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for a Future Retiree 

Participant 

Date of Birth 10/8/1963 

Normal Retirement Date 11/1/2025 

Age at Normal Retirement Date 62 years 0 months 

Age at Suspension Date 55 years 5 months 

Optional Form of Payment Not Retired 

Type of Pension Not Retired 

Monthly Benefit Earned as of Suspension Date $178.38 

Total Credited Service as of Suspension Date 7.43 

Calculation of 110% of PBGC Guarantee* 

Monthly Benefit Earned as of Suspension Date $178.38 

Accrual Rate $24.00 

PBGC Guaranteed Accrual Rate $20.75 

PBGC Guaranteed Benefit $154.22 

110% of PBGC Guaranteed Benefit $169.65 

Calculation of Monthly Benefit under Proposed Suspension 

Monthly Benefit Earned as of Suspension Date $178.38 

Base 8% Reduction $14.27 

Benefit prior to Guarantee-Based Limitation $164.11 

Benefit after Guarantee-Based Limitation $169.65 

Final Monthly Benefit under Proposed Suspension** $169.65 

* Calculated based on estimated Credited Service and accruals through Suspension Date. 

** Payable at Normal Retirement. These amounts could change based on age and form of 

payment elected at retirement. 

SWORCCPP2018-000067
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for Disabled Retiree and Contingent Beneficiary Under Age 75 

Contingent 

Participant Beneficiary 

Date of Birth 1/5/1951 3/16/1954 

Date of Retirement 10/1/2001 10/1/2001 

Age at Retirement Date 50 years 8 months 47 years 6 months 

Age at Suspension Date 68 years 2 months 65 years 0 months 

Optional Form of Payment 50% Joint & Survivor 50% Joint & Survivor 

Annuity Annuity 

Type of Pension Disability Disability 

Current Monthly Benefit $1,637.48 $818.74 

Total Credited Service 17.11 17.11 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $1,637.48 $818.74 

Accrual Rate $95.69 $47.84 

PBGC Guaranteed Accrual Rate $35.75 $35.75 

PBGC Guaranteed Benefit $611.79 $611.79 

110% of PBGC Guaranteed Benefit $672.97 $672.97 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $1,637.48 $818.74 

Benefit after Disability-Based Limitation $1,637.48 $753.24 

Final Monthly Benefit under Proposed Suspension $1,637.48 $818.74 

SWORCCPP2018-000068
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Age-Based Limitation for Retiree and Contingent Beneficiary Between Age 75 and 80 

Contingent 

Participant Beneficiary 

Date of Birth 3/4/1941 1/7/1940 

Date of Retirement 4/1/2003 4/1/2003 

Age at Retirement Date 62 years 0 months 63 years 2 months 

Age at Suspension Date 78 years 0 months 79 years 2 months 

Optional Form of Payment 75% Joint & Survivor 75% Joint & Survivor 

Annuity Annuity 

Type of Pension Normal Normal 

Current Monthly Benefit $1,948.33 $1,461.25 

Total Credited Service 13.18 13.18 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $1,948.33 $1,461.25 

Accrual Rate $147.87 $110.90 

PBGC Guaranteed Accrual Rate $35.75 $35.75 

PBGC Guaranteed Benefit $471.05 $471.05 

110% of PBGC Guaranteed Benefit $518.16 $518.16 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $1,948.33 $1,461.25 

Base 8% Reduction $155.87 $116.90 

Benefit Prior to Age-Based Limitation $1,792.46 $1,344.35 

Months from age 80 (at Suspension Date)* 24 24 

Benefit after Age-Based Limitation $1,885.98 $1,414.49 

Final Monthly Benefit under Proposed Suspension $1,885.98 $1,414.49 

* Assumes Contingent Beneficiary does not go into payment before Suspension Date. 

SWORCCPP2018-000069
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Age-Based Limitation for Future Retiree Between Age 75 and 80 

Participant 

Date of Birth 12/30/1942 

Normal Retirement Date 1/1/2005 

Age at Suspension Date 76 years 2 months 

Optional Form of Payment Not Retired 

Type of Pension Not Retired 

Monthly Benefit Earned as of Suspension Date $138.66 

Total Credited Service as of Suspension Date 6.40 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $138.66 

Accrual Rate $21.67 

PBGC Guaranteed Accrual Rate $19.00 

PBGC Guaranteed Benefit $121.60 

110% of PBGC Guaranteed Benefit $133.75 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $138.66 

Late Retirement Adjustment Factor as of Suspension Date 6.397483 

Base 8% Reduction $70.97 

Benefit Prior to Age-Based Limitation $816.10 

Months from age 80 (at Suspension Date) 46 

Benefit after Age-Based Limitation $832.66 

Final Monthly Benefit under Proposed Suspension $832.66 

* Calculated based on Credited Service and accruals through Suspension Date. 

** Payable at Normal Retirement. These amounts could change based on age and form of 

payment elected at retirement. 

SWORCCPP2018-000070
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for Retiree Under Age 75 

Participant 

Date of Birth 12/22/1950 

Date of Retirement 4/1/2008 

Age at Retirement Date 57 years 3 months 

Age at Suspension Date 68 years 3 months 

Optional Form of Payment 100% Joint & Survivor 

Annuity 

Type of Pension Early Reduced 

Current Monthly Benefit $2,070.94 

Total Credited Service 18.23 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $2,070.94 

Accrual Rate $113.58 

PBGC Guaranteed Accrual Rate $35.75 

PBGC Guaranteed Benefit $651.82 

110% of PBGC Guaranteed Benefit $717.00 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $2,070.94 

Initial Early Retirement Reduction Factor 14.25% 

Early Retirement Reduction Factor based on Proposed Suspension 61.67% 

Benefit Adjusted for Early Retirement $1,489.44 

Base 8% Reduction $119.15 

Benefit prior to Guarantee-Based Limitation $1,370.29 

Benefit after Guarantee-Based Limitation $1,370.29 

Final Monthly Benefit under Proposed Suspension $1,370.29 

SWORCCPP2018-000071
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for Retiree Under Age 75 

Participant 

Date of Birth 4/28/1950 

Date of Retirement 5/1/2012 

Age at Retirement Date 62 years 0 months 

Age at Suspension Date 68 years 11 months 

Optional Form of Payment 50% Joint & Survivor 

Annuity 

Type of Pension Normal 

Current Monthly Benefit $92.71 

Total Credited Service 10.90 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $92.71 

Accrual Rate $8.51 

PBGC Guaranteed Accrual Rate $8.51 

PBGC Guaranteed Benefit $92.71 

110% of PBGC Guaranteed Benefit $101.98 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $92.71 

Base 8% Reduction $7.42 

Benefit prior to Guarantee-Based Limitation $85.29 

Benefit after Guarantee-Based Limitation $92.71 

Final Monthly Benefit under Proposed Suspension $92.71 

SWORCCPP2018-000072
Southwest Ohio Regional Council of Carpenters Pension Plan 

Application for Benefit Suspension 

Demonstration That Limitations on Individual Suspensions are Satisfied 

Example of Guarantee-Based Limitation for Retiree Over Age 80 

Participant 

Date of Birth 1/12/1937 

Date of Retirement 8/1/2005 

Age at Retirement Date 68 years 6 months 

Age at Suspension Date 82 years 2 months 

Optional Form of Payment Single Life Annuity 

Type of Pension Normal 

Current Monthly Benefit $2,302.42 

Total Credited Service 27.76 

Calculation of 110% of PBGC Guarantee 

Current Monthly Benefit $2,302.42 

Accrual Rate $82.94 

PBGC Guaranteed Accrual Rate $35.75 

PBGC Guaranteed Benefit $992.42 

110% of PBGC Guaranteed Benefit $1091.66 

Calculation of Monthly Benefit under Proposed Suspension 

Current Monthly Benefit $2,302.42 

Base 8% Reduction $184.19 

Benefit Prior to Age-Based Limitation $2,118.23 

Months from age 80 (at Suspension Date) 0 

Benefit after Age-Based Limitation $2,302.42 

Final Monthly Benefit under Proposed Suspension $2,302.42 

SWORCCPP2018-000073
 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #9 – 4.02(1) Demonstration that Proposed Suspension is Estimated to Enable the 

Plan to Avoid Insolvency 

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 Revenue Procedure 2017-43. 

The 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 is set forth in Exhibit V of the Supplemental Actuarial Information document attached 

as Document 6.1. 

SWORCCPP2018-000074
 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #10 – 4.02(2) Illustration Utilizing Stochastic Projections 

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 not required if the plan is not required to appoint a retiree representative under 

§ 432(e)(9)(B)(v)(I) and stochastic projections were not used in making the required determination.) 

See Section 4.02(2) of Revenue Procedure 2017-43. 

The Southwest Ohio Regional Council of Carpenters Pension Plan has fewer than 10,000 participants, 

and is not the type of plan described in Section 432(e)(9)(B)(v)(I). As a result, the Plan is not required to 

appoint a retiree representative. Stochastic projections were not required to make the determination; 

therefore, the application filed on behalf of the Plan does not include any stochastic projections. 

SWORCCPP2018-000075
 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #11 – 4.03 Demonstration that Proposed Suspension is Not Projected to Materially 

Exceed Level Necessary to Avoid Insolvency 

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 Revenue Procedure 2017-43. 

The 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 

is included in Exhibit VI of the Supplemental Actuarial Information attached as Document 6.1. 

SWORCCPP2018-000076
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #12 – 4.04 Demonstration that the Proposed Benefit Suspension is Distributed 

Equitably 

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

including: 

▪ information on the effect of the suspension on the plan in the aggregate; 

▪ information on the effect of the suspension for different categories or groups; 

▪ a list of the factors taken into account; 

▪ an explanation of why none of the factors listed in § 432(e)(9)(D)(vi) were taken into account (if 

applicable); 

▪ for each factor taken into account that is not one of the factors listed in § 432(e)(9)(D)(vi), an 

explanation why the factor is relevant; and 

▪ an explanation 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 Revenue Procedure 2017-43. 

The demonstration that the proposed suspension is equitably distributed is set forth in the attached 

Document 12.1, which includes a statement of the number of participants, beneficiaries, alternate payees; 

the average monthly benefit before the suspension; the average monthly benefit after the suspension 

(determined taking into account the individual limitations); and the aggregate present value reduction in 

benefits for all individuals. 

In addition, included as an attachment to Document 12.1, are tables that illustrate the percentage reduction 

for monthly benefits as distributed between all participants, actives and retirees. 

Document 12.2 sets forth an explanation of the factors taken into account in the design and adoption of 

the proposed suspension of benefits in the "Pension Recovery Plan" adopted by the Board of Trustees of 

the Southwest Ohio Regional Council of Carpenters. 

SWORCCPP2018-000077
Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan

All ParticipantsCounts as of December 31, 2017 *

Participants

4,811

Beneficiaries

592

Alternate

Average Monthly Benefit Before Proposed SuspensionAverage Monthly Benefit After Proposed SuspensionPercentage Reduction in Average Monthly Benefit

$934$792

15.17%

$589$529

10.20%

Reduction in Present Value of Benefits Due to Proposed Suspension ** $78,182,066 $4,050,233 $2

* Based on data summarized in this application.** Represents the change in the present value of future liabilities as of January 1, 2019 between the current plan and the proposed suspens

Percentage reduction in benefits Count

No reduction 1,175

Greater than 0% but less than 10%

At least 10% but less than 20%At least 20% but less than 30%At least 30% but less than 40%At least 40% but less than 50%At least 50% but less than 60%At least 60% but less than 70%

70% or more

Total number of participants impacted by proposed suspension

Grand Total

3,612

164103154111

9471

3

4,312

5,487
Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan

Participants who received Partially Subsidized Early Retirement BenefitsCounts as of December 31, 2017 *

Participants

560

Beneficiaries

175

Alternate

Average Monthly Benefit Before Proposed SuspensionAverage Monthly Benefit After Proposed SuspensionPercentage Reduction in Average Monthly Benefit

$783$640

18.26%

$548$472

13.97%

Reduction in Present Value of Benefits Due to Proposed Suspension ** $9,636,418 $1,631,853 $

* Based on data summarized in this application.** Represents the change in the present value of future liabilities as of January 1, 2019 between the current plan and the proposed suspens

Percentage reduction in benefits Count

No reduction 225

Greater than 0% but less than 10%

At least 10% but less than 20%At least 20% but less than 30%At least 30% but less than 40%At least 40% but less than 50%At least 50% but less than 60%At least 60% but less than 70%

70% or more

Total number of participants impacted by proposed suspension

Grand Total

235

95649139

10

0

525

750
Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan

Participants who received Fully Subsidized Early Retirement Benefits (Retired Early under the Rule of 80 or Rule of 85)Counts as of December 31, 2017 *

Participants

528

Beneficiaries

63

Alternate

Average Monthly Benefit Before Proposed SuspensionAverage Monthly Benefit After Proposed SuspensionPercentage Reduction in Average Monthly Benefit

$1,953$1,203

38.40%

$1,255

$950

24.32%

Reduction in Present Value of Benefits Due to Proposed Suspension ** $50,444,622 $2,182,537 

* Based on data summarized in this application.** Represents the change in the present value of future liabilities as of January 1, 2019 between the current plan and the proposed suspens

Percentage reduction in benefits Count

No reduction 103

Greater than 0% but less than 10%

At least 10% but less than 20%At least 20% but less than 30%At least 30% but less than 40%At least 40% but less than 50%At least 50% but less than 60%At least 60% but less than 70%

70% or more

Total number of participants impacted by proposed suspension

Grand Total

81

693963729371

3

491

594
Participant Information 

Southwest Ohio Regional Council of Carpenters Pension Plan

Participants who retired on or after their Normal Retirement Date or who are not eligible for Subsidized Early Retirement BenefitsCounts as of December 31, 2017 *

Participants

3,723

Beneficiaries

354

Alternate

Average Monthly Benefit Before Proposed SuspensionAverage Monthly Benefit After Proposed SuspensionPercentage Reduction in Average Monthly Benefit

$812$757

6.80%

$490$482

1.68%

Reduction in Present Value of Benefits Due to Proposed Suspension ** $18,101,026 $235,843 $2

* Based on data summarized in this application.** Represents the change in the present value of future liabilities as of January 1, 2019 between the current plan and the proposed suspens

Percentage reduction in benefits Count

No reduction 847

Greater than 0% but less than 10%

At least 10% but less than 20%At least 20% but less than 30%At least 30% but less than 40%At least 40% but less than 50%At least 50% but less than 60%At least 60% but less than 70%

70% or more

Total number of participants impacted by proposed suspension

Grand Total

3,296

000000

0

3,296

4,143
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 12.2 

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan propose a 

suspension of benefits formula that applies a uniform series of steps to recalculate each participant or 

beneficiary's accrued benefit, effective as of March 31, 2019, whether the participant or beneficiary is 

presently in pay status or has not yet commenced payment of benefits. After consideration of the factors 

set forth below, and several possible alternative designs, the Board of Trustees determined that the 

proposed suspension of benefits set forth in this application was equitable to the Plan's participants and 

beneficiaries and the preferred implementation for a suspension of benefits for this Plan. 

The first step of the recalculation is the application of the early retirement factors, a full actuarial 

reduction, that would have been applicable to the participant's age at retirement had the participant retired 

subject to the same Plan provisions that apply to monthly benefits with an annuity starting date on or after 

January 1, 2013 (the date of the final removal of any and all subsidies for early retirement). Similarly, 

beneficiaries presently receiving monthly benefits would have their benefits recalculated to apply the 

early retirement factors that would have been applicable on or after January 1, 2013 to the accrued benefit 

of the participant on whom the beneficiary's benefit is based. 

The purpose of this first step is to "level the playing field" and eliminate any subsidy that any participant 

or beneficiary may receive from the Plan for monthly benefits going forward. Thus, for any participant 

who retired at age 62 (Normal Retirement Age) or after January 1, 2013, the first step would not result in 

any reduction of their monthly benefit because either no early retirement reduction was applicable due to 

retirement on or after age 62, or the participant or beneficiary would be or already has been subject to the 

early retirement reduction. 

The second step of the recalculation is to apply a uniform eight percent (8%) reduction to the monthly 

benefit of every participant and beneficiary. 

Each of the above steps is limited by the application of the guarantee-based limitation, described in 26 

C.F.R. §1.432(e)(9)-1(d)(2), the age-based limitation, described in 26 C.F.R. §1.432(e)(9)-1(d)(3), and the 

disability-based limitation, described in 26 C.F.R. §1.432(e)(9)-1(d)(4). 

Basically, the proposed suspension of benefits eliminates all subsidies for all participants and 

beneficiaries for any monthly payments after March 31, 2019, and then applies a uniform eight percent 

(8%) reduction. As a result of this suspension of benefits design, over ninety percent (90%) of participants 

and beneficiaries will be subject to a benefit suspension of twenty percent (20%) or less. In addition, over 

eighty-five percent (85%) of participants and beneficiaries be subject to a benefit suspension of ten 

percent (10%) or less. 

Through the analysis, consideration and adoption of the proposed suspension of benefits that the Board of 

Trustees refers to as the "Pension Recovery Plan" for the Southwest Ohio Regional Council of Carpenters 

Pension Plan, the Board of Trustees considered the following factors: 

Age and Life Expectancy 

The Board of Trustees considered the age and life expectancy of the participants and beneficiaries, noting 

the protection that the age-based limitation and the disability-based limitation provided by the 

Multiemployer Pension Reform Act of 2014, and the regulations promulgated thereunder. The Board of 

Trustees did not choose to advantage or disadvantage any participant or beneficiary based on their life 

Document #12.2 

SWORCCPP2018-000082
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

expectancy other than the removal of the subsidies for those individuals who retired prior to age 62 or 

their beneficiaries and commenced benefits prior to January 1, 2013. 

Amount of Benefit 

The Board of Trustees reviewed and considered the impact of the amount of benefit each participant had 

accrued. However, the Board of Trustees determined that a uniform percentage reduction of participants' 

accrued monthly benefit, after the elimination of the pre-2013 subsidies for those participants who retired 

prior to attaining age 62 (subject to the various statutory limitations), resulted in a more equitable 

suspension of benefits than any reduction of historical accrual rate or flat dollar reduction targeted at any 

particular group of participants or beneficiaries. 

Type of Benefit: Survivor, Normal Retirement, Early Retirement 

The Board of Trustees reviewed the possible impact of distinguishing between the various types of 

benefits. As set forth above, the Board of Trustees resolved to remove any subsidy for retirement prior to 

age 62 (Normal Retirement Age), which resulted in the imposition of early reduction factors to the 

monthly benefit of those participants, or their beneficiaries, who retired prior to January 1, 2013 and had 

not attained age 62 at retirement. However, all participants, and their beneficiaries, who retired on or after 

January 1, 2013 were already subject to those same early reduction factors. Except for the elimination of 

early retirement subsidies, the Board of Trustees did not distinguish between the types of benefit that a 

participant or beneficiary received. 

Extent to which Participant or Beneficiary is Receiving a Subsidized Benefit 

The Board of Trustees determined that the Plan would remove all subsidies from early retirement before 

the imposition of additional reductions to participants' accrued benefits. The accrued benefit is the core 

promise of the Plan, and thus, the Board of Trustees determined that it would be inequitable to continue to 

provide costly subsidies to retirees that would result in more significant reductions to other participants' 

and beneficiaries' accrued benefits. 

The Board of Trustees considered the fact that the last of all of the subsidized adjustable benefits were 

removed as of January 1, 2013, and thus, not available to any participant who retired on or after that date. 

Due to the anti-cutback rule of Internal Revenue Code §411(d)(6), significant liabilities from subsidized 

benefits existed in the form of unreduced early retirement benefits, referred to as the "Rule of 80" (and 

later, the "Rule of 85"), that allowed participants to retire with an unreduced monthly benefit after 

meeting certain requirements (i.e. that their age plus either Years of Vesting Service or continuous 

membership in the United Brotherhood of Carpenters and Joiners of America ("Union") equaled or 

exceeded 80, or later 85). 

In the absence of the approval and implementation of the proposed suspension of benefits, an additional 

$190 million would be paid over current retirees' expected lifetimes due to early retirement benefits in 

excess of what current active participants would receive if they retired today. A participant with an 

accrued benefit of $2,000 per month who retired on or after January 1, 2013 at age 55 would be subject to 

a 49.8% reduction of their monthly benefit amount. In comparison, under the previously available "Rule 

of 80," a participant who joined the Union at age 20 and worked until age 50 with an accrued benefit of 

$2,000 could have retired and received an unreduced monthly benefit for five (5) full years until age 55, 

and still receive a monthly benefit almost double that of the participant with an identical monthly benefit 

solely due to the existing subsidy. 

Document #12.2 

SWORCCPP2018-000083
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Finally, as set forth in the final regulations, 26 C.F.R. §1.432(e)(9)-1(d)(6)(iv), the application of the 

uniform set of early retirement reduction factors through the elimination of the Plan's early retirement 

subsidy does not result in different pre-suspension or post-suspension benefit formulas; therefore, the 

post-suspension benefit formula is a straightforward equitable reduction of each participant's and 

beneficiary's monthly benefit amount by eight percent (8%). 

History of Benefit Increases and Reductions 

The Board of Trustees also considered the Plan's history of benefit reductions. Prior to January 1, 2002, 

the benefit accrual rate for a Year of Credited Service was $99 per month. The benefit accrual rate for a 

Year of Credited Service was reduced to $80 for all Years of Credited Service on or after January 1, 2002. 

The Board of Trustees further reduced the benefit accrual rate to $50 per Year of Credited of Service for 

all Years of Credited Service on or after June 1, 2003. 

Along with consideration of the history of the reduction of the value of a Year of Credited Service, the 

Board of Trustees also considered the history of increases in the hourly contribution rate. In 1999, the 

contribution rate was $2.40 per hour. The rate was incrementally raised over the years to the current rate 

of $6.95 per hour. 

As a result of the reduction in the benefit accrual rate, the monthly benefit that a participant receives at 

retirement has been shrinking since 2003, and will continue to do so through 2030 (followed shortly 

thereafter by insolvency unless the proposed suspension of benefits is approved). The monthly benefit of 

a participant who worked 1,500 hours per year for 30 straight years and retired at age 62 in 2016 would 

be twenty percent (20%) less than that of a participant who worked the same amount and retired in 2000. 

Similarly, the monthly benefit of a participant who worked 1,500 hours per year for 30 straight years and 

retired at age 62 in 2030 will be forty percent (40%) less than that of a participant who worked the same 

amount and retired in 2000. These differences do not account for the time value of money (that a dollar in 

2030 will be worth less than a dollar in 2000). 

In addition, the increase in the amount of contributions made on behalf of the participants has risen over 

the same time period. A participant who retired in 2016 would have had more than twice the contributions 

made to the Plan on their behalf than a participant who worked the same amount and retired in 2000. 

Similarly, a participant who retired in 2030 would have had 3.5 times more contributed to the Plan on 

their behalf than the participant who worked the same amount and retired in 2000. 

Ultimately, the Board of Trustees decided that, subject to the various guarantee-based, age-based, and 

disability-based limitations required by law, each participant and beneficiary would have the same eight 

percent (8%) reduction applied to their monthly accrued benefit following the application of the 

standardized early retirement reduction factors. 

Any Discrepancies Between Active and Retiree Benefits 

This factor was considered and discussed in conjunction with, and with the same conclusion, as the 

history of benefit reductions set forth in the previous paragraph. 

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 

As demonstrated in the history of benefit increases and reductions above, and the summary of the actions 

taken by the Board of Trustees to avoid insolvency detailed in the response to Checklist Item #17, the 

Document #12.2 

SWORCCPP2018-000084
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

active participants who had not retired prior to January 1, 2013 have already lost the opportunity to retire 

prior to age 62 without significant reduction in their monthly benefit, and earned a smaller benefit over 

their careers despite having a significantly greater amount contributed to the Plan on their behalf. Active 

participants are aware that not all participants and beneficiaries have "shared the pain" imposed by the 

Rehabilitation Plan to date. The Board of Trustees was concerned that any perceived additional unfair 

allocation of benefit reductions to active participants would risk their rejection of the Pension Recovery 

Plan. 

Although some individuals who retired under the Rule of 80 or Rule of 85 advocated to the Board of 

Trustees for an uniform flat percentage reduction applied to all participants' benefits, without the 

standardization of early reduction retirement factors, the Board of Trustees did not feel that an increased 

reduction for thousands of active participants and beneficiaries to preserve the significant subsidies 

received by some retirees that were never available to the others was an equitable allocation of the 

necessary suspension of benefits. Further, the Board of Trustees were concerned that a significant 

majority of the participants and beneficiaries would reach the same conclusion and not support the 

proposed Pension Recovery Plan. 

Ultimately, the Board of Trustees decided that after the application of standardized early retirement 

reduction factors, each participant and beneficiary should receive a uniform eight percent (8%) reduction 

to their monthly benefit, subject to the various statutory age-based, guarantee-based, and disability-based 

limitations. 

Ease of Communication 

In addition to the statutory factors listed in Internal Revenue Code §432(e)(9)(D) set forth and described 

above, the Board of Trustees also considered the practical difficulties of communicating any adopted 

design for the suspension of benefits to the participants and beneficiaries of the Plan. 

The Board of Trustees considered various suspensions of benefits designs, including various maximum 

percentage or dollar reductions and the standardization of prior accrual rates, and concluded that the 

proposed design provided the most equitable allocation of benefit reductions and remained the best 

option. 

FACTORS THAT WERE NOT TAKEN INTO ACCOUNT 

Through the analysis, consideration and adoption of the proposed suspension of benefits that the Board of 

Trustees refers to as the "Pension Recovery Plan" for the Southwest Ohio Regional Council of Carpenters 

Pension Plan, the Board of Trustees did not consider the following factors: 

Length of Time in Pay Status 

As set forth above, the Board of Trustees' proposed elimination of the early retirement subsidies that 

caused all participants and beneficiaries to be subject to the same early retirement reduction factors. After 

applying that reduction, the Board of Trustees did not make any further distinction regarding length of 

time in pay status. 

Extent to which Participant or Beneficiary has Received Post-Retirement Benefit Increases 

The Board of Trustees did not consider or take into account the extent to which participants or 

beneficiaries received any post-retirement benefit increases. The last post-retirement increase was in 1997 

(a lump sum post-retirement payment of $700 was made to retirees in 1999, and again for $725 in 2000), 

Document #12.2 

SWORCCPP2018-000085
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

and combined with the age-based limitation, attempting to make any distinguishing adjustment would not 

have been worth the additional administrative burden. 

The Board of Trustees and the Plan's professionals were concerned that the claw back of pre-retirement 

and post-retirement increases, all of which were at least 18 years old, would cause unnecessary 

administrative difficulty trying to confirm applicable historical increases subject to reduction for 

individuals' recalculated benefits. 

Years to Retirement for Active Employees 

The Board of Trustees did not make any distinction between the age or year of retirement of any active 

participants. All active participants are subject to the same terms and conditions for retirement, including 

early retirement reduction factors, as well as benefit accrual rate and employer hourly contribution rate. 

Extent to which Benefits are Attributed to Service with an Employer that Failed to Pay its Full 

Withdrawal Liability 

As a Plan that primarily covers individuals in the building and construction industry plan, an employer 

that ceases its obligation to contribute to the Plan and does not perform work in the jurisdiction of the 

collective bargaining agreement of the type for which contributions were due within 5 years of the 

cessation of the employer's obligation to contribute to the Plan would not owe withdrawal liability 

pursuant to ERISA §4203(b). As a result, only a few employers incurred a complete withdrawal and 

ultimately failed to pay the full amount of withdrawal liability assessed, whether due to the eventual 

bankruptcy of the employer, arbitration settlement, or other reasons. None of the failures to pay the full 

amount of assessed withdrawal liability resulted in a significant loss that compelled the Board of Trustees 

to consider imposing an additional reduction on the accrued benefit or monthly payments of participants 

who worked for such an employer. 

Document #12.2 

SWORCCPP2018-000086
 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #13 – 4.05(1) Copy of Notices 

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

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

See Section 4.05(1) of Revenue Procedure 2017-43. 

Attached as Document 13.1 are copies of the notices (including redacted sample calculations that meet the 

requirements under § 432(e)(9)(F)) and accompanying correspondence provided to participants, 

beneficiaries, employers that have an obligation to contribute within the meaning of Section 4212(a) of 

ERISA, and each employee organization representing participants under the Plan. 

SWORCCPP2018-000087
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 13.1 

Copies of the correspondence and notices provided to participants, beneficiaries, employers that have an 

obligation to contribute within the meaning of Section 4212(a) of ERISA, and each employee 

organization representing participants under the Plan are attached. 

Document #13.1 

SWORCCPP2018-000088
Southwest Ohio Regional Council of Carpenters' 

Fringe Benefit Funds 

Health Fund: P.O. Box 1257, Troy, MI 48099 

Pension Fund: P.O. Box 31580, Independence, OH 44131 

Phone: 330-779-8862 

Website: www.ocbenefits.org 

June 2018 

Dear Participant, 

As you are by now aware, our Pension Plan is in Critical and Declining status. Ifwe do nothing, 

our Pension Plan is projected to run out ofmoney by 2036--meaning that all pension payments 

will stop in less than 19 years. 

However, we are not doing nothing. We have developed a Pension Recovery Plan as provided 

under the Multiemployer Pension Reform Act (MPRA). 

What is the Attached Notice of Application for Approval of a Proposed Reduction of 

Benefits? 

The Pension Plan is applying to the United States Treasmy Department for MPRA relief. MPRA 

gives Trustees ofplans like ours the ability- within certain limits-to avoid insolvency and save 

your pensions by reducing benefits of active members, retirees already collecting their pensions 

and tenninated vested participants. Our MPRA relief plan is called the Pension Recovery Plan. 

We submitted our Pension Recove1y Plan to the Treasmy Department on June 29, 2018. By law, 

we are required to send the attached notice to you. Much ofthe notice is legally required text that 

we could not change. We have put together this letter as well as the resources listed in the "Want 

More Inf01mation?" section to help you make sense of the attached notice and the Pension 

Recove1y Plan in general. 

The notice is divided into six main sections: 

1. Why is the Board ofTrustees proposing to reduce benefits? 

2. What will happen ifthe Pension Plan runs out ofmoney? 

3. How did the Board ofTrustees decide whose benefits to reduce and by how much? 

4. What are the proposed reductions in benefits? 

5. What comes next? 

6. An individualized estimate* that explains how your pension will be impacted by the 

Pension Recove1y Plan. 

* Ifyou are already collecting a pension, please remember that the amount shown in the 

individualized notice that represents your cunent benefit amount is before taxes and before any 

other deductions, so it is likely different from the amount on your monthly pension check. 

What's Next? 

Now that our Pension Recove1y Plan has been submitted to the Treasmy Department, you have 

the opportunity to review it, comment on it and, upon approval of the Treasury Department, vote 

SWORCCPP2018-0000SB0 
 

 

 

 

 

 

on whether to ratify it or not. We will continue to keep you informed throughout the Pension 

Recovery Plan process. 

Want More Information? 

We are devoting resources to helping you understand this process. 

 Pension Recovery Plan Call Center: (330) 779-8862 (Select Option 3 from the 

directory when you call) 

 Pension Recovery Plan Website: www.SORCCPensionRecovery.org. We have 

information about the Pension Recovery Plan, including FAQs, graphics and videos, as 

well as downloadable copies of documents and mailings. 

In Conclusion 

Our Pension Plan is projected to run out of money by 2036—unless we act now. That is why we 

are taking these dramatic steps. And our Pension Recovery Plan is far better than the alternatives. 

Reducing pensions for current retirees and beneficiaries is not something we ever thought we’d 

have to do. The only reason we’re even considering these changes is to prevent the Pension Plan 

from becoming insolvent, and your pension payments from being cut even more—or 

disappearing altogether. If the Pension Recovery Plan works as we expect it to, the result will be 

a Pension Plan you can count on for many years to come. 

We encourage you to carefully review the notice and all of the other materials we have prepared. 

We hope that they will help you understand the seriousness of our situation and why we need 

your support for the Pension Recovery Plan. 

Sincerely, 

The Board of Trustees 

SWORCCPP2018-000090
Southwest Ohio Regional Council of Carpenters' 

Fringe Benefit Funds 

Health Fund: P.O. Box 1257, Troy, MI 48099 

Pension Fund: P.O. Box 31580, Independence, OH 44131 

Phone: 330-779-8862 

Website: www.ocbenefits.org 

June 2018 

NOTICE OF A PROPOSED REDUCTION OF YOUR PENSION BENEFITS 

On June 29, 2018, the Board of Trustees of the Southwest Ohio Regional Council of Carpenters' Pension Plan ("Plan") 

submitted an application to the U.S. Treasury Department for approval to reduce benefits under the Plan. This type of 

benefit reduction is allowed by the Federal law called the Multiemployer Pension Reform Act of 2014. 

You are getting this notice because you have a pension benefit under the Plan. The end of this notice describes the 

proposed reduction of your monthly payments1

• This notice will also answer the following questions for you: 

1. Why is the Board of Trustees proposing to reduce benefits? 

2. What will happen if the Plan runs out of money? 

3. How did the Board of Trustees decide whose benefits to reduce and by how much? 

4. What are the proposed reductions in benefits? 

5. What comes next? 

1. Why is the Board of Trustees proposing to reduce benefits? 

The Plan's actuary estimated that, unless benefits are reduced, the Plan will not have enough money to pay benefits in 

the year 2036. This estimate is based on how much money the actuary expects the Plan to receive and to pay out each 

year. The Plan's actuary estimated that, with the reduction of benefits that the Board of Trustees has proposed, the plan 

should not run out of money. 

2. What will happen if the Plan runs out of money? 

If the Plan does not have enough money to pay benefits, then only the amount guaranteed by the Pension Benefit 

Guaranty Corporation ("PBGC") will be paid. You can find the amount of your benefit that is guaranteed by PBGC at 

the end of this notice. 

3. How did the Board of Trustees decide whose benefits to reduce and by how much? 

Under Federal law, the Board of Trustees must apply the following rules to the proposed reduction-

• The total reduction in everybody's benefits must be estimated to be large enough to keep the plan from 

running out of money but not larger than needed to do that. 

• Your monthly benefit and the benefit of your beneficiary cannot be reduced below 110% of the amount 

guaranteed by PBGC. 

• Disability benefits (as defined under the Plan) cannot be reduced. 

• The benefits of people who are at least 80 years old on April 30, 2019 and their beneficiaries cannot be 

reduced. 

• The benefits of people who are at least 75 years old on April 30, 2019 and their beneficiaries are partially 

protected, and the closer the person is to age 80 the less the benefits can be reduced. 

• The reduction of benefits must be spread fairly among the people who have a pension benefit under the 

plan. 

A version of this notice that does not include the estimate of the effect on your benefit is being sent to 

unions that represent Plan participants and to all contributing employers. 

SWORCCPP2018-00009~o 

1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In deciding whether the proposed reduction is spread fairly, the Board of Trustees took into account the following: 

 Age and Life Expectancy 

 Amount of Benefit 

 Type of Benefit: Survivor, Normal Retirement, Early Retirement 

 Extent to which participant or beneficiary is receiving a subsidized benefit 

 History of benefit increases and reductions 

 Any discrepancies between active and retiree benefits 

4. What are the proposed reductions in benefits? 

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan propose a suspension of 

benefits formula that applies a uniform series of steps to recalculate the participant or beneficiary's accrued benefit, 

effective as of March 31, 2019, whether the participant or beneficiary is presently in pay status or has not yet 

commenced payment of benefits. 

Step 1: The elimination of any subsidy for those individuals, or their beneficiaries, who retired prior to the attainment of 

age 62. The elimination of any subsidy is accomplished by the application of reduction factors for retirements prior to 

age 62, a full actuarial reduction, that would have been applicable to the participant's age at retirement had the 

participant retired subject to the same Plan provisions that apply to monthly benefits with a benefit commencement 

date on or after January 1, 2013 (the date of the final removal of any and all subsidies for retirement prior to age 62). 

Similarly, beneficiaries presently receiving monthly benefits would have their benefits recalculated to apply the same 

reduction factors for retirements prior to age 62 that would have been applicable on or after January 1, 2013 to the 

accrued benefit of the participant on whom the beneficiary's benefit is based. 

If you retired on or after attaining age 62, or you retired on or after January 1, 2013 (or have not yet retired), this step 

will not have any impact on you or your beneficiary. 

Step 2: A uniform eight percent (8%) reduction of the monthly benefit of every participant and beneficiary. 

Limitations on the application of the Steps: 

1 – Participants, and their beneficiaries, who retired and received a Disability Pension Benefit will not be subject 

to any reduction. 

2 – Participants and beneficiaries monthly benefit will not be reduced below 110% of the amount guaranteed by 

the Pension Benefit Guaranty Corporation. 

3 – Participants or beneficiaries who are receiving a monthly benefit and have reached age 80 by April 30, 2019 

will not have their benefit reduced. 

4 – Participants or beneficiaries who are receiving a monthly benefit and have reached age 75 by April 30, 2019 

will have a portion of their benefit protected from reduction. 

Alternate Payees with a separate assigned pension benefit in the Plan will have the above steps applied to their monthly 

benefit as if they were a Participant. Alternate Payees with a shared interest pension benefit in which they receive a 

percentage of each monthly benefit a Participant receives will continue to receive the same percentage of the 

Participant’s monthly benefit after application of the above steps. Alternate Payees with a shared interest pension 

benefit in which they received a fixed dollar amount from each monthly benefit a Participant receives will continue to 

receive the same fixed dollar amount unless the reduction reduces the Participant’s benefit to less than the assigned 

benefit. Alternate Payees should review their Qualified Domestic Relations Orders to determine what type of assigned 

benefit they have. Participants and Alternate Payees may adjust current QDROs by filing a new revised QDRO. 

5. What comes next? 

Approval or denial of the application by the Treasury Department 

SWORCCPP2018-000092
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Treasury Department will review the application to see whether it meets all of the legal requirements 

under Federal law. If the application meets all of those requirements, the Treasury Department is required to 

approve the application. If the application does not meet the legal requirements, the Treasury Department 

will deny the application. The Treasury Department will have until February 9, 2019 to make a decision. 

You can get information from the Treasury Department 

More information about the proposed benefit reductions and a copy of the application is available at 

www.treasury.gov/mpra. 

The application will be available on that website within 30 days after the Treasury Department receives it. The 

application includes more information about the proposed reduction, including details about: 1) the Plan 

actuary’s certification that the Plan will run out of money (that is, that the plan is in “critical and declining 

status”); 2) how the proposed reduction would satisfy the requirement that it be large enough so that the Plan 

is estimated not to run out of money, while not being larger than needed; and 3) the sensitivity of these 

estimates to the assumptions used. 

The application describes the steps the Board of Trustees has already taken to keep the Plan from running out 

of money and why the Board of Trustees believes that a benefit reduction is the only remaining option to keep 

the plan from running out of money. In addition, the application explains why the Board of Trustees believes 

that the proposed reduction is spread fairly among the people who have a pension benefit under the plan. 

The Treasury Department website will also provide updated information on the application, such as whether 

the application has been updated or withdrawn. 

For further information and assistance, you can also write to the Treasury Department at the following address: 

Department of the Treasury 

Attn: MPRA Office, Room 1001 

1500 Pennsylvania Avenue, NW 

Washington, DC 20220 

You Can Comment on the Application to Reduce Benefits 

You can submit a comment on the application by going to www.treasury.gov/mpra. Comments may also be mailed to 

the Department of the Treasury, at the address listed above. All interested parties can make comments, and the 

comments will be publicly available. 

Retiree Representative 

If a plan has 10,000 or more participants, the Board of Trustees must select a retiree representative to advocate for the 

interests of retirees, beneficiaries, and deferred vested participants as part of this process. A plan is required to pay the 

reasonable expenses of the retiree representative. 

The Board of Trustees is not required to select a retiree representative, because the Plan has fewer than 10,000 

participants. The Board of Trustees has not chosen to select a retiree representative. 

Vote on the proposed benefit reduction 

If the application for the proposed reduction of benefits is approved by the Treasury Department, then you will have 

the opportunity to vote on the proposed reduction. Unless a majority of all participants and beneficiaries of the Plan 

vote to reject the reduction, the Treasury Department must allow the reduction of benefits to take effect. This means 

that not voting counts the same as a vote to approve the reduction. 

You may contact PBGC’s Participant and Plan Sponsor Advocate by mail at Pension Benefit Guaranty Corporation, Attn: 

Participant and Plan Sponsor Advocate, 1200 K St., NW, Washington DC 20005; by telephone at (202) 326- 4448; or by 

e-mail at advocate@PBGC.gov. 

SWORCCPP2018-000093
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Your right to see Plan documents 

You may want to review Plan documents to help you understand your rights and the proposed reduction to your 

benefits. The Plan administrator must respond to your request for the following documents within 30 days: 

• The Plan document (including any amendments adopted to reflect an authorized reduction of 

benefits), trust agreement, and other documents governing the Plan (such as collective bargaining 

agreements). 

• The Plan’s most recent summary plan description (SPD or plan brochure) and any summary of material 

modifications. 

• The Plan’s Form 5500 annual reports, including audited financial statements, filed with the U.S. 

Department of Labor during the last six years. 

• The annual funding notices furnished by the Plan during the last six years. 

• Actuarial reports, including reports prepared in anticipation of the benefit reduction, furnished to 

the Plan within the last six years. 

• The Plan’s current rehabilitation plan, including contribution schedules and annual plan-sponsor 

determinations that all reasonable measures to avoid running out of money continue to be taken and 

that the Plan would run out of money if there were no benefit reductions. 

• Any quarterly, semi-annual or annual financial reports prepared for the Plan by an investment manager, 

fiduciary or other advisor and furnished to the Plan within the last six years. 

The Plan administrator may charge you the cost per page to the Plan for the cheapest way of copying documents, but 

cannot charge more than 25 cents per page. The Plan’s Form 5500 Annual Return/Report of Employee Benefit Plan is 

also available free of charge at www.dol.gov/ebsa/5500main.html. Some of the documents also may be available for 

examination, without charge, at the Plan administrator’s office, your worksite or union hall. 

Your right to challenge incorrect calculations 

If you think the Plan miscalculated the reduction to your benefits, then you have the right to submit a claim to the Plan 

to have the calculation corrected. The Plan’s summary plan description (“SPD”) tells you how to submit a claim. The 

SPD also describes your right to have a court review the Plan’s final decision on your claim. 

If you believe the information used to calculate your estimate at the end of this notice is wrong, please contact the 

Plan office at: 

Southwest Ohio Regional Council of Carpenters’ Pension Plan 

P.O. Box 31580 

Independence, OH 44131 

Phone: 330-779-8862 

SWORCCPP2018-000094
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – ACTIVE AND TERMINATED VESTED AND NONVESTED PARTICIPANTS OVER 62 

Your benefit without the proposed reduction as of January 1, 2017 in the form of single life annuity is 

$1,235.48. Under the proposed reduction your monthly benefit in the same form will be reduced to 

$1,136.641 effective March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have 14.9 years of credited service under the Plan. 

 You will be 64 years, 5 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $532.76. 

1 These amounts will be different if you take your benefit in a different form. For example, if you elect a 100% Joint 

and Survivor benefit, your reduced monthly benefit will be $931.67. 

SWORCCPP2018-000095
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – ACTIVE AND TERMINATED VESTED AND NONVESTED PARTICIPANTS UNDER 62 

If you start receiving your benefit on January 1, 2023 in the form of a Single Life Annuity, your monthly 

benefit without the proposed reduction would be $655.09. Under the proposed reduction your monthly 

benefit in the same form would be reduced to $602.681

. 

The proposed reduction is permanent. 

This is an estimate of the effect of the proposed reduction on your benefit under the Plan. It is not a 

final benefit calculation. This was done assuming that the proposed benefit reduction starts on March 

31, 2019. If the benefit reduction starts later, the effect of the proposed reduction on your benefit might 

be different. 

This estimate is based on the following information from Plan records: 

 You have 6 years of credited service under the Plan. 

 You will be 58 years, 4 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $214.50 

1 These numbers are just estimates. The actual amount you receive will depend on things like how long you work

and when you begin receiving payments. For more information, see the Summary Plan Description. 

SWORCCPP2018-000096
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – BENEFICIARIES IN PAY STATUS 

Your current monthly benefit is $1,906.46. Under the proposed reduction your monthly benefit will be 

reduced to $1,753.94 beginning on March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have 20.7 years of credited service under the Plan. 

 You will be 65 years, 2 months as April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $740.03. 

SWORCCPP2018-000097
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – BENEFICIARIES IN PAY STATUS AGES 75-80 

Your current monthly benefit is $1,491.41. Under the proposed reduction your monthly benefit will be 

reduced to $1,427.78 beginning on March 31, 2019 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have years 20.6 of credited service under the Plan. 

 You will be 77 years, 4 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $736.45. 

SWORCCPP2018-000098
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – RETIRED MEMBERS – EARLY REDUCED 

Your current monthly benefit is $1,304.31. Under the proposed reduction your monthly benefit will be 

reduced to $986.40 beginning on March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have 12.4 of credited service under the Plan. 

 You will be 69 years, 4 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $443.30. 

SWORCCPP2018-000099
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – RETIRED MEMBERS – EARLY UNREDUCED 

Your current monthly benefit is $2,302.42. Under the proposed reduction your monthly benefit will be 

reduced to $1,091.66 beginning on March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have 27.8 years of credited service under the Plan. 

 You will be 63 years, 9 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $992.42. 

SWORCCPP2018-000100
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – EXEMPTED MEMBERS 

Your monthly benefit of $254.63 would not change under the proposed reduction. 

This estimate is based on the following information from Plan records: 

 You have 15.8 years of credited service under the Plan. 

 You will be 66 years, 11 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $254.63. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $234.42. 

SWORCCPP2018-000101
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – EXEMPTED MEMBERS 

Your monthly benefit of $1,408.67 would not change under the proposed reduction. 

This estimate is based on the following information from Plan records: 

 You have 10.0 years of credited service under the Plan. 

 You will be 66 years, 1 month as of April 30, 2019. 

 The portion of your benefit that is based on disability is $1,408.67. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $357.50 

. 

SWORCCPP2018-000102
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – RETIRED MEMBERS – AGE 62 AT RETIREMENT 

Your current monthly benefit is $1,220.94. Under the proposed reduction your monthly benefit will be 

reduced to $1,123.26 beginning on March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records: 

 You have 17 years of credited service under the Plan. 

 You will be 68 years, 3 months as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $607.75. 

SWORCCPP2018-000103
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – RETIRED MEMBERS – AGE 75-80 

Your current monthly benefit is $1,948.33. Under the proposed reduction your monthly benefit will be 

reduced to $1,888.58 beginning on March 31, 2019. 

The proposed reduction is permanent. 

This estimate is based on the following information from Plan records as of January 1, 2017: 

 You have 13.2 years of credited service under the Plan. 

 You will be 78 years, 1 month as of April 30, 2019. 

 The portion of your benefit that is based on disability is $0.00. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $471.05. 

SWORCCPP2018-000104
This estimate of the effect of the proposed reduction of benefits has been prepared for: 

HOW YOUR MONTHLY PAYMENTS WILL BE AFFECTED – EXEMPTED MEMBERS 

Your monthly benefit of $2,017.17 would not change under the proposed reduction. 

This estimate is based on the following information from Plan records: 

 You have 24.1 years of credited service under the Plan. 

 You will be 87 years, 3 months as of April 30, 2019. 

PBGC Guaranteed Benefits 

If the Plan does not have enough money to pay benefits, your monthly benefit would be no larger than 

the amount guaranteed by PBGC. The amount of your monthly benefit guaranteed by PBGC is estimated 

to be $861.58. 

SWORCCPP2018-000105
 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #14 – 4.05(2) Description of Efforts to Contact Participants 

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 Revenue Procedure 2017-43. 

Attached as Document 14.1 is a narrative description of the efforts of the Board of Trustees of the 

Southwest Ohio Regional Council of Carpenters Pension Plan to contact participants, beneficiaries in pay 

status, and alternate payees regarding this application for benefit suspension. 

SWORCCPP2018-000106
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 14.1 

The notices informing participants, beneficiaries and alternate payees required by Internal Revenue Code 

§432(e)(9)(F) and the regulations thereunder will be delivered solely by United States mail. In addition, 

the Board of Trustees held two informational seminars to discuss the proposed Pension Recovery Plan. 

The first was held on December 1, 2016 at the local union hall of the Indiana / Kentucky / Ohio Regional 

Council of Carpenters located at 204 Garver Road, Monroe, Ohio. The second was held on March 16, 

2017 at the Savannah Center in West Chester Township, Ohio. Notice of these informational seminars on 

the Plan's proposed Pension Recovery Plan was mailed to all participants, beneficiaries in pay status, and 

alternate payees. As a result, the Plan’s third party administrator has an early indication of the number of 

potential individuals who will require additional efforts to locate and contact. 

The Plan's third-party administrator will work with local union officials to find additional information on 

any missing individuals, and will utilize internet search tools to attempt to locate such individuals. In 

addition, the Board of Trustees has engaged the services of a commercial locator service, Pension Benefit 

Information (www.pbinfo.com), to assist in the location of any remaining missing individuals using 

commercial and credit reporting databases. 

Through the initial 2017 filing of this Application and the preparation of this 2018 filing, the third-party 

administrator and the Plan's attorney both utilized commercial search software to attempt to locate any 

missing participants or beneficiaries over the age of 70. 

Finally, the Board of Trustees established an informative website http://sorccpensionrecovery.org/ to 

provide information to participants, beneficiaries and alternate payees through Frequently Asked 

Questions, a copy of the summary presentation from the March 16, 2017 informational seminar, 

additional graphic and factual documentation, and informational videos. 

Document #14.1 

SWORCCPP2018-000107
 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #15 – 4.05(3) Delivery of Electronic Notices 

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 Revenue Procedure 2017-43. 

The third party administrator of The Southwest Ohio Regional Council of Carpenters Pension Plan does 

not use electronic delivery of Plan notices or communications to Plan participants. The Plan is a building 

and construction industry plan, and many of the covered employees lack access to a computer during the 

ordinary course of their employment. As a result, the Plan intends to send all notices and communications 

issued in connection with this Application for Benefit Suspension by U.S. regular mail, consistent with 

previous Plan communications. 

SWORCCPP2018-000108
 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #16 – 4.05(4) List of Employers Required to Contribute 

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 Revenue Procedure 2017-43. 

Attached as Document 16.1 is a list of each employer who has an obligation to contribute under the Plan 

and each employee organization representing participants under the Plan. 

SWORCCPP2018-000109
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 16.1 

List of employers who have an obligation to contribute to the Plan 

1. 360 CONSTRUCTION COMPANY INC. 

2. 74 INSTALLATIONS, LLC. 

3. A & A MILLWRIGHT & RIGGING SVCS INC. 

4. A.J. CONSTRUCTION CO. 

5. ADVANTAGE INDUSTRIAL SYSTEMS, LLC 

6. AIC CONTRACTING, INC. 

7. AIC, INC. 

8. ALAN STONE COMPANY, INC. 

9. ALBERICI CONSTRUCTORS, INC. 

10. ALPHA & OMEGA 

11. ALTERCON CONSTRUCTION, INC. 

12. AMERICAN CONTRACTING & SERVICES INC. 

13. AMQUIP CRANE RENTAL 

14. AMW INSTALL LLC 

15. AP COM POWER, INC. 

16. AQUARIUS MARINE, LLC 

17. ARISTEO CONSTRUCTION 

20. ARISTEO INSTALLATIONS 

21. ARMSTRONG STEEL ERECTORS, INC. 

22. ATLANTIC PLANT MAINTENANCE 

23. ATLAS INDUSTRIAL CONTRACTORS LLC 

24. AUBURNDALE 

25. AZCO, INC. 

Document #16.1 

SWORCCPP2018-000110
 

 

 

26. BAKER CONCRETE CONSTRUCTION 

27. BEATY CONSTRUCTION 

28. BECDIR CONSTRUCTION CO. 

29. BERKEL & CO. CONTRACTORS, INC. 

30. BRAND ENERGY SERVICES LLC 

31. BRIGADIER CONSTRUCTION SERVICES LLC 

32. BRUNEMANN BROS. CONSTRUCTION 

33. BRUNS-GUTZWILLER 

34. BRUNSWICK BOWL & BILLIARD 

35. BUCK RUN SPECIALTIES INC. 

36. C & C INTERIORS 

37. C & N CONSTRUCTION INC 

38. C. R. MEYER & SONS COMPANY 

39. CARPENTERS FOR HIRE, INC. 

40. CARPENTERS LOCAL 2 

41. CBI MANAGEMENT 

42. CBI SERVICES 

43. CECO CONCRETE CONSTR 

44. CECO CONCRETE CONSTR KY 

45. CENTRAL CONVEYOR COMPANY 

46. CHARLES LIPPS & SON 

47. CINCINNATI FLOOR COMPANY, INC. 

48. COMBS INTERIOR SPECIALTIES 

49. COMMONWEALTH CONSTRUCTORS, INC. 

50. COMPLETE GENERAL CONSTRUCTION CO. 

51. COUSIN CONSTRUCTION 

Document #16.1 

SWORCCPP2018-000111
 

 

 

 

52. DAG CONSTRUCTION CO. 

53. DANESSA CONSTRUCTION LLC 

54. DEFCON FORCE LLC 

55. DENNEMANN/GEIMAN CONSTR 

56. DONALD R. BORG CONSTRUCTION 

57. DONLEY'S, INC. 

58. DOT CONSTRUCTION CORP. 

59. DOUBLE Z CONSTR CO. 

60. DUNCAN MACHINERY MOVERS, INC. 

61. E. S. WAGNER COMPANY 

62. EAGLE BRIDGE 

63. ELFORD, INCORPORATED 

64. EMPIRE BUILDING COMPANY 

65. ENDEAVOR CONSTRUCTION 

66. ENERFAB POWER & INDUSTRIAL, INC. 

67. ETHOSENERGY FIELD SERVICES LLC 

68. FA WILHELM CONSTRUCTION CO, INC. 

69. FAITH MILLWRIGHT & RIGGING 

70. FARNHAM EQUIPMENT COMPANY 

71. FASTDECKS, INC. 

72. FENTON RIGGING COMPANY 

73. FLOORSHOP, INC. 

74. FMS CONSTRUCTION 

75. FRED A NEMANN CO. 

76. FRYMAN-KUCK GENERAL CONT., INC. 

Document #16.1 

SWORCCPP2018-000112
 

 

 

 

77. GATEWAY CONCRETE FORMING SERVICES, INC. 

78. GATEWAY CONSTRUCTION 

79. GEISSLER ROOFING CO. INC. 

80. GEM INDUSTRIAL CONTR. CORP. 

81. GEMMA POWER SYSTEMS LLC 

82. GEORGIA DIRECT LLC 

83. GLEESON CONSTRUCTION, INC. 

84. GOEBEL FIXTURE COMPANY 

85. GOETTLE COMPANY 

86. GRANGER CONTRACTOR COMPANY 

87. GRAYCOR INDUST. CONSTR. 

88. GREAT LAKES CONSTR. CO. 

89. HALKER DRYWALL 

90. ICON INDUSTRIAL SERVICES LLC 

91. INDIANA/KENTUCKY/OHIO REG COUNCIL CARP 

92. INDUSTRIAL CONTRACTORS SKANSKA 

93. INDUSTRIAL MAINTENANCE SERVICES INC 

94. INTEGRA EXCAVATING LLC 

95. INTERIOR INSTALLATION SERVICES 

96. J.T. THORPE & SON INC 

97. JAMES HUNT CONSTRUCTION CO. 

98. JDL WARM CONSTRUCTION LLC 

99. JH WOODWORKING INSTALLATION, INC. 

100. JL KUCK GENERAL CONTRACTORS 

101. JORDIM INT'L 

102. K&M CONTRACTING OF OHIO 

Document #16.1 

SWORCCPP2018-000113
 

103. K.E. RANKLE CONST 

104. KEWAUNEE SCIENTIFIC EQUIP CORP 

105. KINGS ISLAND 

106. KIRK BROTHERS COMPANY 

107. KIRK ERECTORS 

108. KOKOSING CONSTRUCTION CO., INC. 

109. KOKOSING INDUSTRIAL INC. 

110. KRAMIG CO. 

111. LANKFORD CONSTRUCTION COMPANY 

112. LAYNE HEAVY CIVIL, INC. 

113. LEO B. SCHROEDER, INC. 

114. LESCO DESIGN & MFG. CO., INC. 

115. LILJA CORPORATION 

116. LOCK INSTALLATIONS 

117. MACY'S EXPENSE PAYABLE DEPT 

118. MAGNUM MANAGEMENT CORP 

119. MARION CONVEYOR SERVICE 

120. MARK DUFFY COMMERCIAL DIVING 

121. MAXIM CRANE WORKS 

122. McCOOL PLASTER & DRYWALL, INC. 

123. MCGRAW/KOKOSING INC. 

124. MCT SERVICES LLC 

125. MHS TECHNICAL SERVICES 

126. MIDDENDORF 

127. MIDDENDORF NIEOFF CONTRACTORS 

Document #16.1 

SWORCCPP2018-000114
 

 

 

 

 

128. MIDEAST MACHINERY MOVERS 

129. MIDWAY STORAGE & DISTRIB DBA MIDWAY MAINTENANCE 

130. MIDWEST MEDICAL SERVICE & INSTALLATION 

131. MILLER BROS. CONSTRUCTION INC. 

132. MILLWRIGHT INDUSTRIAL SERVICES 

133. MINK CONSTRUCTION CO. 

134. MODERN DAY CONCRETE CONSTR 

135. MONARCH CONSTRUCTION COMPANY 

136. MR DAVID'S FLOORING INTERNATIONAL LTD 

137. MURRAY INTERIORS 

138. NET QUEST SERVICES, INC. 

139. NEWELL MACHINERY CO., INC. 

140. NEYER CONSTRUCTION LLC 

141. NKC CONVEYOR INSTALL CO INC. 

142. NORTHEAST OHIO INTERIORS INC. 

143. NORTHSIDE CONSTRUCTION, INC. 

144. OCP CONTRACTORS, INC. 

145. OHIO BRIDGE STRIPPING, INC. 

146. OHIO CARPENTERS JOINT APPR & TRG/NE/NW/SC/SW 

147. OK INTERIORS CORP. 

148. ORBIT MOVERS & ERECTORS, INC. 

149. ORBIT SHEET METAL & MILLWRIGHT SERVICES, INC. 

150. OREN PLASTERING COMPANY 

151. PARSONS CONTRACTING 

152. PATRIOT INDUSTRIAL CONTR SVCS 

153. PC CONTRACTING, INC. 

Document #16.1 

SWORCCPP2018-000115
 

 

154. PERFORMANCE CONTRACTING, INC. 

155. PERKINS/CARMACK CONSTRUCTION 

156. PETERSON CONSTRUCTION CO. 

157. PETERSON INDUSTRIAL 

158. PIQUA STEEL CO. 

159. PLATFORM CEMENT, INC. 

160. PRECISION COOLING TOWERS 

161. PRECISION FURNISHINGS, LLC 

162. PRO SERVICES, INC. 

163. PROCRAFT FLOORING INC. 

164. PROTECTIVE COATINGS INC. 

165. PSC MILLWRIGHT SERVICES LLC 

166. PULVERIZER SERVICES, INC. 

167. QUALITY INTERIORS, INC. 

168. QUEEN CITY ACOUSTICAL INC. 

169. R & B CONTRACTING INC. 

170. R B JERGENS 

171. R. J. BEISCHEL BUILDING CO. 

172. RHECORS GENERAL CONT., INC. 

173. RICHARD GOETTLE INC. 

174. RIVERSIDE CONSTRUCTION SERVICES 

175. RUDOLPH LIBBE 

176. RUHLIN COMPANY 

177. SAFWAY SERVICES LLC 

178. SCHNABEL FOUNDATION COMPANY 

Document #16.1 

SWORCCPP2018-000116
 

 

 

179. SCHUMACHER CONSTRUCTION CO. 

180. SCHUMACHER DUGAN CONST C 

181. SCS CONSTRUCTION SERVICES 

182. SEASON CONTRACTORS INC. 

183. SHELLY & SANDS, INC. 

184. SHOOK CONSTRUCTION CO. 

185. SIEMENS GENERATION SERVICES 

186. SKILLED TRADES SERVICES 

187. SMITH CONSTRUCTION GROUP 

188. SMOOT CONSTRUCTION 

189. SOLID PLATFORMS, INC. 

190. SOUTHERN MARINE CONSTR., CO. 

191. SOUTHERN SYSTEMS INC. 

192. SPORTS SYSTEMS UNLIMITED CORP. 

193. STERLING BOILER & MECHANICAL 

194. STEVENS ENGINEERS & CONSTRUCT. 

195. STRAHM DIVISION OF SGI, INC. 

196. SUBURBAN MAINTENANCE & CONST. 

197. T & D INTERIORS 

198. TAYLOR BROS. CONST. CO., INC. 

199. TENNESSEE VALLEY IND. CORP. 

200. THE BOLDT COMPANY 

201. THE DOTSON COMPANY INC. 

202. THE PRICE ERECTING CO - DIV OF RIDGEWAY LLC 

203. THE SCHAEFER GROUP, INC. 

204. THE SELINSKY FORCE, LLC 

Document #16.1 

SWORCCPP2018-000117
 

 

 

 

 

 

205. THOMAS R. O'SHEA, INC. 

206. TKF CONVEYOR SYSTEMS DIV. OF FEDERAL EQUIPMENT 

207. TRI-K CONSTRUCTION INC. 

208. TRI-STATE BLG. CONST. TC 

209. TRI-STATE INSTALLATION 

210. TRI-STATE INTERIORS LTD. 

211. TURBINE PRO'S LLC 

212. TURNER CONSTRUCTION 

213. TUTTLE CONSTRUCTION, INC. 

214. UBC NATIONAL JOB CORP TRAINING FUND, INC. 

215. UNITED FOUNDATIONS, INC. 

216. UNITED GLASS & PANEL SYSTEMS 

217. UNIVERSAL CONTRACTING IN 

218. UNIVERSAL INSTALLATIONS PLUS 

219. UTTER CONSTRUCTION INC. 

220. VALLEY ACOUSTICS, INC. 

221. VALLEY INTERIORS SYSTEMS 

222. VECTOR INTERIORS, INC. 

223. VINE INTERIORS, LLC 

224. W. SOULE & COMPANY 

225. WEIFFENBACH MARBLE & TILE CO. 

226. WEITZ INDUSTRIAL 

227. WENGER CORPORATION 

228. WESTERN INDUSTRIAL CONTRACTORS 

229. WISE CONSTRUCTION CO., INC. 

Document #16.1 

SWORCCPP2018-000118
 

230. WOODS CONSTRUCTION, INC. 

231. ZSR CONTRACTING AND RESTORATION 

List of each employee organization representing participants under the Plan 

1. INDIANA / KENTUCKY / OHIO REGIONAL COUNCIL OF CARPENTERS 

Document #16.1 

SWORCCPP2018-000119
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #17 – 5.01 Narrative Description of Past and Current Measures to Avoid Insolvency 

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

See Section 5.01 of Revenue Procedure 2017-43. 

Attached as Document 17.1 is a narrative description of the past and current measures taken by the Board 

of Trustees to avoid insolvency of the Southwest Ohio Regional Council of Carpenters Pension Plan. 

SWORCCPP2018-000120
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 17.1 

The following sets forth a detailed description of measures taken by the Board of Trustees of the 

Southwest Ohio Regional Council of Carpenters Pension Plan ("Plan") in order to avoid insolvency over 

the ten (10) Plan Years (2008 through 2017) immediately preceding the Plan Year (2018) in which this 

application is submitted. In addition, to provide additional context and information, some information has 

been provided for Plan Years prior to 2007 demonstrating the Board of Trustees’ and the bargaining 

parties’ attempts to address the declining funded status of the Plan. 

At the beginning of the 2000 Plan Year, the Plan was funded 101% on a market basis ($363,189,521 –

Market Value of Assets / $359,511,504 – Accrued Liability) with 4,590,926 hours worked for which 

contributions were due. The hourly contribution rate was $2.40. The Plan had 3,778 active members, 

which was 52% of the 7,228 total participants and beneficiaries (including vested terminated participants, 

service retirees, disability retirees and beneficiaries). 

Despite the funding health of the Plan, the Plan had a negative 3.5% cash flow percentage for the 2000 

Plan Year, and asset investment returns were 3.7%. The negative cash flow percentage would continue to 

worsen over the next 15 years despite the remedial actions taken by the Board of Trustees to attempt to 

address the funded status of the Plan. Similarly, significant decreases over that period of time in active 

contributing participants and hours worked for which contributions were due, coupled with adverse 

investment experience, led to the current substantial underfunding despite significant reductions in 

adjustable benefits and other actions detailed in this summary. 

The Plan commenced the 2001 Plan Year with a funded percentage of 88% on a market basis 

($338,284,530 – Market Value of Assets / $383,943,182 – Accrued Liability). With asset returns of -6.8% 

in 2001, and a 26% decrease in hours worked, the Board of Trustees amended the Plan, effective January 

1, 2002, to reduce the benefit accrual rate of $99 per Year of Credited Service to $80 per Year of Credited 

Service for any Years of Credited Service on or after January 1, 2002. 

At the start of the 2002 Plan Year, the Plan's funded percentage was 78% on a market basis ($300,207,040 

– Market Value Of Assets / $383,228,868 – Accrued Liability). The Plan had a -11.3% asset return for the 

Plan Year and an additional 4.8% decrease in hours worked. In addition, the Plan had a negative cash flow 

of 6.5% for the 2002 Plan Year. In two years, the Plan's active participants decreased from 3,778 at the 

beginning of 2000 to 2,809 at the beginning of 2002. 

The Plan began the 2003 Plan Year with a funded percentage of 66% on a market basis ($250,916,369 –

Market Value of Assets / $377,813,484 – Accrued Liability). In response to the previous decline in funded 

percentage, the Board of Trustees further reduced the benefit accrual rate to $50 per Year of Credited 

Service for all Years of Credited Service on or after June 1, 2003 (effectively 50% of the benefit accrual 

rate just two years prior). Further, the bargaining parties raised the hourly contribution rate to the Plan by 

$0.50 to $2.90 per hour for the 2003 Plan Year. 

The Plan continued to lose active participants, with only 2,325 at the beginning of the 2004 Plan Year (a 

62% reduction in active participants from the 2000 Plan Year). The Board of Trustees and the bargaining 

parties attempted to address the declining health of the Plan with increases in the hourly contribution 

rate, approving a $0.50 increase in 2004 to $3.40 per hour, and again in 2005 to $3.90. The decline in the 

funded percentage slowed after the low of 2003, and began to recover at the beginning of 2004 with a 

71% funded ratio on a market basis ($277,707,958 – Market Value of Assets / $388,643,038 – Accrued 

Liability). 

Document #17.1 

SWORCCPP2018-000121
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

An additional $0.25 per hour was added to the hourly contribution rate for the 2006 Plan Year. The 

Pension Protection Act of 2006 was adopted effective August 17, 2006, which provided additional tools 

and a framework for addressing the underfunding of the Plan. 

Plan Year 2007 – The Plan Year commenced with a funded percentage of 74% on a market basis 

($297,201,817 – Market Value of Assets / $400,227,408 – Accrued Liability), continuing an upward trend 

since 2003. However, the number of active participants was only 2,089. 

The Board of Trustees and the bargaining parties took the following actions: 

(1) They increased the hourly contribution rate to the Plan by $0.35; and 

(2) They also provided for a temporary additional contribution of $2.00 per hour from July 1, 

2007 through August 31, 2008. This was accomplished by diverting of a portion of the hourly 

contributions the bargaining parties allocated to the Ohio and Vicinity Regional Council of 

Carpenters Health and Welfare Plan. This effectively raised the hourly contribution rate to the 

Plan to $6.50 per hour for that period of time. 

Plan Year 2008 – At the start of the 2008 Plan Year, the Plan had a funded percentage of 74% on a 

market basis ($303,177,606 – Market Value of Assets / $408,275,549 – Accrued Liability). 

On November 25, 2008, the Board of Trustees adopted the initial Funding Improvement Plan under the 

Pension Protection Act of 2006. Based on assumptions set forth in the Funding Improvement Plan, 

including an estimated assumed investment return rate of 7.5% per year, the Plan's funding ratio was 

projected to be 83% in 2014. During the analysis and adoption of the Plan's Funding Improvement Plan, 

the Board of Trustees considered modifications to the Plan and compared the benefits offered through the 

larger statewide Ohio Carpenters Pension Plan. 

Under the Funding Improvement Plan, the Board of Trustees increased the hourly contribution rate to the 

Plan for four years, including the previous increase for the 2007 Plan Year (to $4.50), and continuing 

through the 2008 Plan Year ($4.85), the 2009 Plan Year ($5.20), and the 2010 Plan Year ($5.55). 

In addition, the Trustees resolved to amend the Plan to: 

(1) Increase the early retirement reduction for benefits accrued after January 1, 2009 to 3/10 

of 1% for each month by which the commencement of the Participant's Early Retirement Benefit 

preceded the Normal Retirement Date (from the previous 1⁄4 of 1%). 

(2) Consider only years of continuous membership in the United Brotherhood of Carpenters 

and Joiners of America through December 31, 2008 for eligibility under the "Rule of 80." The 

Rule of 80 exempted a Participant's benefits from the application of the early retirement 

reduction, provided that the Participant had attained age 50, and that the sum of the Participant’s 

age and years of continuous membership in the United Brotherhood of Carpenters and Joiners of 

America equaled at least 80. 

(3) Additionally, benefits accrued on or after January 1, 2009 would not be exempted from 

the early retirement reduction as a result of a Participant's continuous membership in the United 

Brotherhood of Carpenters and Joiners of America. 

Document #17.1 

SWORCCPP2018-000122
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The temporary $2.00 per hour additional contribution, implemented on July 1, 2007 and originally 

scheduled to expire on August 31, 2008, was extended through June 30, 2010. 

Unfortunately, the Plan suffered a negative 25.9% percent asset return (-$76,931,110) for the year, from 

which the Plan has never recovered. 

Plan Year 2009 – Following the financial crisis and significant investment loss in the preceding year, the 

2009 Plan Year began with the Plan at a 52% funded ratio on a market basis ($214,567,422 – Market Value 

of Assets / $412,568,583 – Accrued Liability). The previous year's hours worked (2,928,547) remained 

generally consistent with prior years (an average of 3,157,873 over the four previous plan years). 

At the beginning of the year, the Board of Trustees reviewed the availability of funding relief under the 

Worker, Retiree, and Employer Recovery Act of 2008 ("WRERA"). In consultation with the Plan's actuary, 

and thoroughly discussed during a special meeting called for such purpose, the Board of Trustees elected to 

avail the Plan of the relief, and extended the Plan's 2008 Pension Protection Act funded status to 2009. 

Further, the Trustees extended the existing Funding Improvement Plan from 10 years to 13 years. 

During this time, the Plan briefly considered the possibility of a merger with the Ohio Carpenters 

Pension Plan; however, the requirements and limitations imposed by the Pension Protection Act of 2006 

and the then-current funded status of both plans created significant barriers that could not be overcome at 

that time. 

As the year proceeded, it became apparent that the Plan would be certified as "critical" for the following 

Plan Year, and would need to adopt a Rehabilitation Plan. Hours worked were substantially down, and the 

Plan Year ended with 500,000 fewer hours worked than the preceding year (the 2,928,547 hours worked 

in 2008 declined to 2,423,298 hours worked in 2009). Although the Plan had an investment return of 

14.9% for the Plan Year, it did not significantly reverse the Plan’s declining funded status following the 

devastating impact of the previous year's investment loss. Significantly, the Plan's negative cash flow 

percentage increased to 8.4% (compared to an average negative cash flow percentage of 5.3% per year 

over the previous four years). 

The Board of Trustees began reviewing the different adjustable benefits under the Plan, and the impact 

that the elimination or reduction of those adjustable benefits would have on the Plan's funded status. 

Plan Year 2010 – The Plan Year commenced with a funded ratio of 56% on a market basis 

($226,040,736 – Market Value of Assets / $404,027,509 – Accrued Liability). The number of active 

participants continued to fall, with only 1,831 active participants at the beginning of the Plan Year. 

Unfortunately, hours worked continued to decrease in 2010 (1,966,833), which was drastically lower –

almost 500,000 fewer hours worked – than the previous Plan Year (2,423,298), and almost 1,000,000 

fewer than the 2008 Plan Year (2,928,547). 

On March 31, 2010, the Plan's actuary certified the Plan as "critical" for the Plan Year beginning on 

January 1, 2010. On April 9, 2010, the Trustees adopted the initial Rehabilitation Plan and preferred 

schedule. The changes to the Plan by the initial Rehabilitation Plan and amendment to the Plan 

incorporating the preferred schedule were as follows: 

 For retirements commencing on or after April 30, 2010, the Plan's suspension rules for 

Disqualifying Employment before Normal Retirement Age were expanded by applying 

the rules in effect for benefits accrued on or after July 1, 2005 to benefits accrued prior to 

July 1, 2005 as well. 

Document #17.1 

SWORCCPP2018-000123
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 For retirements commencing on or after September 1, 2010, the accrued benefits of 

terminated vested participants who commenced receipt of pension benefits prior to their 

Normal Retirement Date would be subject to a full actuarial reduction to reflect early 

commencement. 

 For retirements commencing on or after September 1, 2010, the accrued benefits of 

vested participants who retired from active service and commenced receipt of pension 

benefits prior to their Normal Retirement Date would be subject to a reduction of 0.003 

for each month that the early commencement of their benefits preceded their Normal 

Retirement Date. The prior Funding Improvement Plan had included a similar 

provision, but that reduction had been applicable only to benefits accrued on or after 

January 1, 2009. 

 For disabilities incurred on or after July 1, 2010, the Plan's Total and Permanent 

Disability benefit was modified to provide that vested participants who were eligible for 

an Early Retirement Benefit would receive a monthly pension equal to their Early 

Retirement Benefit. In addition, for vested participants who incurred a total and 

permanent disability, but had not yet attained age 55, the participant would receive a 

monthly pension equal to their accrued benefit subject to a full actuarial reduction. 

Effective April 30, 2010, the Plan's lump sum return of contributions Total and 

Permanent Disability benefit was eliminated. The Rehabilitation Plan noted that the Plan 

would continue to maintain its Trade Disability benefit. 

 For deaths occurring on or after April 30, 2010, the return of contributions death benefit 

was eliminated for non-vested and vested unmarried participants. 

 For deaths occurring on or after July 1, 2010, the Plan would continue to provide a 

Qualified Pre-Retirement Survivor Annuity to the surviving spouses of vested 

participants; however, the amount payable to the surviving spouse would be determined 

as if the participant retired on the date before his date of death, or age 55 if later, elected 

the Joint & 50% Survivor Annuity form of payment, and died. Payments would not 

commence prior to the first month in which the deceased participant would have attained 

age 55. 

 For retirements on or after September 1, 2010, the Plan's Rule of 80 Early Retirement 

benefit was replaced with a Rule of 85 Early Retirement benefit. Eligibility for the Rule 

of 85 Early Retirement benefit would require a minimum age of 55, and the sum of the 

participant's age plus years of vesting service must equal or exceed 85. In addition, a 

participant would be required to have at least 1,000 hours of contributions to the Plan for 

work in Covered Employment during the 24-month period immediately preceding their 

Early Retirement Date. Only vesting service earned under the Plan would be counted in 

calculating the vesting service required for Rule of 85 Early Retirement eligibility. For 

the participant to receive an unreduced Early Retirement benefit, they would be required 

to satisfy these conditions. 

In addition, the Rehabilitation Plan adopted additional contribution requirements as follows: 

 The base journeyman hourly contribution rate was increased to $5.70 per hour for all 

hours of work on or after June 1, 2010. 

 Beginning June 1, 2011 and ending June 1, 2020, an annual increase of $0.25 per hour 

was imposed on the Plan's hourly contribution rate. 

Document #17.1 

SWORCCPP2018-000124
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Following the adoption of the Rehabilitation Plan, the Board of Trustees amended the 

Plan to remove ancillary benefits that did not require the same advance notice as the 

reduction of adjustable benefits. On and effective as of April 29, 2010, the Board of 

Trustees amended the Plan to eliminate certain ancillary benefits, including a lump sum 

return of contributions benefit for (1) those participants who died with less than five years 

of vesting service, (2) deceased unmarried participants who were receiving a single life 

annuity and did not receive benefits in excess of the amount of employer contributions 

made on their behalf, and (3) married participants who died before they or their spouse 

received benefits in aggregate less than the employer contributions made on behalf of the 

participant. 

The Plan finished the year with an investment return of 10.6% for the year; however, the Plan's negative 

cash flow continued to increase with a 9.3% negative cash flow for the year. 

Plan Year 2011 – As of January 1, 2011, the number of active participants in the Plan was 1,583, a 

reduction of about 250 from the prior year. Active participants made up about 29% of total participants 

and beneficiaries. 

On March 3, 2011, the Board of Trustees elected to use the longer amortization period and asset 

smoothing options under Internal Revenue Code Section 431(b)(8) as allowed under the Pension Relief 

Act of 2010, for the Plan Year beginning on January 1, 2011. 

As the year progressed, the Trustees noted that hours worked through the first several months was 

tracking significantly downward from the average hours worked (3,185,584) over the past seven years 

(excluding 2010). The Board of Trustees considered variations of different projections from the actuary, 

including no additional pension accrual, increased pension contributions, lower hour assumptions, and 

lower investment return. As the Trustees continued to discuss the impact of lower hours, the Board began 

to discuss and consider the advantages of hybrid pension plan designs. 

The Board of Trustees conducted a request for proposals for a possible replacement of the Plan's 

investment consultant. 

The Plan ended the year with 2,092,816 hours worked, and an investment asset return of 0.8%. The Plan 

also had negative cash flow of 9.1% for the year. 

Plan Year 2012 – The first action of the Plan in 2012 was to select Marquette Associates as the 

Investment Consultant. 

The Plan was at a 53% funded ratio on a market basis ($210,235,006 – Market Value of Assets / 

$399,455,599 – Accrued Liabilities). The hourly contribution rate for the Plan Year, after a $0.25 increase 

under the rehabilitation plan, was $6.20. The number of active participants reached a 22-year historic low 

of 1,575 at the beginning of the Plan Year, only 41% of the number of active participants in 2000. 

In June, the Board of Trustees met with Chris Heinz, who served as a legislative consultant to the United 

Brotherhood of Carpenters. Mr. Heinz was then seeking legislative relief from the United States Congress 

to permit pension plans to reduce accrued benefits of participants and retirees in pay status in order to save 

severely underfunded plans. Due to the nature of the Plan's difficulties, including the ongoing negative cash 

flow percentage arising in part because of the Plan's significant unreduced early retiree benefit payment 

obligations, the Trustees recognized the possibility that such a tool might prevent the eventual insolvency 

of the Plan. The Plan authorized Mr. Heinz to use the Plan's funding situation and identity in order to 

demonstrate the utility of a legislative fix. 

Document #17.1 

SWORCCPP2018-000125
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Plan's new Investment Consultant began advising the Board of Trustees on various ways to reduce the 

Plan's investment volatility due to the Plan's fragile funding status and negative cash flow. On the advice 

and guidance of the new Investment Consultant, the Board of Trustees adopted modifications to the Plan’s 

investment portfolio. 

In consultation with the Plan's actuary, the Board of Trustees updated the Plan's Rehabilitation Plan to 

further modify the Plan's early retirement benefit as follows: 

 For a Participant who commenced receipt of an Early Retirement Benefit on or after 

January 1, 2013, the Early Retirement Benefit would equal the Participant's actuarially 

reduced accrued benefit. 

 The Rule of 85 was completely eliminated for Early Retirement Benefits commencing on 

or after January 1, 2013. 

The Plan ended the year with 2,305,944 hours worked and an investment asset return of 10.1%. The Plan's 

negative cash flow was 8.2% for the year. 

Plan Year 2013 – At the beginning of the Plan Year, the Plan was funded at a 53% funded ratio on a 

market basis ($212,968,506 – Market Value of Assets/ $404,284,154 – Accrued Liabilities). The hourly 

contribution rate for the Plan Year, after another $0.25 increase under the rehabilitation plan, was $6.45. 

The number of active participants had risen slightly from the prior year to 1,645 as of January 1, 2013. 

As of the first Board of Trustees meeting, despite the continued difficulties, the Plan was making 

scheduled progress in meeting the requirements of the Rehabilitation Plan. However, altering the 

assumptions so that future hours worked continued at approximately 2,300,000 per year, the Plan would 

require additional measures to rehabilitate. 

The Plan again met with Chris Heinz of Grossman Heinz to receive updates about possible relief pursuant 

to the report prepared by the National Coordinating Committee for Multiemployer Plans. There was some 

hope that the recommendations could be introduced during the Fall of 2013. 

Towards the end of the year, the Board of Trustees again followed the advice and guidance of its 

Investment Consultant and modified investments to reduce volatility and protect the Plan going forward. 

Further, as the hours worked for the year continued to trend lower, the Plan's actuary presented additional 

various projections for the Plan. Notably, these projections informed the Trustees that if the future hours 

worked held steady at 2,100,000 per year, despite the remaining seven years of scheduled $0.25 per hour 

per year contribution increases, the Plan would still be projected to incur a funding deficiency. 

The Plan ended the year with 2,091,252 hours worked and an investment asset return of 14.2%. The Plan's 

negative cash flow was 8.5% for the year. 

Plan Year 2014 – The Plan began the 2014 Plan Year with a 54% funded ratio on a market basis 

($223,046,067 – Market Value of Assets / $409,939,373 – Accrued Liabilities). The hourly contribution 

rate for the Plan Year, incorporating the scheduled $0.25 increase under the rehabilitation plan, was $6.70. 

The number of active participants was 1,573 as of January 1, 2014. 

Document #17.1 

SWORCCPP2018-000126
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Board of Trustees, in consultation with the Plan actuary, elected to extend the Plan's amortization 

period for an additional five years. By correspondence to the Internal Revenue Service dated July 3, 2014, 

the Plan formally requested the approval of an automatic extension of the amortization periods in 

accordance with §431(d)(1) of the Internal Revenue Code of 1986. 

During the regular Trustee meetings, the Board continued to review and consider the impact of various 

assumptions on the funding status of the Plan. Based on hours worked through the first half of 2014, the 

Board of Trustees recognized that there would not be a material improvement during 2014. 

The Board of Trustees reviewed numerous options, and considered the possibility that continued 

increases in the per hour contribution rate would have a negative impact on generating additional hours 

worked for which contributions were due. Further, the Plan had already eliminated all ancillary benefits 

and cut all adjustable benefits. Previously, the Plan had considered the impact of reducing the benefit 

accrual to zero; however, the reduction of future benefit accruals would not sufficiently counteract the 

Plan's negative cash flow percentage and legacy obligations connected with the unreduced early 

retirement benefits. The Plan's actuary reviewed the possibility of declaring that the Plan had 

"exhausted all reasonable measures." The Board of Trustees directed the Plan's actuary to prepare an 

updated Rehabilitation Plan invoking the exhaustion of all reasonable measures for consideration and 

discussion at the final meeting of 2014. 

At the final Board of Trustees meeting, the actuary led a discussion and analysis of declaring "exhaustion 

of all reasonable measures." The consideration and decision to declare that all reasonable measures had 

been exhausted is detailed in the Responses to Checklist Items #19, #20 and #21. The Board of Trustees 

adopted an updated Rehabilitation Plan recognizing that the Plan would not emerge from critical status 

within the scheduled Rehabilitation Period. The updated Plan continued the $0.25 per year increases to the 

hourly contribution rate through 2020. 

At the end of the year, the Multiemployer Pension Reform Act of 2014 was passed and signed into law. 

For the 2014 Plan Year, the Plan had 2,239,505 hours worked, an investment asset return of 7.2%, and a 

negative cash flow of 7.8%. 

Plan Year 2015 – The 2015 Plan Year began with the Plan at a 54% funded ratio on a market basis 

($221,295,712 – Market Value of Assets / $408,066,808 – Accrued Liabilities). The hourly contribution 

rate for the Plan Year was $6.95, incorporating the scheduled $0.25 increase under the Rehabilitation 

Plan. The number of active participants was 1,576 as of January 1, 2015. 

The Board of Trustees continued to review and consider the impact of future hours worked and asset 

return variables. Despite an asset return of 6.8% for the year ending December 31, 2014 and 7.0% 

thereafter, continued employer contribution increases of $.25 per hour in each of the next six years and 

future annual hours totaling 2,300,000 per year, the Plan was still scheduled to incur a funding deficiency. 

Following significant discussions on the assumptions, the Plan's actuary stated that based on the 

assumptions of 2,300,000 hours worked, an annual investment return of 6.5% and the hourly contribution 

rate of $6.95, the Plan would be certified as "critical and declining" status for 2015. 

The Board of Trustees continued to consider the potential impact of the tools provided by MPRA, and 

waited for additional guidance on benefit suspensions and application procedures. At each Board of 

Trustee meeting, the Trustees dedicated significant time to consideration of benefit suspensions, as well 

as alternative plan designs such as variable defined benefit plans and an "Evergreen Plan" design created 

by the Plan's actuary. The Evergreen Plan establishes a Section 414(k) account inside a pension plan, and 

utilizes the Plan's Evergreen account to receive a transfer of defined contribution account balance, which 

is then annuitized and paid to the Participant in the form of a monthly benefit for the Participant's life 

Document #17.1 

SWORCCPP2018-000127
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(and the Participant's spouse, if a joint and survivor benefit is elected). Each participant would have an 

Evergreen account equal to contributions made on the member's behalf plus returns and less expenses. 

The Board of Trustees scheduled and held a special meeting dedicated solely to the consideration of 

alternative plan designs and possible benefit suspensions. 

The Board of Trustees also directed the Investment Consultant to undertake an asset allocation study to 

determine an assumed rate of return for purposes of consideration of benefit suspensions under MPRA 

and funding projections. 

With the guidance available at that time, the Board of Trustees considered various benefit suspension 

designs that would avoid Plan insolvency. As of October 2015, the actuary demonstrated to the Board of 

Trustees that the Plan would become insolvent in 2033 if no changes were made. The Plan's actuary 

reviewed several alternative projections which considered different percentages of benefit suspensions. It 

was also noted that active members had already been subject to reductions in benefits and contribution 

rate increases, whereas other members had retired under the Rule of 80 with unreduced benefits. The 

Board of Trustees continued to work towards avoiding Plan insolvency. 

On September 10, 2015, the Board of Trustees adopted an updated Rehabilitation Plan. It was determined 

that the continued increase of the hourly contribution rate would not forestall insolvency. In addition, 

hours worked continued to be significantly lower than pre-financial crisis levels. As detailed in the 

response to Checklist Items #19, #20 and #21, the updated Rehabilitation Plan ceased the increase of the 

hourly contribution rate at $6.95. 

The Plan had a slightly better year in 2015 with 2,544,244 hours worked. The Plan finished the year with 

an investment asset return of 2.8%, and a negative cash flow of 6.6%. 

Plan Year 2016 – The 2016 Plan Year commenced with the Plan at a 45% funded ratio on a market basis 

($213,252,642 – Market Value of Assets / $470,229,784 – Accrued Liabilities), as adjusted with the new 

assumptions of the Rehabilitation Plan. The hourly contribution rate for the Plan Year remained $6.95. 

The number of active participants was 1,576 as of January 1, 2015. 

The Board of Trustees continued to review possible benefit suspensions that would satisfy the criteria to 

avoid insolvency. In addition, the Plan's actuary provided information and guidance on the possibility of 

an alternative plan design such as the "Evergreen" plan or the "Composite Plan" rumored to be a possible 

newly available option. 

The Plan's Board of Trustees concentrated the remaining portion of the Plan Year towards working to 

submit an application for benefit suspensions under MPRA, as it was considered the only viable option for 

avoiding eventual insolvency. 

Plan Year 2017 – The 2017 Plan Year commenced with the Plan at a 48% funded ratio on a market basis 

($218,949,354 – Market Value of Assets / $460,087,441 – Accrued Liabilities). The hourly contribution 

rate for the Plan Year remained at $6.95. The number of active participants was 1,691 as of January 1, 

2017. 

Document #17.1 

SWORCCPP2018-000128
 

 

 

 

 

 

On March 30, 2017, the Board of Trustees submitted an application for suspension of benefits under the 

Multiemployer Pension Reform Act of 2014. After several months of substantive discussions regarding 

the application's assumptions and the requirements for approval with the Department of Treasury and the 

Pension Benefit Guaranty Corporation, at the request and direction of the Department of Treasury and 

Pension Benefit Guaranty, the Board of Trustees withdrew the application on October 12, 2017, with the 

understanding that guidance and other assistance would be provided for submission of a subsequent 

application. 

Document #17.1 

SWORCCPP2018-000129
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #18 – 5.02 Plan Factors Described in §432(e)(9)(C)(ii) 

Does the application include information regarding the plan factors described in §432(e)(9)(C)(ii), for 

the past 10 plan years immediately preceding the plan year in which the application is submitted? 

See Section 5.02 of Revenue Procedure 2017-43. 

The information regarding the plan factors described in §432(e)(9)(C)(ii), for the past 10 plan years 

immediately preceding the plan year in which the application is submitted is set forth on the attached 

Document 18.1. 

SWORCCPP2018-000130
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 18.1 

The information requested by Section 5.02 of Internal Revenue Service Revenue Procedure 2017-43 is 

included as follows: 

Summary of Hourly Contribution Rates 2000 through Present 

Effective Date of Change# Hourly Contribution Rate 

June 1, 1999 $2.40 

June 1, 2003 $2.90 

June 1, 2004 $3.40 

June 1, 2005 $3.90 

June 1, 2006 $4.15 

June 1, 2007 $4.50^ 

June 1, 2008 $4.85^ 

June 1, 2009 $5.20^ 

June 1, 2010 $5.70 

June 1, 2011 $5.95 

July 1, 2012 $6.20 

July 1, 2013 $6.45 

June 1, 2014 $6.70 

June 1, 2015 $6.95* 

Through Present $6.95 

#A few of the Collective Bargaining Agreements change the Hourly Contribution Rate as of the 

September following the dates above. 

^A temporary additional contribution of $2.00 per hour (in addition to the hourly contribution rate set 

forth in the table above) was implemented from July 1, 2007 through June 30, 2010. This was 

accomplished by diverting of a portion of the bargaining parties’ hourly contributions to the Plan that had 

been previously allocated to the Ohio and Vicinity Regional Council of Carpenters Health and Welfare 

Plan. 

*On September 10, 2015, the Board of Trustees determined that additional increases in the hourly 

contribution rate would not forestall insolvency, and ceased the annual $0.25 increase to the hourly 

contribution rate. The Board of Trustees determined that the Plan had exhausted all reasonable measures 

at the December 4, 2014 Board of Trustees meeting. 

Levels of Benefit Accruals 

A Year of Credited Service is defined as each Plan Year in which 1,500 Hours of Service are earned at 

the base journeyman rate (pro-rated for hours other than 1,500). 

Prior to January 1, 2002, a Year of Credited Service earned a $99 benefit credit. 

Effective January 1, 2002, a Year of Credited Service was reduced to an $80 benefit credit. 

Effective June 1, 2003, a Year of Credited Service was further reduced to a $50 benefit credit. 

Document #18.1 

SWORCCPP2018-000131
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Prior Reductions of Adjustable Benefits under §432(e)(8) 

The following adjustable benefits have been reduced: 

Early Retirement Reductions: 

Effective January 1, 2009, an increase the early retirement reduction for benefits accrued after 

January 1, 2009 to 3/10 of 1% for each month by which the commencement of the Participant's 

Early Retirement Benefit preceded the Normal Retirement Date (from the previous 1⁄4 of 1%). 

For retirements commencing on or after September 1, 2010, the accrued benefits of terminated 

vested participants who commenced receipt of pension benefits before their Normal Retirement 

Date would be subject to a full actuarial reduction to reflect the early commencement of their 

benefits. 

For retirements commencing on or after September 1, 2010, the accrued benefits of vested 

participants who retired from active service and commenced receipt of pension benefits before 

their Normal Retirement Date would be subject to a reduction of 0.003 for each month that the 

commencement of their benefits preceded their Normal Retirement Date. 

For a Participant who commenced receipt of an Early Retirement Benefit on or after January 1, 

2013, the Early Retirement Benefit would equal the Participant's actuarially reduced accrued 

benefit. 

Reduction and Elimination of "Rule of 80": 

Effective January 1, 2009, only years of continuous membership in the United Brotherhood of 

Carpenters and Joiners of America through December 31, 2008 would be considered for 

eligibility for retirement under the "Rule of 80." The Rule of 80 exempted a Participant's benefits 

from the application of the early retirement reduction, provided that the Participant had attained 

age 50, and whose age and years of continuous membership in the United Brotherhood of 

Carpenters and Joiners of America equaled at least 80. 

Benefits accrued on or after January 1, 2009 would not be exempted from the early retirement 

reduction as a result of a Participant's continuous membership in the United Brotherhood of 

Carpenters and Joiners of America. 

For retirements on or after September 1, 2010, the Plan’s Rule of 80 Early Retirement benefit was 

replaced with a Rule of 85 Early Retirement benefit. Eligibility for the Rule of 85 Early 

Retirement benefit would require a minimum age of 55, and the sum of the participant’s age plus

years of vesting service must equal or exceed 85. In addition, a participant would be required to 

have at least 1,000 hours of contributions to the Plan for work in Covered Employment during the 

24-month period immediately preceding their Early Retirement Date. Only vesting service earned 

under the Plan would be counted in calculating the vesting service required for Rule of 85 Early 

Retirement eligibility. For the participant to receive an unreduced Early Retirement benefit, they 

would be required to satisfy these conditions. 

The Rule of 85 was completely eliminated for Early Retirement Benefits commencing on or after 

January 1, 2013. 

Document #18.1 

SWORCCPP2018-000132
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Expansion of Suspension of Benefit Rules for Early Retirement Benefits 

For retirements commencing on or after April 30, 2010, the Plan’s suspension rules for

Disqualifying Employment before Normal Retirement Age were expanded by applying the rules 

in effect for benefits accrued on or after July 1, 2005 to benefits accrued before July 1, 2005 as 

well. 

Reduction of Total and Permanent Disability Benefit 

For disabilities incurred on or after July 1, 2010, the Plan’s Total and Permanent Disability 

benefit was modified to provide that vested participants who were eligible for an Early 

Retirement Benefit would receive a monthly pension equal to their Early Retirement Benefit. In 

addition, for vested participants who incurred a total and permanent disability but had not yet 

attained age 55, the participant would receive a monthly pension equal to their accrued benefit 

subject to a full actuarial reduction. 

For applications filed for Total and Permanent Disability after July 31, 2018, eligibility for the 

benefit will require a determination of total and permanent disability by the Social Security 

Administration under the Old Age and Survivors Disability Insurance (OASDI) program. 

Effective March 31, 2019, and contingent on the approval of this application by the Department 

of Treasury, eligibility for total and Permanent Disability benefits will be limited to participants 

who have not attained age 55 as of the date the participant became totally and permanently 

disabled. 

Reduction of Qualified Pre-Retirement Survivor Annuity and Delay until Age 55 

For deaths occurring on or after July 1, 2010, the Plan would continue to provide a Qualified PreRetirement Survivor Annuity to the surviving spouses of vested participants; however, the 

amount payable to the surviving spouse would be determined as if the participant had retired on 

the day before his date of death, or age 55 if later, elected the Joint & 50% Survivor Annuity form 

of payment, and died. Payments would not commence before the first month the deceased 

participant would have attained age 55. 

Elimination of Return of Contributions Ancillary Benefit 

Effective as of April 29, 2010, the Board of Trustees amended the Plan to eliminate the lump sum 

return of contributions benefit for (1) those participants who died with less than five years of 

vesting service, (2) deceased unmarried participants who were receiving a single life annuity and 

did not receive benefits in excess of the amount of employer contributions made on their behalf, 

and (3) married participants who died before they or their spouse received benefits in aggregate 

less than the employer contributions made on behalf of the participant. 

Effective April 30, 2010, the Plan’s lump sum return of contributions Total and Permanent 

Disability benefit was eliminated. 

Elimination of Trade Disability Benefit 

Effective August 1, 2018, the Plan's Trade Disability benefit was eliminated. 

Document #18.1 

SWORCCPP2018-000133
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Any Prior Suspensions of Benefits Under §432(e)(9). 

The Board of Trustees has not received approval for any prior suspensions of benefits under §432(e)(9). 

Measures Undertaken by the Plan Sponsor to Retain or Attract Contributing Employers. 

The Board of Trustees has worked to retain and attract contributing employers through consultation and 

engagement with the employers and the various associations through the rehabilitation plan process. 

Through this communication, in response to employer association request, the Board of Trustees adopted 

a "free look" plan amendment on June 21, 2007. 

Additionally, the Board of Trustees has had several withdrawing employers re-sign and proceed through 

the abatement process rather than pay withdrawal liability. 

The Impact on Plan Solvency of the Subsidies and Ancillary Benefits Available to Active 

Participants. 

As of January 1, 2013, the Plan does not provide any subsidy or ancillary benefit to any active participant. 

All ancillary benefits have been eliminated from the Plan effective as of January 1, 2013. 

Compensation Levels of Active Participants Relative to Employees in the Participants' Industry 

Generally. 

During the review of the suspension of benefits and determination of the exhaustion of all reasonable 

measures, the Board of Trustees reviewed the hourly contribution rate and the amount of benefit credit 

received by the active participants of the Plan. Notably, as part of the determination that the Board of 

Trustees had exhausted all reasonable measures, it was demonstrated that continued annual increases to 

the hourly contribution rate would not prevent the eventual projected insolvency of the Plan. Accordingly, 

further scheduled annual increases to the hourly contribution rate were discontinued. 

In comparison to the $6.95 per hour contribution rate and $50.00 benefit credit based on 1500 hours 

worked, the other larger nearby Carpenter pension funds each provide a significantly higher benefit. 

Union / Craft Year Contribution Rate 

Ohio Carpenters Pension Plan 2017 Between $7.18 – $8.53 per hour 

contribution rate (for a 1.0% 

benefit credit), which would 

equal approximately between 

$107.70 – $127.95 annual benefit 

credit based on 1500 hours 

worked. Effective November 1, 

2017, the benefit credit is subject 

to a variable benefit design that 

adjusts in accordance with the 

Plan's investment return. 

Document #18.1 

SWORCCPP2018-000134
 

 

 

 

 

 

 

 

 

 

 

 

Union / Craft Year Contribution Rate 

Indiana / Kentucky/ Ohio 

Regional Council of Carpenters 

Pension Plan 

2016 $8.04 per hour contribution rate 

(for a 0.90% benefit credit), 

which would equal 

approximately $108.54 annual 

benefit credit based on 1500 

hours worked. 

Competitive and other Economic Factors Facing Contributing Employers 

Contributing employers have faced significant competitive and economic difficulties over the last 15 

years, including a general slowdown in construction activity within the Plan's geographic area after the 

financial crisis of 2008, and an increase in non-union competition. 

The geographic area from which contributions are made to the Plan suffered a reduction in hours worked 

for which contributions were due from 4,590,926 in the 2000 Plan Year to 2,392,616 in the 2017 Plan 

Year. In addition, the number of signatory contractors dropped from 256 during the 2000 Plan Year to 

211 during the 2017 Plan Year. 

Document #18.1 

SWORCCPP2018-000135
 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #19 – 5.03 All Reasonable Measures 

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

factors listed in Section 5.02 in the determination that all reasonable measures were taken to avoid 

insolvency? 

See Section 5.03 of Revenue Procedure 2017-43. 

The narrative description of how the plan sponsor took into account – or did not take into account – the 

factors listed in Section 5.02 in the determination that all reasonable measures were taken to avoid 

insolvency is attached as Document 19.1. 

SWORCCPP2018-000136
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 19.1 

The Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan determined 

that it had exhausted all reasonable measures in December, 2014. The determination that the Plan had 

exhausted all reasonable measures to avoid insolvency was considered and debated during the 2014 Plan 

Year. The factors set forth in Section 5.02 of Internal Revenue Service Revenue Procedure 2017-43 were 

taken into account in the determination as follows (note – a number of factors are addressed together): 

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

At the time it was determined that the Plan had exhausted all reasonable measures to avoid insolvency in 

December of 2014, the Board of Trustees had removed all adjustable benefits under §432(e)(8). The 

Board of Trustees recognized that previously valued and popular options, such as subsidized early 

retirement, subsidized total and permanent disability benefits, and a return of contributions death benefit 

were no longer available to active participants. 

Contribution levels 

The impact of benefit and contribution levels on retaining active participants and bargaining groups under 

the Plan 

The impact of past and anticipated contribution increases under the plan on employer attrition and 

retention levels 

Despite significantly and consistently raising the hourly contribution rate annually since 2003 – from 

$2.40 to $6.95 per hour – including a three-year period in which the bargaining parties contributed an 

additional $2.00 per hour to the Plan through the diversion of amounts previously allocated to the Ohio 

and Vicinity Regional Council of Carpenters Health and Welfare Plan, the Plan's funded status did not 

improve. The Plan's aggregate hours worked remained stagnant, and apparently permanently lower than 

prior to the financial crisis in 2008. The Plan's rehabilitation plan called for an annual $0.25 increase in 

the contribution rate, beginning June 1, 2011 and scheduled to end June 1, 2020 at $8.20 per hour. The 

Plan's actuary informed the Board of Trustees that the continued increases in the Plan's contribution rate 

would not prevent the eventual insolvency of the Plan. 

The increases in the hourly contribution rate and the noticeable elimination of adjustable benefits were 

not popular with participants. Similarly, a number of employers complained about the increasing pension 

contribution and its detrimental impact on competitive bidding. Following the 2008 financial crisis, the 

Plan assessed a number of employers for withdrawal liability. A few of the employers withdrew from the 

Plan believing that they could compete more successfully without the burden of mandatory contributions 

to the Plan. The Board of Trustees was concerned that continuing to increase the hourly contribution rate 

would lead to further employer and active participant exodus from the Plan. 

After the initial determination that the Plan had exhausted all reasonable measures in December, 2014, the 

Board of Trustees amended the Rehabilitation Plan in September, 2015 to maintain the hourly 

contribution rate at $6.95, rather than risk possible further erosion of the active participants or 

contributing employers. 

Document #19.1 

SWORCCPP2018-000137
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Levels of benefit accruals, including any prior reductions in the rate of benefit accruals 

Compensation levels of active participants relative to employees in the participants' industry generally 

The active participants in the Plan contributed similar or higher hourly contribution rates for less of an 

accrued benefit than other carpenter funds in the State of Ohio and nearby. Further, the active participants 

were no longer able to retire prior to age 62 without the application of an early retirement reduction factor 

to their monthly benefit, or receive a return of contributions benefit in the event of their death prior to 

receiving monthly benefits equal to the hourly contributions made on their behalf. 

In comparison to the $6.95 per hour contribution rate and $50.00 benefit credit based on 1500 hours 

worked for active participants in the Plan, the other larger nearby Carpenter pension funds each provided 

a significantly higher benefit. 

Union / Craft Year Contribution Rate 

Ohio Carpenters Pension Plan 2014 Between $5.44 – $6.74 per hour 

contribution rate (for a 1.0% 

benefit credit), which would 

equal approximately between 

$81.60 – $101.10 annual benefit 

credit based on 1500 hours 

worked. 

Indiana / Kentucky/ Ohio 

Regional Council of Carpenters 

Pension Plan 

2014 $7.34 per hour contribution rate 

(for a 0.90% benefit credit), 

which would equal 

approximately $99.09 annual 

benefit credit based on 1500 

hours worked. 

With this information, the Board of Trustees determined that further reductions to the rate of benefit 

accrual (from $50 per Year of Credited Service) would not be reasonable, and would have an adverse 

impact on retaining active participants. 

Competitive and other economic factors facing contributing employers 

The Board of Trustees considered the competitive and other economic factors facing contributing 

employers. Primarily, with respect to the determination that the Plan had exhausted all reasonable 

measures to avoid insolvency, the Board of Trustees took into account the reduction in the number of 

signatory employers contributing to the Plan (256 during the 2000 Plan Year to 182 during the 2016 Plan 

Year) and the amount of hours worked per Plan Year. The Board of Trustees noted that it was unlikely 

that the amount of hours worked would return to the 3,000,000-plus per year level common prior to 2008 

any time soon. 

Document #19.1 

SWORCCPP2018-000138
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

The Board of Trustees discussed the fact that few new contributing employers would desire to accept an 

obligation to contribute to the Plan due to the presence of withdrawal liability, regardless of the "free 

look" provision adopted by the Plan. Thus, the Board of Trustees determined that the cessation of the 

continued increase of the hourly contribution rate would help prevent the exit of any current contributing 

employers. 

The impact on plan solvency of the subsidies and ancillary benefits available to active participants 

As of January 1, 2013, the Plan did not provide any subsidy or ancillary benefit to any active participant. 

There were no subsidies or ancillary benefits to preserve or consider removing in connection with the 

determination that the Plan had exhausted all reasonable measures to prevent insolvency. 

* * * * * * * * * * * * * * * 

The factors set forth in Section 5.02 of Internal Revenue Service Revenue Procedure 2017-43 that the 

Board of Trustees did not take into account in the determination, even nominally, is limited to the 

following: 

Any prior suspension of benefits under Internal Revenue Code §432(e)(9) 

The Board of Trustees declared that the Plan had exhausted all reasonable measures December 4, 2014. 

At that time, the Multiemployer Pension Reform Act of 2014 had not yet been adopted, and, thus, no 

prior suspension of benefits under Internal Revenue Code §432(e)(9) occurred or was taken into account 

in the determination that all reasonable measures had been taken to avoid insolvency. 

* * * * * * * * * * * * * * * * 

The only other factor the Plan considered was the possibility that some legislative action would provide 

the Plan some additional methods or tools to address its funding deficiency; however, at the time of the 

determination that the Plan had exhausted all reasonable measures to avoid insolvency, this possibility 

seemed unlikely. 

* * * * * * * * * * * * * * * * 

In sum, the Board of Trustees determined that the Plan had exhausted all reasonable measures to avoid 

insolvency because the current rehabilitation plan would result in a funding deficiency within the next 

Plan Year, the continued increase in the hourly contribution rate or further reduction of the rate of benefit 

accrual would likely have an adverse impact on the Plan, and the Plan did not have any additional 

adjustable benefits or ancillary benefits to remove. 

Document #19.1 

SWORCCPP2018-000139
 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #20 – 5.03 All Reasonable Measures – Retention of Participants and Employers 

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

the determination that all reasonable measures have been taken to avoid insolvency the impact of: 

▪ benefit and contribution levels on retaining active participants and bargaining groups under the 

plan; and 

▪ past and anticipated contribution increases under the plan on employer attrition and retention 

levels? 

See Section 5.03 of Revenue Procedure 2017-43. 

Document 19.1 contains the description of how the Board of Trustees of the Southwest Ohio Regional 

Council of Carpenters Pension Plan took into account the impact of: 

▪ benefit and contribution levels on retaining active participants and bargaining groups under the 

plan; and 

▪ past and anticipated contribution increases under the plan on employer attrition and retention 

levels. 

in the determination that all reasonable measures have been taken to avoid insolvency. 

SWORCCPP2018-000140
 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #21 – 5.04 Other Factors 

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 Revenue Procedure 2017-43. 

Document 19.1 contains the description of all of the factors the Board of Trustees of the Southwest Ohio 

Regional Council of Carpenters Pension Plan took into account in the determination that all reasonable 

measures have been taken to avoid insolvency, including how and why such factors were taken into 

account. 

SWORCCPP2018-000141
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #22 – 6.01 Proposed Ballot 

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

statement in opposition, the individualized estimates, and the voting procedures? 

See Section 6.01 of Revenue Procedure 2017-43. 

A copy of the Proposed Ballot excluding the statement in opposition, the individualized estimates, and the 

voting procedures is attached as Document 22.1. 

SWORCCPP2018-000142
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 22.1 

BALLOT FOR APPROVAL OF THE PENSION RECOVERY PLAN 

Southwest Ohio Regional Council of Carpenters Pension Plan 

The "Pension Recovery Plan" for the Southwest Ohio Regional Council of Carpenters was 

submitted on June 29, 2018 by the Board of Trustees in accordance with the Multiemployer Pension 

Recovery Plan of 2014 ("MPRA") and its regulations. 

On [Insert Date], the Pension Recovery Plan was approved by the United States Secretary of 

Treasury, in consultation with the Pension Benefit Guaranty Corporation and the United States 

Department of Labor. 

The next step is for all eligible voting participants to approve or reject the proposed Pension 

Recovery Plan. The proposed suspension of benefits set forth in the Pension Recovery Plan will be 

effective for benefits paid after March 31, 2019 unless a majority of all eligible voters affirmatively vote 

to reject the Pension Recovery Plan. An individual's failure to cast a vote has the same effect as a vote to 

approve the Pension Recovery Plan. This Ballot is required by Federal law to provide information and 

assistance to you in exercising your right to vote. 

The Board of Trustees Recommends the Approval of the Pension Recovery Plan 

The Board of Trustees strongly recommends the approval of the Pension Recovery Plan. The 

Pension Recovery Plan is designed to prevent the Plan from becoming insolvent, and to preserve your 

pension benefits as completely as possible. You have worked hard for your pension benefit. The intent of 

the Pension Recovery Plan is to avoid insolvency, stop the Plan's funding decline, and allow the Plan to 

continue to provide benefits going forward. 

Description of the Pension Recovery Plan 

You have already received an individual estimate illustrating the Pension Recovery Plan's impact 

on your monthly benefit amount. 

The basic policy of the Pension Recovery Plan is that every person's monthly retirement benefit 

paid after March 31, 2019 would be recalculated as if the same reductions applicable under the current 

Plan provisions were applied based on their age at retirement. 

The reduction of your monthly benefit is determined in 2 steps: 

1 - If you retired prior to January 1, 2013 and had not reached age 62, the Pension Recovery 

Plan will apply the early retirement reduction factors that would have been applicable to your age at 

retirement had you retired subject to the same Plan provisions that apply to monthly benefits that 

commence on or after January 1, 2013. 

If you retired on or after January 1, 2013, or retired at age 62 or later, the first step of the 

reduction would not have any impact on your monthly benefit. 

2 - An 8% reduction will be applied to all monthly benefits currently being paid and all 

accrued benefits not yet in pay status. 

Document #22.1 

SWORCCPP2018-000143
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

If you are a Beneficiary receiving a monthly benefit, your monthly benefit will be adjusted based 

on your Participant's recalculated benefit as described in steps 1 and 2 above. 

This is a one-time recalculation and will not impact accrued benefits earned on or after April 1, 

2019. The recalculation will be applied to all Participants, Beneficiaries and Alternate Payees. The 

Pension Recovery Plan, if approved, will not reduce or take into account amounts already paid to 

individuals through March 31, 2019. 

Individuals who commenced their benefit pursuant to a Disability Pension under the Plan, or their 

beneficiaries, will not have their monthly benefit reduced. Individuals who have attained age 80 by 

March 31, 2019 will not have their monthly benefit reduced. Individuals who have attained age 75, but 

have not attained age 80, by March 31, 2019, will be subject to smaller reductions than they would have 

otherwise. 

The Trustees have spent the last two years evaluating possible alternatives in an attempt to create 

an equitable plan that satisfies the requirements of MPRA. Some of the factors set forth in MPRA that the 

Board of Trustees considered while attempting to craft an equitable allocation of the benefit reductions 

included: 

1 - The age and life expectancy of the participant and beneficiary; 

2 - The amount of benefits; 

3 - The type of benefit, such as early retirement benefits; 

4 - The extent to which a participant or beneficiary is receiving a subsidized benefit; 

5 - The history of benefit increases and reductions for participants and beneficiaries; 

6 - The differences between active and retiree benefits; and 

7 - The extent to which active participants are reasonably likely to withdrawal support for the 

Plan. 

If the Pension Recovery Plan is approved, the proposed suspension of benefits will remain in 

effect indefinitely. 

The Insolvency of the Southwest Ohio Regional Council of Carpenters Pension Plan 

Without the approval of the Pension Recovery Plan, our Plan is scheduled to go insolvent within 

the next 18 years (2036), and possibly sooner. The insolvency of the Plan would result in the reduction of 

benefits to the benefit guaranteed by the Pension Benefit Guaranty Corporation ("PBGC"). The PBGC is 

a Federal agency that acts as an insurance company for pensions and guarantees a minimum benefit to 

participants and beneficiaries. Federal law requires that our Pension Recovery Plan provide a benefit at 

least as much as 110% of the guaranteed benefit from the PBGC; thus, all Participant, Beneficiary and 

Alternate Payee monthly benefits would be higher if the Pension Recovery Plan is approved than if the 

Plan is turned over to the PBGC. If the Pension Recovery Plan is rejected, the Plan will eventually 

become insolvent. As a result, all Participants, Beneficiaries and Alternate Payees would be reduced to 

the amount guaranteed by the PBGC. Individuals who retired on a Disability Pension and individuals who 

attained age 80 would be included in the reduction to the PBGC guaranteed benefit. 

Document #22.1 

SWORCCPP2018-000144
 

 

 

 

 

 

 

 

 

 

The Plan's actuary has certified that the approval and implementation of the Pension Recovery 

Plan will avoid insolvency and allow the Plan to continue to pay the reduced benefits and future accrued 

benefits indefinitely. The actuary's projection is based on conservative estimates of future hours worked 

for which contributions are due and the future investment returns of the Plan, and is therefore subject to 

some uncertainty. 

The Insolvency of the Pension Benefit Guaranty Corporation 

The Pension Benefit Guaranty Corporation is expected to become insolvent in 2025, several years 

before the insolvency of our Plan. The insolvency of the PBGC would mean that the PBGC would not 

have enough money to provide the guaranteed benefit and your monthly benefit provided through the 

PBGC would be reduced to almost nothing. The Pension Recovery Plan is structured to avoid the Plan's 

insolvency and the involvement of the PBGC, and ensure the continuation of your monthly benefit 

payments indefinitely. 

The Board of Trustees recommends you support and approve the Pension Recovery Plan. 

Document #22.1 

SWORCCPP2018-000145
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #23 – 6.02 Proposed Partition 

Does application indicate whether the plan sponsor is requesting approval from the PBGC of a proposed 

partition under Section 4233 of ERISA? 

See Section 6.02 of Revenue Procedure 2017-43. 

The Application filed on behalf of the Southwest Ohio Regional Council of Carpenters Pension Plan does 

not include a request for partition under Section 4223 of ERISA. 

SWORCCPP2018-000146
 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #24 – 6.02 Effective Date of Proposed Partition 

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 Revenue Procedure 2017-43. 

Not Applicable. The answer to Checklist Item No. 23 indicated that no request would be made to the 

Pension Benefit Guaranty Corporation for a proposed partition. 

SWORCCPP2018-000147
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # – 31-6127287/001 

Checklist Item #25 – 6.03 Actuarial Assumptions Used for Projections 

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 Revenue Procedure 2017-43; 

▪ 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 Revenue Procedure 2017-43. 

The information requested above is set forth in the attached Document 25.1. 

Document #25.1 

SWORCCPP2018-000148
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

The information requested in Section 6.03 and Appendix B of Revenue Procedure 2017-43 is set forth in 

the following attachments: 

1. Appendix B 

2. Addendum 1 to Appendix B 

3. Addendum 2 to Appendix B 

4. Addendum 3 to Appendix B 

5. Addendum 4 to Appendix B 

Document #25.1 

SWORCCPP2018-000149
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

Appendix B 

Document #25.1 

SWORCCPP2018-000150
 

 

 

 

 

 

APPENDIX B 

INFORMATION ON ACTUARIAL ASSUMPTIONS AND METHODS

Appendix B details the information requested in Revenue Procedure 2017-43 Appendix B on actuarial 

assumptions and methods that, pursuant to section 6.03 of this revenue procedure, must be described in an 

application for approval of a proposed benefit suspension. 

Investment Returns

Detailed information regarding our proposed investment rate return assumption along with supporting 

documentation is shown in addendums 1 & 2. The proposed assumption used in our Application for

Suspension and subsequent documentation is 6.64% for the first 10 years (2018-2027) and 7.13% thereafter 

(2028+).

Marquette Associates, the Plan's investment consultant, provided the model that was used to inform and 

support this proposed investment return assumption. Please note that they have used stochastic projections

to prepare the results presented in their December 11, 2017 memorandum, but we will be using deterministic

projections based on these results in our projections. The answers provided reflect stochastic projections 

based on their modeling software. In developing our proposed assumption, we have relied on the judgment 

of investment professionals as well as our own professional knowledge in determining that the assumption

is our best estimate for the purpose of this measurement. We are not investment professionals and we rely 

on our colleagues who work in this field for guidance as provided by the Actuarial Standard of Practice. 

Mortality Assumptions

Standard mortality tables were used. 

Non-Disabled 

Disabled

RP-2014 with Blue Collar adjustment. 

RP-2014 Disabled Retiree. 

Base Year Adjustment 

Future Projections 

2006 using Scale MP-2014. 

Projected generationally using Scale MP-2016.

This Plan’s participants consist primarily of blue collar workers. We have relied on the blue-collar mortality

rates in the RP-2014 Mortality Tables Report issued by the Society of Actuaries as the mortality experience 

for this plan. As is explained in the Society of Actuaries release of Mortality Scale MP-2016 we have 

adjusted the base table to 2006 using MP-2014 and projected generationally using MP-2016.

Other demographic assumptions

Please see addendum 3 and the summary included in the Supplemental Actuarial Information Report. 

SWORCCPP2018-000151
 

 

 

 

 

 

Assumptions regarding form and commencement age of benefits 

Please see addendum 3 and the summary included in the Supplemental Actuarial Information Report. The 

probability of any given payment form is independent of age and status. 

The payment form election assumption incorporates the changes to the optional forms included in the 

proposed Plan Amendment. The table used is below. 

 Payment Form % Electing 

Joint & 100% Survivor 32%

Joint & 50% Survivor 16%

Single Life Annuity 52%

Assumptions regarding missing or incomplete data 

We valued all participants that were provided to us by the Plan Administrator. Please see addendum 3 

which details the assumptions used to fill in missing data. For those that are assumed to elect a payment 

form with a beneficiary, it is assumed that wives are 3 years younger than husbands. 

New entrant profile 

Entry Age Sex Entry Age 

Accrued Benefit 

Entry Age 

Service

Weighted Percentage

of New Entrants 

19.1

22.7

27.5

32.5

37.3

42.5

47.3

52.5

57.0

M 

M 

M 

M 

M 

M 

M 

M 

M 

$333.65

$422.52

$423.70

$472.74

$505.04

$470.10

$563.70

$596.03

$594.10

0.8

0.9

0.9

0.9

0.8

0.9

0.9

0.8

0.8

1%

11%

13%

16%

17%

14%

13%

11%

4%

Please see addendum 3 for more detail on the development of each profile.

SWORCCPP2018-000152
 

 

 

 

 

 

Contribution rates and base units 

Please see addendum 4 for detail on the history of employers that contributed 5% or more of annual 

contributions to the plan.

The assumed contribution rate for each year during the projection period is $6.88 per hour.

The assumed contribution base units for each year during the projection period is 2,150,000 hours. This 

represents an assumption of 1,275 hours per year per active participant. 

Historical trends in contribution rates and base units 

Over the past 10 years, the construction industry in Southwest Ohio has seen significant volatility in its

workflow. In 2007, the Plan had 3.2 million hours worked and the pipeline of future projects, membership

and contractors was strong. However, with the economic collapse of 2008, not only did the Plan lose 

significant assets on its investments, it also saw a significant slowdown in work projects and in its pipeline

of future construction projects. Similar to the rest of the economy, the industry saw a decline in available 

work as capital investment dried up and this had a direct impact on work hours. Projects began returning in

2011 and 2012, especially with respect to government funded projects, allowing the CBUs to increase.

However, in 2009 and 2010 a significant loss in membership and contractors caused a supply shortage and

impacted the ability to pursue available projects. 

Given the nature of construction industry work, much of the work hours and contributions received are 

based on project driven work that is cyclical and volatile in nature. This volatility is exacerbated by the 

reliance on extremely large projects in the jurisdiction of the local. An example of an event that could 

have a significant impact on the CBUs for a plan such as this would be the building of a sports stadium or 

installation of a new power plant. The cycles shown are consistent with other local industries and reflect 

the cyclical nature of large project construction industry work. 

The sharp drop in average contribution rate can be attributed in part to the temporary additional 

contribution of $2.00 per hour that was made from July 1, 2007 through August 31, 2008. This was 

accomplished by the diversion of a portion of hourly contributions the bargaining parties had allocated to 

the Ohio and Vicinity Regional Council of Carpenters Health and Welfare Plan. This is further detailed in 

Checklist Item #17 of the application. This increased contribution rate accounted for the higher than 

expected average contribution rates in the 2007 and 2008 Plan Years. The 2009 Plan Year average 

contribution rate was impacted by many members working outside of the jurisdiction in surrounding areas 

that had lower contribution rates than the Journeyman Rate in Southwest Ohio. 

Rationale for selection of contribution base unit and contribution rate assumptions

We would note that this is a construction industry plan and that the work is cyclical and large-project

oriented in nature. Determining an ongoing assumption is difficult given the inconsistency of CBUs from 

year to year. In a plan such as this, defining an ongoing assumption for hours presents numerous challenges 

including: uncontrollable market influences, the impact of the legislative environment, volatility of projects, 

and future predictions of labor and contractor supply.

SWORCCPP2018-000153
 

 

 

When preparing our assumption, we have attempted to take into account this cyclicality and that recent

years are believed to be at a peak. This assumption reflects input from the trustees as to the expected work 

going forward and represents our best estimate of ongoing average CBUs. We rely significantly on their

industry expertise and experience in determining this assumption. While we would not expect every year 

to be flat, we believe guessing in regard to the timing of the peaks and troughs of the work cycle does not 

provide the best estimate in future years. Instead we have used a reasonable estimate of the average ongoing

CBUs expected in the future. 

The flat contribution rate reflects the rates negotiated in the current Rehabilitation Plan. We have not 

assumed any future additional contribution rate increases in our projections. 

Employer withdrawals and withdrawal liability payments 

The withdrawal liability payments are based on currently negotiated withdrawal liability payment streams 

being received. No assumption has been made regarding future withdrawal liability payments expected to 

be collected. We have merely reflected already settled payments that have been deemed collectible. 

The Plan is a building and construction industry plan. As a result, a complete withdrawal occurs only if an 

employer ceases an obligation to contribute to the Plan and continues to perform work (or resumes such 

work within 5 years) in the jurisdiction of the collective bargaining agreement of the type for which 

contributions would have been due. Thus, if a contributing employer to the Plan closes its business and 

does not resume such work without an obligation to contribute, then no withdrawal has occurred. 

The Plan has not had very many withdrawals within the last 5 years. Most of the Plan’s withdrawals 

occurred immediately following the financial crisis from 2009 through 2012, of which the Plan has been 

very aggressive and had significant success collecting such amounts. For employers with a year of 

withdrawal date of 2013 or after, the Plan has collected approximately 89% of the assessed amounts. 

Administrative expenses

Assumed administrative expenses paid by the plan, other than investment-related expenses, are assumed 

to be $1,800,000 in 2018; $1,000,000 in 2019 and increased 3.0% per year thereafter. The higher amount 

in 2018 reflects the cost of preparation, submission, and communication of the Pension Recovery Plan.

Projection methodology

No approximation or data grouping techniques were used. No changes were made to the programming of 

the actuarial software used, nor were modifications made to the resulting cash flow projections provided 

by such software. 

SWORCCPP2018-000154
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

Addendum 1 to Appendix B 

Document #25.1 

SWORCCPP2018-000155
 

 

 

 

 

 

 

•,,-• MarquetteAssociates 

To: Southwest Ohio Regional Council of Carpenters Pension Fund 

From: Marquette Associates (“Marquette”) 

Date: December 11, 2017 

Re: Long-Term Asset Allocation Projections 

The following memo is in response to a specific request by the Southwest Ohio Regional 

Council of Carpenters Pension Fund (the “Pension Fund”) to provide an asset allocation 

study that goes beyond the typical ten-year period, and to further provide a tiered 

expected return over time. Any asset allocation study run by Marquette in its capacity 

as Investment Consultant is for the exclusive benefit of the Pension Fund in accordance 

with the terms of the Investment Consulting Agreement between the Pension Fund and 

Marquette. Marquette understands that certain aspects of any asset allocation study 

may be used as an additional resource for Cuni, Rust & Stenk, on behalf of the Pension 

Fund, in developing an appropriate actuarial investment return assumption. Under no 

circumstances should any asset allocation study be construed as a recommendation or 

determination by Marquette regarding the appropriateness of any actuarial investment 

return assumption used by the Pension Fund. 

Marquette’s Model 

Marquette’s asset allocation software is based on a Monte Carlo simulation of 

macroeconomic factors, which are used to model monthly return outcomes of capital 

markets. The simulations are created by a powerful economic scenario generator 

(“ESG”), which is the driving force behind the asset allocation model. The ESG simulates 

the future performance of the capital markets and macro-economy; the underlying 

models are calibrated based on long-term historical data series, so that they will 

reproduce the kinds of volatility and stress scenarios that have been observed over the 

20th and 21st centuries. The models are linked and correlated so that the behavior of 

different asset classes and economic variables is consistent within each random scenario. 

Long Term Assumptions 

Marquette provides asset allocation studies to simulate client portfolio performance 

over the course of the next ten years. While the Monte Carlo analysis used in the studies 

can be extended to model longer time frames, Marquette calibrates the simulation 

process to a ten-year forecast due to the erratic nature of financial markets and the 

dynamic changes that can take place in the global economy over the course of time, 

both of which make it extremely difficult to make predictions beyond a ten-year period 

with a reasonable level of accuracy. As a result, while the asset class assumptions used 

SWORCCPP2018-000156

1 
•• 

in Marquette's studies may change beyond the ten-year mark (mainly due to mean 

reversion) we do not make any specific deviations in our projections after this period. 

If the Monte Carlo analysis were to be extended past the ten-year time frame, fixed 

income would be the most impacted asset class w ith projected improved returns d ue 

to a normalization of interest rates that is still occurring after ten years in Marquette's 

current asset allocation model. As a result, the revised asset allocation study would 

project higher overall portfolio performance over the long term. The below chart sets 

forth the projected returns for the Pension Fund using the extended time frame: 

Yea rs Years 1-10 Yea rs 11 -20 Total 20 Yea r Period 

Total Portfolio Expected Return1 6.64% 7.13% 6.86% 

Recommendation 

While Marquette's asset allocation model has the ability to provide expected returns for 

longer t ime horizons, the accuracy of the model's forward-looking assumptions 

decreases as the t ime period extends beyond ten years. As such, Marquette 

recommends utilizing asset allocation studies based upon a ten-year t ime frame. We 

also recommend running additional asset allocation stud ies on a regular basis to make 

sure the assumptions used in the model are up to date and account for any changes in 

the broad macro environment. 

1 Returns are annualized returns based on the average 10 year and 20 year ret u rns generated in 1,000 

M onte Carlo simu lat ions. 

,..- MarquetteAssociates December 11, 2017 I 2 

SWORCCPP2018-000157 
 

 

 

 

•,.. • MarquetteAssociates 

The sources of information used in this study are believed to be reliable. Marquette 

Associates, Inc. has not independently verified all of the data used in this study and its 

accuracy cannot be guaranteed. Estimates and projections of financial market 

performance do not guarantee future performance. Since the model used to create this 

report relies on market data, results will vary depending on the date of the study. Past 

study results do not guarantee future results and are subject to change as more data 

becomes available. As appropriate, Marquette Associates, Inc. reserves the right to 

adjust the model used to prepare the study to reflect improved accuracy of portfolio 

modeling techniques. Results may change if the model is adjusted. 

About Marquette Associates 

Marquette Associates is an independent investment consulting firm that helps 

institutions guide investment programs with a focused three-point approach and 

carefully researched advice. For more than 30 years, Marquette has served this mission 

in close collaboration with clients – enabling institutions to be more effective investment 

stewards. Marquette is a completely independent and 100% employee-owned 

consultancy founded with the sole purpose of advising institutions. For more 

information, please visit www.marquetteassociates.com. 

December 11, 2017 

SWORCCPP2018-000158

3 
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

Addendum 2 to Appendix B 

Document #25.1 

SWORCCPP2018-000159
 

 

 

 

 

 

 

 

 

The following answers are specific to the asset allocation studies conducted by Marquette 

Associates, Inc. (“Marquette”). The asset allocation studies were run for the exclusive benefit 

of the Southwest Ohio Regional Council of Carpenters Pension Fund (the “Pension Fund”) in 

accordance with the terms of the Investment Consulting Agreement between the Pension Fund 

and Marquette. Marquette understands that certain aspects of the asset allocation studies may 

be used as an additional resource for Cuni, Rust & Stenk, on behalf of the Pension Fund, in 

developing an appropriate actuarial investment return assumption. Under no circumstances are 

the asset allocation studies to be construed as a recommendation or determination by 

Marquette regarding the appropriateness of any actuarial investment return assumption used 

by the Pension Fund. 

• Net investment return for deterministic projections. 

Not applicable 

• Assumptions used for stochastic projections (if applicable). Provide the expected 

geometric returns, arithmetic returns, and standard deviation of returns for each 

asset class in which the plan is invested (or is expected to be invested), including the 

probability distribution of returns (e.g., normal or log-normal) along with any 

correlations used in the projections, including correlations among asset returns (and 

serial correlations, if any). 

Marquette’s asset allocation software is based on a Monte Carlo simulation of macroeconomic 

factors, which are used to model monthly return outcomes of capital markets. The simulations 

are created by an economic scenario generator (“ESG”), which is the driving force behind our 

asset allocation model. The economic scenario generator simulates the future performance of 

the capital markets and macro-economy; the underlying models are calibrated based on the 

long-term historical record so that they may reproduce the kinds of volatility and stress scenarios 

that have been observed over the 20th and 21st centuries. The models are linked and correlated 

so that the behavior of different asset classes and economic variables is typically consistent 

within each random scenario. 

GEMS® is a state-of-the-art ESG developed by Conning's team of quantitative finance experts, 

and its financial models are among the most technologically advanced in the industry. It has won 

InsuranceRisk’s “Best ESG Software” award three times. 

GEMS® enables users to simulate future states of the global economy and financial markets, 

including the pricing of derivatives and alternative assets. It uses advanced modeling and 

estimation technology to produce empirically validated, realistic economic behavior to give 

clients a better understanding of risk. 

GEMS® is distinguished by its: 

• Ability to model asset prices and cash flows at the security level 

• Default-free interest rate models which produce fully integrated nominal and real term 

structures 

• Corporate and municipal bond credit models that permit the simulation of rating 

transitions, defaults and recoveries 

SWORCCPP2018-000160
 

 

 

 

 

 

• Inflation model that permits modeling of inflation derivatives and inflation-linked bonds, 

including those with embedded caps and floors 

• FX model, which provides consistent inter-economy behavior 

• Comprehensive modeling of interest rate, equity, inflation and FX derivatives 

• Wide range of standard asset classes and market indices, along with tools that allow 

users to create customized asset classes 

• A global economy of intra- and inter-linked, correlated economic currency zones 

• Best-of-breed fits to the widest range of market prices across interest rate curves and 

derivatives, credit spread curves, equity options, and inflation-linked derivatives 

• Advanced user estimation tools allowing fast efficient recalibration of GEMS models to 

incorporate different views of the future economy including tails 

GEMS® generates a wide range of financial, economic and macro-economic variables, including 

government bonds, corporate bonds, multiple correlated common stock indices, alternative 

investment classes, mortgage-backed bonds and CMOs, municipal bonds, real estate, actual 

and expected multiple inflation indices, nominal and real GDP growth rate, foreign exchange, 

and the unemployment rate, as well as a rich set of derivatives on interest rates, equity, inflation 

and foreign exchange. 

The currency zones which are currently parameterized as part of the standard quarterly process 

are USD, EUR, GBP, CHF, AUD, CAD, JPY, NOK, SEK, DKK, PLN, BRZ, CZK, CYN, HKD, KRW, 

TWD, SGD, THB and MYR. Economies can expand quite flexibly, dependent only upon data 

being available to support calibration. This GEMS® global economy is parameterized as a single 

process, thus capturing all of the inter- and intra-dependencies. 

The simulated global economy manifests itself as a distribution of possible economic futures, 

including the unexpected but plausible outcomes that are critical to assessing risk. GEMS® 

generates realistic and empirically validated economic behavior that allows a business model to 

be stochastically tested under a wide variety of economic conditions. Such robust analysis 

permits the development of a detailed understanding of the risks a firm faces, as well as a solid 

understanding of the relationship between those risks and the potential rewards in retaining 

them. GEMS® allows dynamic modeling of these risks and the mitigation strategies that a user 

might adopt, enabling management to shape the profile of the firm to suit its tolerance for risk 

and to develop guidelines for maintaining its desired risk profile. 

GEMS® is a powerful tool designed to solve actual business problems. Real world scenarios are 

designed to generate simulated future data which have the same dynamic characteristics as the 

real market, and this is ensured through the thorough and regular validation and back testing 

that is shared with our users. 

There is no upper limit on the number of scenarios that the system can produce. GEMS® can be 

run at more granular time steps, down to daily, though monthly, quarterly and annually are the 

most commonly implemented. 

A full range of calibration and target parameterization tools are available for user customization 

of their own view of the economy within the cascade structure of GEMS® models for stress and 

other analyses. 

SWORCCPP2018-000161
 

 

 

The raw output from the economic scenario generator includes: 

• Yield curves — for government bonds, inflation linked bonds, and corporate bonds by 

rating category (AAA, AA, A, BBB, and High Yield composite), every maturity point on 

the yield curve is calculated, for both par and zero coupon bonds. 

• Equity indices — both price and dividend yields are simulated 

• Market indices — both price and dividend/income yields are simulated 

• Return series — for any asset class modeled or any user-defined blend of asset classes, 

GEMS® will produce price, income and total return series, 

• Economic variables— for inflation, GDP and unemployment, GEMS® will produce the 

relevant index levels and growth rates 

• FX — exchange rates are produced between each pair of modeled economies. 

Model Interaction and Structure 

Correlation between simulated variables is an important issue to consider and vital in capturing 

the risks associated with multi-asset-class investments. The simultaneous movement of 

investment returns and how this changes under differing economic conditions are arguably the 

most important factors in accurately assessing and managing the market risk a firm faces. 

Capturing correlation in a realistic manner is essential to properly understanding the 

diversification and concentration effects among assets and to obtain reliable calculations of risk 

and solvency capital requirements. 

All GEMS® economies are available on a stand-alone basis as well as jointly within a global 

economic framework. Whether running a stand-alone or multi-economy model, the variables 

within GEMS® are linked dynamically within an economy. For multiple economy simulations, 

variables are also linked across economies. 

Enabling correlated behavior between different components of a model within an ESG is as 

much a technological challenge as a theoretical one. Within GEMS®, three primary mechanisms 

are applied to enable correlation: 

1. Direct functional relationships among the economic models. 

2. Correlation of the independent random processes associated with the models. 

3. Correlation of jump processes to enable enhanced correlation in the tails of distributions 

where appropriate. 

These methods are the most commonly used and well-researched for enabling joint behavior. 

The former is introduced through a cascade structure, wherein each economic model forms an 

interconnected network. In a cascade structure, scenario generation is governed by a welldefined sequence in which variables at the top of the structure can only influence those below. 

The exact sequence of the variables is to some extent arbitrary; however, interest rates are often 

used as a starting position, and since one may need to calculate discounted cash flows through 

the life of a simulation, it is for practical reasons an obvious choice. Indeed, within the GEMS® 

ESG the cascade structure, shown below, begins with the non-defaultable term structure model, 

SWORCCPP2018-000162
 

 

 

 

 

 

Market 

Variables 

Mortgage 

Bonds 

Corporate 

Bonds 

Municipal 

Bonds 

Property 

j 

Inflation Rate 

Real & Expected Macroeconomic 

Variables 

Treasury 

Bonds 

~-::,,,.,- ( Unemployment ) 

r -

I ,------------, 

Mortgage Bond 

I Prepayment Rates 

Corporate Bond 

Recovery Rates 

Corporate Bond 

Default Rates 

Corporate Bond 

Spreads 

Property Rental 

Yields 

1 _______ _ 

'-........._ - ~ ,---. 

...........__--............_/- GDP 

Equity Dividend 

Yields 

/ 

I 

I 

I 

Property Rates 

of Return 

---- --------- -, 

Equity Rates 

of Return 

I 

I 

I 

Primitive 

Processes 

Treasury Bond I 

Short Rate I 

Treasury State 

Variables 

Equity State 

Variables 

proceeds through equities and macroeconomic variables to end with unemployment (see the 

diagram below). 

The latter two methods in practice involve applying the Cholesky decomposition of a covariance 

matrix to the vector of independent random processes driving the stochastic processes. While 

the estimation of the covariance matrix requires careful consideration, this approach has 

significant advantages, since the mean correlation can be controlled to some extent while 

allowing for simulated paths which exhibit a range of different correlation values. 

Extreme care must be taken in the development and estimation of global economies, and 

GEMS® excels in this respect. Some models may claim to offer a global economy, but in fact a 

detailed look reveals that individual economies are simply joined together in an arbitrary manner 

(e.g., by the use of a static covariance matrix) and thereby fail to capture the true intricacies of 

the global economy, such as enhancements in correlation in the tails of the distribution. Where 

appropriate, GEMS® models have been built to respect the relationships between variables, 

including tail correlation, such that contagion effects in economic crises are properly modeled. 

This approach is somewhat sophisticated, but it is necessary, especially when determining the 

tail measures commonly used for risk management purposes today (e.g., VaR). 

The result of this approach enables GEMS® to show realistic relationships between variables on 

average, over different time horizons, and in tail events. Examples include: 

• Capturing the contemporaneous correlation between projected US equity and 

corporate credit are within 0.07 versus historical average for all five rating classes 

• Tail correlations are captured exhibiting a strong relationship of tail correlations 

between equity and corporate credit within an economy and equity across economies 

SWORCCPP2018-000163
0.35 - SP500 vs High Yield Bonds -

- SP500 vs BBB Corp Bonds 

0.3 +-~-------------------

- SP500 vs A Corp Bonds 

0.25 -+----+------------------- SP500 vs AA Corp Bonds _ 

- SP500 vs AAA Corp Bonds 

C: 0.2 

.Q 

-IQ 

ai 0.15 

t: 

0 

u 0.1 

0.05 

0 

0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 

-0.05 

Percentile of S&P500 Returns 

Source: Conning/GEMS@ Simulation 

• Capturing the d ifferent relationship between variables over time and across modeled 

projections. Historica l relationships of US Equities and Treasuries have varied over time 

and depending on horizon. The first chart below shows the historical rolling correlations 

since 1950. Two observations that can be made are that the relationship varies over time 

and the correlation between the two variables decreases as the horizon increases. The 

second chart shows the path wise correlation between the two variables for a 50 year 

monthly projection of 1000 scenarios from GEMS®. The first column shows the measure 

for each path and the second the second is the statistic across the paths (i.e., the 

average of the minimum 1 year rolling correlation of each path is -0.63). 

SPX & Int TSY - Rolling Monthly Correlations 

1.00 

0.80 

0.60 

0.40 Ill 

5 0.20 --l YR

~ 0.00 --SYR 

~ (0.20) - lOYR 

u (0.40) 

- 20YR (0.60) 

(0.80) 

{1.00) 

0 1/'l 0 1/'l 0 1/'l 0 1/'l 1/'l 00 00 m § ...c m m m m m 8 0 ...c ...c ...c ...c ...c N N N 

SWORCCPP2018-000164 
.1 

0.08 

0.06 

. C: ~ 

., 

0 . .. 0.04 0.:: 

.f: 

>-

0 

>-

~ 0.02 

::> 

0 

• 

.\• 

-0.02 

-0.04 

0.02 

UK 1 Year Yield 

... 

. . . 

• 1st Quintile 

 2nd Quintile 

3rd Quintile 

• 4th Quintile 

• 5th Quintile 

0.16 

Source: Bloomberg 

Historical Data GEMS Difference 

Meaure Over Paths 1 5 10 20 1 5 10 20 1 5 10 20 

Min -87% -47% -32% -16% -92% -50% -35% -24% -5% -3% -4% -8% 

Min Average -87% -47% -32% -16% -63% -25% -15% -7% 24% 22% 17% 9% 

Max -87% -47% -32% -16% -35% -4% 0% 10% 52% 42% 32% 26% 

Min 11% 9% 9% 17% -13% -14% -14% -15% -25% -23% -23% -31% 

Avg Average 11% 9% 9% 17% 0% 0% 0% 0% -11% -9% -10% -17% 

Max 11% 9% 9% 17% 16% 14% 14% 15% 5% 5% 5% -2% 

Min 79% 56% 53% 33% 34% 5% -4% -8% -45% -50% -57% -41% 

Max Average 79% 56% 53% 33% 63% 25% 15% 7% -16% -31% -38% -25% 

Max 79% 56% 53% 33% 94% 55% 33% 21% 14% 0% -19% -11% 

Source: Bloomberg/GEMS® Simulation 

• Reflecting dependence of variable to different values as seen between UK 1 year yields 

and UK YoY Inflation. 

Historical Data 

Source: Bloomberg/Conning 

SWORCCPP2018-000165
 

 

 

.3 

0.25 

- .·· 

0.2 .. C 

0 

:;::; 0.15 ~ .!: •, 

>- ,• 

0 

>- 0.1 ~ 

:::> 

0.05 

0 

-0.05 

-;· 

~--:. · ·· .. . ·· .. .. . ...... . ··:.· .

R2_.=:= 0.0032 ~ ~4:-:=~---:-7~;,.-,-:..:... 

· R2 = 0.0099 

,.. R2 = 0 0237 

R2 ~ 0.305 -

0.1 0.12 0.1 4 

UK 1 Year Yield 

R2 = 0.0009 

0.16 0.18 

GEMS® Simulated YoY Inflation and 1 Year Yield 

Source: GEMS® Simulation 

Model Selection 

In general, the approach Conning takes to determine model selection for GEMS® is to work with 

industry and academic experts to thoroughly research the known literature on economic and 

financial models and choose the models which best meet the following criteria: 

• Ability to replicate the stylized facts of the historical record. It should be possible to 

parameterize the model in such a way as to produce future paths which have similar 

features and qualities as the historical data. 

• Ability to reproduce prices of market instruments. A well-specified, well-parameterized 

model will give reasonably accurate prices for traded securities. 

• Ability to produce novel yet plausible paths. There should be enough sources of 

variability in the models to produce a rich set of stochastic movements, potentially 

revealing risks that would not emerge in a simpler model. 

• Stable parameterizations. The stability of the estimated parameters over time is evidence 

that the model is well specified and likely to produce results that are robust under varying 

economic conditions. 

• Computational efficiency. Some models have properties that make them efficient to 

implement computationally. Such models lead to faster run times and are likely to 

produce more accurate results. 

SWORCCPP2018-000166
 

 

• Suitability for real world and risk neutral applications. Where possible it is desirable to 

implement a single model for both real world (e.g., risk management, SCR, Investment 

management) and risk neutral applications (asset pricing, MCEV). This approach allows 

users to have consistency in modeling approach across different parts of its business, 

satisfies a more literal interpretation of the Solvency II use test, and only requires users 

to understand the workings of a single model rather than multiple. 

An overview of some of the models which are incorporated within GEMS® is shown in the table 

below. 

SWORCCPP2018-000167
Model Type Key Attributes 

Interest 

Rates 

3-factor 

Affine Model 

. Rea listic yield d istributio ns 

. Produces all commonly observed yie ld curve shapes 

including inversions 

. No exploding yie lds 

. The ability of the model to fit the initial yie ld curve 

. Fo r MCEV risk-neutral applications the model can fit the 

entire swaption implied volatility surface, not just a 

li mited number of points 

Corporate 

Bonds 

GEMS 

Corporate 

Security 

Model 

. Model of individual bonds 

. Stochastic spreads and stochastic tra nsition and default 

incorporated 

. Issuer concentration risk can be captured 

. Incorporates liquidity component 

GEMS 

Corporate 

Yield Model 

. Stochastic spreads 

. Stochastic tra nsitio n and default dynamics 

. Abil ity to produce the jump-like behavior in spreads 

observed during the 2008 crisis (RW) 

. Ma rket-consistent fits to the initial spread curves across 

multiple ratings 

. Correlations between spreads or d iffe re nt ratings <1 and 

close to market va lues 

Equity SVJ 

(Stochastic 

Volatility with 

Jumps 

. Rea listic return and volatility behavior 

. Jump p rocess produces crisis-like events 

. Able to price derivatives, including volatility "smile" 

. Ability to fit to market prices of options 

Inflation 4-factor 

Affine Model 

. Rea listic interest rate and inflatio n dynamics 

. Rea listic rea l yield curve dynamics 

. Inflation derivatives priced 

. Abil ity to fit the initia l BEIR o r Real Yie ld Curve at time 

zero 

Fore ign 

Excha nge 

Heston . Stochastic volatility of FX rates incorporated 

. FX derivatives priced 

GDP VarX . Rea l and nominal GDP modeled 

. Direct li nk between GDP and other variables (e .g., 

interest rates) 

SWORCCPP2018-0001 68 
 

 

 

 

GEMS® Models 

The following is a list of the primary asset classes, instruments and financial variables modeled 

within GEMS®: 

• Interest rates and non-defaultable bonds 

• Equity indices and dividends 

• Corporate bonds, credit spreads, prices and transition and default 

• Sovereign debt, including spreads and defaults 

• Inflation (core, medical, wage) 

• GDP 

• Unemployment 

• U.S. Mortgage backed bonds 

• U.S. Municipal bonds 

• Covered Bonds 

• Real Estate 

• FX 

• Multiple alternative investment indices (Private Equity, Emerging Market Equity, Debt, 

etc.) 

• A wide range of derivatives on underlying 

o Interest rates 

o Equity indices 

o Inflation 

o FX rates 

Yield Curve Modeling 

The GEMS® Non-Defaultable Term Structure model is a multifactor stochastic model, where 

the level of the curve begins at current market values and tends towards long-term means over 

time. 

The benchmark interest rate model implemented in GEMS® is an 3-factor affine square root 

model. Users may extend or reduce the number of factors in this model by modifying the 

parameter values. In this way, the simpler model of Cox-Ingersoll-Ross may be reproduced. The 

Vasicek model, while not of this form, may be approximated in this framework. This model has 

been chosen for the following reasons: 

• Produces a more varied range of yield curve shapes than competing models 

• The model is mean reverting 

• Yields do NOT explode 

SWORCCPP2018-000169
 

 

 

 

 

 

 

 

 

 

 

 

 

 

• Closed and semi-closed form solutions for a wide variety of bonds and derivatives 

• Stable estimation with Kalman filtering and maximum likelihood method is possible 

• The model has both real world and risk neutral formulations 

• Admits closed formula to predict the distributional moments of the model at future time 

horizons enabling simpler recalibration to user defined targets 

With the three factors that are parameterized by default, GEMS® captures all major types of 

yield curve movement (shift, slope, curvature). The model has a close fit to observed market 

volatility and derivative prices, and can produce skewed distributions. The model also 

incorporates mean reversion and thereby produces stable but robust long-term simulations, as 

opposed to Market models such as Libor models, which often lead to explosive interest rates. 

The model is based on the work of Cox, Ingersoll, and Ross, and contains the single-factor CIR 

model as a special case. The extensions in the model allow for a richer universe of yield curve 

shapes. The model has a close fit to observed market volatility and derivative prices, and can 

produce heavy-tailed and skewed distributions. The model also incorporates mean reversion, 

and, thereby, produces stable but robust long-term simulations. In addition, the shift parameters 

and time-heterogeneous parameters allow very low interest rate and negative interest rate 

scenarios to be produced. 

The instantaneous volatility in the GEMS® model (and all other commercially available ESG’s) is 

static, however by virtue of the multi-factor square root diffusions in the model, measures such 

as rolling volatility, or the volatility of bond returns will appear stochastic and time-varying. For 

example, the GEMS® model is flexible enough to incorporate the fact that when interest rates 

are high, bond return volatilities are high. 

The model performed extremely well during the 2008 crisis in terms of capturing the sudden 

drop to a low interest rate environment experienced during that time, as well as the return 

characteristics of bond indices and portfolios. 

Defaultable Sovereign Debt Model 

The events post 2007 brought back into focus the risks of investing in Sovereign debt, and the 

fact that movements in asset prices arise from a variety of sources including the potential of 

default. The potential for default has become of increasing interest to risk management 

practitioners, investment professionals and regulatory bodies around the world. In response to 

this the GEMS Economic Scenario Generator contains a model of defaultable sovereign debt. 

The model is based on extensive research of historical Sovereign debt defaults and 

restructuring, and is intended to give a realistic representation of how government debt 

portfolios respond to these events. The model is intended to give users a more complete and 

granular approach to assessing risk, making investment decisions and determining regulatory 

capital requirements than the current standard market approaches. 

A model of non-defaultable debt, even one with built in high volatility, is structurally incapable 

of capturing the effects of Sovereign debt crises on a portfolio of such bonds. The GEMS 

Defaultable Sovereign Spread Model generates stochastic yield and spread term structures for 

both high and medium risk classes of Sovereign bonds corresponding to elevated and moderate 

levels of default probability and loss severity. As in the real market, default triggers a percentage 

SWORCCPP2018-000170
 

 

 

 

 

 

0.06 

0.05 

0.04 

"O 0.03 ~ 

f 

Q. 

~ 0.02 

0.01 

0 

~ 

-0.01 ~ -~ 

Historical Spread on High Risk Combined Spanish and Italian 

Government Bonds (1997-2012) 

.. ········· 

......... ..,,. l() IC IC t-- t-- 00 00 ~ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 --

0 

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 

-- -

sc ~ -

QO -;:;:; -- Q in -

N --i:"::: N -=-i 

- - -- - - -

-- N 

--

0 0 -0 

~ ~ ~ 

-~ --

sc -- --High Risk 3M ----High Risk SY ······· High Risk lOY High Risk 30Y 

- - 1 

-.2 -.15 -.1 -.05 

40 

30 

.05 

:----+ 

.I .15 

simulated 

histoml 

of the invested capital to be lost at a specified loss rate. The model produces as output a term 

structure of yields and spreads. Spread dynamics such as those shown in figure 2 exhibiting long 

periods of active spreads followed by long periods of dormant spreads are faithfully reproduced 

by the model. 

Historical spreads on different maturities of high risk Eurozone government bonds, 

based on a combined time series of Spanish and Italian bonds. Source: Conning/Bloomberg 

The figure at right shows the return 

characteristics of the model compared to 

the historical weighted average returns of 

a portfolio of Spanish and Italian bonds. 

Clearly the bulk of the historical return 

distribution is well matched by the GEMS 

Defaultable Sovereign Spread Model. 

Additionally, the model has a clear tail 

structure which is driven by rare but 

severe default events within the bond 

portfolio. It is these types of events which 

are essential for understanding the risk profile of this asset class, and which cannot be captured 

by traditional non defaultable approaches. These combined features make the GEMS 

Defaultable Sovereign Spread Model the most realistic and robust model incorporated into any 

Economic Scenario Generator on the market. 

Corporate Security Model (Corporate Bonds) 

The GEMS® Corporate Security Model is based on a reduced-form approach that was first 

explored in a paper by Duffie and Singleton (see Duffie and Singleton, “Modeling Term 

Structures of Defaultable Bonds,” The Review of Financial Studies, 1999). In this model, 

individual bonds are modeled and corporate yields are generated by adding the credit spreads 

to the corresponding treasury yield. The credit spread is driven by a default intensity process, 

SWORCCPP2018-000171
 

 

 

which also determines each bond’s rating and a liquidity process, enabling the levels of spreads 

observed in the last seven years to be captured and exceeded without overly inflating the 

implied default probability. The evolution of the default intensity determines the migration, if 

any, of a bond’s rating from one class to another. 

Bonds are rated in five categories, which are composites of the rating classes prevalent in the 

markets: AAA, AA, A, BBB and High Yield (includes everything BB and lower). The “market 

curve” for each rating category is fitted based on the modeled spreads of each individual bond 

in that category, much like the actual market curve is calculated. 

Crucially, the default processes for the modeled bonds are linked through systemic risk drivers, 

both to other corporate bonds and to other market sectors. At the same time, each bond will 

have its own, idiosyncratic, default behavior. The proper calibration of the systemic and 

idiosyncratic risk processes creates realistic volatility, correlation and concentration risk 

dynamics. 

This modeling approach offers two key advantages in modeling flexibility: 

• The user can tailor the set of bonds modeled to match the characteristics of the portfolio 

being modeled (important since bonds of the same rating are not priced identically by 

the markets) 

• The user can directly observe simulated effects of rating downgrades and defaults 

There are several types of correlation structures accounted for in the GEMS® corporate bond 

model. The first is the correlation between credit spreads and the equity markets, such that as 

equity markets fall, credit spreads are seen on average to increase, both within GEMS® and 

within real market data. The second is the systematic correlation of all corporate bonds in the 

market. The GEMS® corporate bond model includes a systemic risk factor which causes the 

transition and default probabilities of individual bonds to increase when the entire market 

default rates increase; again this is also observed in real market data. Finally, there is correlation 

between the corporate bond markets of different economies such that credit events in one 

economy will have an impact on the probability of credit events in another economy. 

Corporate Yield Model 

The Corporate Yield Model is an arbitrage-free model for corporate bond prices which 

incorporates a systemic risk dynamic that faithfully captures severe market stresses. It is an 

alternative to the Corporate Security Model described above. In the Corporate Yield Model, 

corporate bonds are assigned a credit rating and each bond is then exposed to the risk of rating 

migration and default risk within a framework that generates sophisticated stochastic spread 

dynamics and captures market correlations with treasury and equity returns. The Corporate 

Yield Model may be used for real world applications and for risk-neutral market consistent 

embedded value (MCEV) applications. The Corporate Yield Model may be calibrated to all initial 

corporate market yield curves. 

The Corporate Yield Model serves two primary purposes. First, it is a next-generation tool for 

risk-neutral MCEV applications which calibrates to the corporate bond market and incorporates 

sophisticated risk dynamics necessary to faithfully capture corporate bond market risk. Second, 

it also provides a robust model for real world applications that includes a jump process and 

SWORCCPP2018-000172
 

 

 

 

 

GEMS Corporate Yield Model Spread Evolution 

Simulntion Quarter 

- AAA 1 yea!' - AA l Yea,· - A 1 Year - BBB 1 Yea!' - HY 1 Yea!' 

stochastic transition matrix, thereby permitting users to include severe market stresses in their 

management of corporate bond investment risk. An example of an extreme path produced by 

the model for ratings AAA, AA, A, BBB and High Yields is shown below. 

U.S. Municipal Security Model 

The U.S. Municipal Security Model provides for a range of credit quality in modeling municipal 

bond positions and incorporates a systemic risk dynamic that faithfully captures severe market 

stresses. Municipal bonds are assigned by users to a given credit type and each bond is then 

exposed to the risk of default and credit spread dynamics that are characteristic of its type. The 

model produces a universe of municipal securities and the individual security data is aggregated 

to obtain representative yield curves just as is done in the real market. The model can be used 

for tax-exempt or taxable municipal securities. The systemic risk dynamic can be adjusted by 

the client to impose their own views on systemic market risk. 

The model permits users to capture the broad range of credit quality that is available in the 

municipal bond market. Additionally, the model includes a realistic systemic risk dynamic that 

enables users to include severe market stresses in their management of municipal bond 

investment risk. Our clients are now able to model a wide range of municipal bond securities in 

a flexible framework which captures the risks they face in today’s municipal bond market. 

Equity Modeling 

Modeling the real world behavior of equity markets accurately is critical to assessing the risk in 

investment portfolios and for uncovering weaknesses in hedging strategies. To reproduce 

stylized facts such as jump dynamics volatility persistence and the kinds of rare, but severe, 

drawdowns observed in times of crisis, it is necessary to use an equity model that combines 

stochastic volatility with a jump (SVJ) process. The SVJ model in GEMS® is based on the paper 

of Bates (2005) and is used to model large cap, mid cap and small cap equity indices as well as 

a range of specialized indices such as the NASDAQ. The core of the GEMS® model is driven by 

the following stochastic volatility jump-diffusion process: 

SWORCCPP2018-000173
 

 

 

 

 

0.16 

0.11 

0.06 

0.01 

-0.04 

-0.09 

-0.14 

-0.19 

-0.24 

0 .1 6 

0 .11 

0 .06 

0 .01 

-0.04 

-0 .1 9 +-------+-----------------------------------< 

-0.24 ~ ----------------------------------------~ 

ddSStt = μμttdddd + �VVttddWWtt

(1) + dddd(VVtt,dd) SStt

(2) ddVVtt = (αα − ββVVtt)dddd + σσ�VVttddWWtt

where the continuous movements in the equity index price and the stochastic volatility 

(governed by W(1) and W(2), respectively) are correlated Brownian motions such that when 

simulated equity markets fall volatility increases. Note also that the volatility enters into the jump 

process dJ, increasing the likelihood of jumps (e.g. crises) when volatility is high, leading to jump 

clustering in periods of high volatility. These effects can be seen if one considers the comparison 

below of daily equity returns for the S&P 500 and GEMS® simulated returns for the same index. 

S&P500 Daily Returns 1926-2005 

GEMS® Simulated Daily Returns 

It is important to note that not all SVJ models are the same. There can be substantial differences 

in results, depending on how the model is parameterized. Poor parameterization will result in 

the model not being able to exhibit behavior consistent with actual historical stylized facts. The 

tremendous success of the GEMS® equity model depends on our ability to robustly parameterize 

the model so that the stochastic volatility and jump aspects of the model are balanced to reflect 

the true market behavior. This balance is achieved through the incorporation of advanced 

estimation techniques and validation based on deep histories of data to determine what tail 

effects are reasonable and desirable. 

SWORCCPP2018-000174
 

 

 

 

 

 

 

The GEMS® equities model enables users to more accurately capture the risks in equity 

investing. It helps prevent correlations from being under or overstated thus correctly stating the 

risk diversification benefits of investing in equity markets. GEMS® also captures the fact that 

equity markets correlation tends to be enhanced when markets experience elevated volatility 

which better positions you to weather the types of turmoil experienced in past economic crises. 

Other Models 

• Foreign exchange — The GEMS® foreign exchange model is a Heston-type model that 

incorporates stochastic volatility of FX rates as well as being arbitrage free and pricing a 

wide range of FX derivatives. In a risk-neutral context the model allows users to fit to a 

market FX option implied volatility surface and the model has been shown to capture 

higher order effects such as smile within these markets. This model represents a 

significant development over other widely available FX models in terms of the features 

already mentioned but also in its ability to produce reasonable FX behavior over long 

simulations. 

• Inflation — GEMS® employs a continuous time model for inflation which is arbitrage free 

and transforms easily from the real world to the risk neutral measure as well as admitting 

closed form or semi-closed form solutions for the pricing of a wide range of inflation 

linked bonds and derivatives commonly traded in the market. The GEMS® continuous 

time arbitrage free inflation model, in addition to inflation, can also: 

 Produce the real term structure of interest rates 

 Produce market expectations of inflation 

 Price inflation linked bonds and derivatives 

 Couple with an econometric model to produce inflation sub-indices 

• Derivatives — The pricing of derivatives within GEMS® is based on the Risk Neutral 

Valuation method (RNV) which calculates the price of the derivative as the expected 

payoff of the derivative in a risk neutral world, discounted at the risk free rate. In practice 

there are a number of approaches to the risk neutral valuation of derivatives, but the 

standard GEMS® approach is to implement models where the change of measure from 

real world to risk neutral can be made at the model level. Where appropriate GEMS® 

implements models in the Affine class which have well documented and well understood 

methodologies for the pricing of a wide range of derivatives (e.g. Duffie, Pan and 

Singleton, “Transform Analysis and Asset Pricing For Affine Jump Diffusions”) and are 

known to outperform less sophisticated models particularly in the pricing of out-of-themoney options. GEMS® prices a market-leading range of derivatives including FRNs, 

interest rate swaps, inflation swaps, FX swaps, Agency CMOs, caps, floors, inflation 

linked caps, inflation linked floors, LPI swaps, reverse FRNs, swaptions and plain vanilla 

options on a wide range of underlying instruments. 

Market Indices 

Asset classes, specific indices or economies outside of the GEMS® core offering can be modeled 

using a flexible framework within GEMS® known as "Market Indices." GEMS® Market indices 

SWORCCPP2018-000175
 

 

 

 

 

 

allows fast, efficient, and robust models to be built and imported directly into the system and 

used for the generation of either real-world or risk-neutral scenarios. The framework allows users 

to define an autoregressive (AR) or vector autoregressive (VAR) models and use other GEMS® 

“core” models (e.g. Equity or Interest Rate Models) as explanatory or exogenous variables (ARx 

and VARX). Items such as private equity, hedge funds, property, and mutual funds can and have 

in the past been modeled using the GEMS® market indices framework. 

Models can either be built by the client or by the Conning professional services team. 

Alternatively, Conning offers training courses on building econometric models to support our 

clients in gaining the maximum benefits from this powerful tool. 

Furthermore, users can write custom business logic by creating customized variables called User 

Values. These variables have access to all the other simulation variables created by GEMS® as 

well as all user inputs (e.g., company-specific holdings or inputs) from the Definition Editor, and 

the user can write Excel-like formulaic expressions using those inputs. Once created, these User 

Values can be used in various places inside the simulation, e.g., to create dynamic trading rules. 

They can also be stored in the simulation output for further analysis in the Query Tool, which 

provides an environment for open-ended query and analysis of the stored simulation data. 

In addition, there is a great deal of flexibility built into GEMS® in terms of which asset models 

to run, which individual securities to model, which simulation output variables to store, and so 

on. These user values can be based on purely user-defined values or on values which are based 

upon or derived from standard GEMS® output, and these may also include advanced features 

such as the addition of a stochastic process. 

Tail Events 

Our models are chosen and calibrated such that simulated variables will exhibit the same 

dynamics as the variables have exhibited in the past. This not only includes the mean and 

standard deviation of returns, but also skewness and kurtosis. These statistics are captured in 

our validation reports. Further, the methods we use to model dependencies between variables 

enable us to capture non-linear relationships. Most notably, this approach captures the tail 

dependence that can occur, resulting in larger portfolio losses than those generated using 

simpler methods. 

An economic scenario generator needs to capture the extreme events that are in the tail of the 

distribution, and these scenarios need to be realistic and plausible. GEMS® is able to simulate 

realistic tail risk events because of the structure of the stochastic models employed (e.g., models 

of equity and credit which contain correlated jump processes), and because of the long historical 

time periods used to calibrate the models. Our historical database includes highly stressed 

environments such as 1929, 1987, 1998 and 2008, so our calibrations are capable of reproducing 

such environments, and some even more extreme scenarios. 

Additionally, GEMS® provides the ability for the user to impose specific user-defined stress 

scenarios for interest rates, credit markets, equity markets, inflation and currency exchange 

rates. Thereby, stress scenarios beyond anything observed in history can be run though the 

system and the effect on the company's business can be simulated. 

SWORCCPP2018-000176
 

 

 

 

 

 

 

 

 

 

 

The performance of GEMS® during the 2008 financial crisis bears out the ESG’s ability to model 

extreme events, as the GEMS® team made several key model implementations prior to 2008 

that meant that we captured the crisis exceptionally well. These included the implementation of 

a stochastic jump diffusion model for equity which captured the extreme tail behavior of equity 

returns, and a three-factor model for interest rates which captured a wide range of yield curve 

dynamics and the low interest rate environment that has been persistent since the crisis. For risk 

neutral applications, these models, coupled with our calibration technology, gave marketleading fits to the most challenging of volatility surfaces. It is our understanding that Conning’s 

GEMS® was the only ESG provider to have the foresight to implement these models prior to 

2008, which is a testament to our commitment and expertise in selecting and implementing the 

most appropriate models. 

Parameterization and Validation 

Conning provides a standard parameterization of the GEMS® real-world models every quarter. 

This calibration is based on a fitting process that incorporates the long-term history of the 

markets and economies we cover. Users may take delivery of any subset of available economies 

and the final scenarios will include realistic correlations between the chosen economies. GEMS® 

official parameterization includes updated starting conditions to reflect markets at the quarter 

end and a review of the long-term assumptions and parameters of the model (e.g., interest, 

equity, credit, inflation, unemployment, GDP, and FX). Targets are based on an analysis of the 

historical record in order to determine an unbiased estimator of a range of different behaviors 

(e.g., mean level, volatility, correlation, returns, etc.). These targets are usually based upon 55– 

65 years of data; however, longer data sets may be taken into consideration in order to inform 

expert judgment. Calibrated results are compared to these data to establish/demonstrate 

goodness of fit — this is contained in the Validation Report and represents our primary regular 

back-testing exercise. 

We explicitly recognize that, in the future, scenarios may emerge that fall outside the bounds of 

historical observations. In setting our calibration targets and validating our models, particular 

attention is paid to establishing volatility characteristics in the models that will produce extreme 

scenarios beyond those observed in the past. At the same time, we work to ensure that the 

tails of our models remain stable over long time horizons, i.e., we seek to achieve a robust level 

of volatility without simplistically dialing up volatility parameters. 

The calibrations themselves are also continually validated. A Validation Report is provided with 

each quarterly real-world parameterization and comprises a standard cross-section of the 

analyses that are reviewed and reflected in the validation process. Collectively the Validation 

Report demonstrates the extent to which simulated economic data will be consistent with the 

starting conditions and the dynamics observed in the historical data. One of the intended uses 

of the Validation Report is that it will be included in a client’s approval/acceptance process of 

each parameterization update. An example of one of our quarterly validation analytics (US 

government bond yield at the 3 month maturity) pages is shown below. We produce similar 

analyses for every variable in every economy, every quarter. 

SWORCCPP2018-000177
and Simulated Data 

US 1953-01-01 :2014-12-31 + 2015Ql for 120 periods 

.2 

,-: 

~ 

i~ M~-rw\ ~ I ~ 0 g ~ 

General 

US Yield Treasury fl 

I r-.; 

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 

0 

~ 

Histogram Cross Sectional Volatility Over Time 

US 1953-01-01:2014-12-31 + 2015Qlfor 120p eriods 

40 

30 

.05 .1 .15 .l 25 50 15 100 

Sil\IULATED DATA: Path Length=l20; )lo.Paths=l003; Freq.=4; Simulated Daia Points=120360 HISTORICAL DATA: Sample 

Period=l953-01-0I to 2014-12-31 ; Historical Data Points=248 

Series l\Iean Stud.Dev. Skewness Kurtosis Min l\Iax o/o<O 

0 . 0387 0 . 0220 0 .1889 2.5498 -0.0037 0 . 0900 0 . 0328 

Simulated ( ( 0 . 0129, ( ( ( ( 

0.0203, 0. 0362 ) -0.5035, 1. 7830, -0.0133 , 0.0543, 0.0000, 

0.0620) 0.8933 ) 3.5829) 0.0052) 0 .1368) 0.1083) 

Sim_Borzn 0 . 0488 0 . 0274 0 . 8068 4 . 0400 - 0 . 0097 0 . 1786 0 . 0082 

Historical 0 . 0460 0.0315 0 . 8798 4.2143 0.0002 0 .1583 0 . 0000 

Returns and inflation are continuously compounded quarterly gro"ih. GDP is continuously compounded YY growth. Treasury 5 and 10 year yields (and their 

corresponding Term Spreads) are par coupon bond yields (spreads). Term Spreads are the 5 and 10 year spread o,·er the 3 month rate. Except for Sim_ Horzn, 

all entries are the means of the PATH statistics - bracketed entries are the 5th and 95th peroentiles of the PATH statistics. For Sim_Horzn, the entries are the 

means of the TIME statistics for the last 10 years (or what is .-"11able) of the simulation. 

Under Adjusted Returns premium: risk premium=equity return o,·er default free 7-10 year bond returns; default premium=lo+ year corporate bond returns o,·er 

default free 7-10 year bond returns; horizon premium=default free 7-10 year bond returns oYer lo 3 month default free return. 

Under Adjusted Returns real: The series are returns/rates net of inflation. long corporate=lo+ year corporate returns; long bond=default free 7-10 year bonds 

returns; short rate=3 month default free return. 

SWORCCPP2018-000178
We have also performed back-testing of GEMS® p rojections vs. actual outcomes for a range of 

variables. The following graphs are examp les of some va lidatio n: 

0.6 

S&PS0O Total Return (GEMS 2007 Vear End/5000 Paths) 

0.4 

N 

i 

0 0 

~ g0 N N N 

g g 

0 0 N N 

 99.5%/0.5% to max/min 95.0%/5.0% to 99.5%/0.5%  Historical Data 

0 .14 US 5 Year Zero Coupon Yield (GEMS 2007 Year Endl 5000 Paths) 

0 .12 

0.1 

-o 0.08 

Qi 

5= 0.06 

99.5%10.5% to max/min 95.0%15.0% to 99.5%/0.5% a Historical Data 

SWORCCPP2018-000179 
0 .14 us 5 Year Zero Coupon Yield (GEMS 2007 Year Endl 5000 Paths) 

0 .12 

0.1 

't:J 0.08 

'ii 

> 0.06 

.. 

~ 

~ 

8 N M ... 8 8 8 ~ ~ ~ ~ 

:l 

§ N M .. S! S! S! 

~ ~ ~ ~ 

99.5%/0.5% to max/min 95.0%/5.0% to 99.5%/0.5% o Historical Data 

So urce: Bloombe rg & GEMS® simulations 

Each graph shows the actual outcome for a key market measure (S&P 500 Index and Investment 

Grade Composite Bond Returns) as a solid line, and confidence intervals based on ex-ante 

GEMS® projections based on starting conditions as of year-end 2005, 2006 and 2007. The 

confidence interva ls range from the 0.5% to 99.5% probability levels. In each case, the actual 

outcome, wh11e extreme, was within the range ofoutcomes projectedby GEMSIP. For ALM and 

risk management purposes, this means that the ESG was robust in the sense that a company 

couldhave seen the potential for the extreme event ahead oftime. 

Reca libration and Sensitivity Ana lysis 

In GEMS® rea l world ca librations, there is a great dea l of customization ava ilable to perform 

sensitivity ana lysis or impose a client's own view. There is a variety of tools ava ilable, which vary 

in their level of complexity and in their suitability to d ifferent tasks. These tools can be grouped 

into the following functions: modifying GEMS® parameterizations, replacing GEMS® scenarios 

pre-simulation, adjusting GEMS® Scenarios post-simulation (path fi ltering & reweighting). 

SWORCCPP2018-000180 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Monte Carlo Simulation 

The GEMS1 projection is uses a pseudo-random to generate a reasonable set of 

economic scenarios. While there are numerous steps involved in this complex process, this 

document will focus on three key components: 

• Generating independent, unit normal random variables 

• Converting those unit normals into correlated variables, where necessary 

• Converting those unit normals into the final desired distributions 

Generating independent, unit normal random variables 

There are numerous situations throughout GEMS that require a random variable. 

Essentially, anywhere that GEMS needs to simulate a distribution, it needs at least one random 

variable. But, not every calculation in GEMS is from a distribution. Consider the case of Treasury 

bonds module. In that module, the first step is generating the Treasury Yield curve. The actual 

dynamics of that process is based on three state variables.2 The equations for each of these 

state variables are a continuous time model. Thus, in order to generate the final state variables 

we need, we need to integrate the model over some time step. Based on Conning’s testing, 

we currently do this integration over 48 subperiods in order to ensure that the resulting 

distribution is aligned with the true distribution that this model is designed to generate. As a 

result, each year of simulated Treasury Yields requires a series of 144 random variables (i.e. 3 

states * 48 subperiods).3 

Despite the large number of random variables for this one process, it is worth noting 

that there are non-random parts of this process. For example, GEMS also generates returns on 

Treasury bonds. While the generation of random Treasury Yields is a key part of this process, 

the actual conversion of these Yields into Returns is a straight forward process that only relies 

on 1. the starting Yield curve, 2. the ending Yield curve and 3. the characteristics (e.g. years to 

maturity, coupon yield) of the bond. This is necessary to ensure that the Returns for different 

Treasury Bonds, say 5- and 10-Year Treasuries, are consistent with each other across all 

scenarios. 

1 GEMS is the Economic Scenario Generator (ESG) portion of the Conning Software. It is included in 

both the FIRM and ADVISE versions of the platform, as well. 

2 Specifically, the GEMS Treasury model is an affine model. In this class of models, the system 

generates underlying variables (i.e. state variables here) that get converted into the final desired results 

(i.e. the Treasury Yield curve). 3 To find out more about the pseudo-random process that GEMS uses to actually generate these values, 

please refer to the Tech Brief on Random Processes in Conning’s Software Documentation Library 

(SDL). 

SWORCCPP2018-000181
 

 

 

 

 

 

 

 

 

 

CP LCD LCV MCP MCD MCV BCP SCP SCD scv 

LCP 1 . 0000 - 0.0000 - 0 . 0000 

LCD - 0 . 1 722 1. 0000 0 . 0000 

LCV - 0 . 498 0 0 . 2 07 4 OO : 

MCP 0 . 939 4 - 0 . 2 078 -

MCD - 0 . 1 396 0 . 9268 1. 0000 ----

MCV - 0 . 557 5 0 . 3 63 0 0 . 4 082 

BCP 0 . 0000 0 . 0000 

BCD 0 . 0000 0 . 00 0 . 0000 0 . 0000 

BCV 0 . 0000 0 . 0000 0 . 0000 ----

SCP 0 . 973 1 - 0 . 2 1 9 0 - 0 . 222 - 0 . 5 32 0 

SCD - 0 . 2488 0 . 6967 0 .4597 - 0 . 263 1 0 . 7 58 1 0 .628 6 0 . 0000 0 . 0000 0 . 0000 - 0 . 3 052 1. 0000 0 . 0000 

scv - 0 . 5 0 68 0 . 321 9 0 . 8832 - 0 . 4 77 5 0 . 387 1 0 . 9637 0 . 0000 0 . 0000 0 . 0000 - 0 . 4 87 4 0 . 6399 1. 0000 

OTP 0 . 9454 - 0 . 0 985 - 0 . 4 789 0 . 884 9 - 0 . 0 467 - 0 . 514 1 0 . 0000 0 . 0000 0 . 0000 0 . 9287 - 0 . 1196 - 0 . 4399 

om - 0 . 44 0 9 0 . 461 8 0 .522 1 - 0 . 4 034 0 . 3222 0 .4 892 0 . 0000 0 . 0000 0 . 0000 - 0 . 3456 0 . 1 960 0 . 380 1 

OTV - 0 .4 684 0 . 0 5 1 2 0 .930 7 - 0 .429 1 0 . 110 8 0 .855 1 0 . 0000 0 . 0000 0 . 0000 - 0 .4 0 14 0 . 323 1 0 . 8 153 

Adding Correlation 

Arguably, one of the most important components of an Economic Scenario Generator is 

how it creates relationships between variables. For example, without meaningful relationships 

between Asset Classes, simulated Portfolio Returns can look unreasonable, even if all the 

underlying Asset Class returns are reasonable. Within GEMS, the majority of these relationships 

are generated through the Cascade structure. Essentially, as part of the model selection and 

calibration process, Conning’s Quantitative Finance Team has developed direct functional 

relationships between difference parts of the Economic Scenario process. For example, the 

Inflation model directly borrows the 3 state variables that are generated as part of the Treasury 

process (see above). This allows GEMS to create much more robust relationships between 

linked portions of the Economic Scenarios than simple correlation will allow. 

That being said, there are still parts of the simulation process where the correlation 

needs to be further adjusted4

. For those cases, GEMS uses a correlation matrix. For example, 

the screen shot below shows a portion of the correlation matrix between different equity 

subindicies: 

Figure 1: US Equity Correlations5 

There are two approaches that are used within GEMS in order to convert the independent, unit 

normals created in the first step into correlated, unit normals. For simple matrices, the model 

uses an approach called Cholesky decomposition6

. Essentially, given a vector of unit normals v 

and a matrix C, if we can find a matrix L such that C = L * LT

, then LT * v will have the desired 

correlation matrix, but will still be unit normals. 

4 Typically, items are either related through only one of these two methods. For example, the cascade 

relationship is the only one between Treasuries and Inflation. Between equities, on the other hand, the 

correlation is entirely done through this correlation matrix approach. 

5 This matrix reflects the correlation matrix that was used as of December 31, 2016. It covers the four 

US equity indices natively modeled by GEMS: S&P 500 (Large Cap), S&P Mid Cap (Mid Cap), Russell 

2000 (Small Cap) and the NASDAQ (Other Cap). For each index, the three rows correspond to Price, 

Dividend and Volatility sources of randomness. 6 For more details about this process, visit https://en.wikipedia.org/wiki/Cholesky_decomposition. 

SWORCCPP2018-000182
 

 

 

 

 

 

Unfortunately, this process doesn’t work in all situations. Specifically, we need the matrix 

C to be positive definite. Meeting this condition can becomes very difficult as matrices increase 

in size, such as when GEMS tries to create correlations between 70+ variables for the full Equity 

simulation across 20+ economies. In order to ensure that the process still runs in these 

situations, GEMS has a two step process to handle these complex situations. First, it uses a 

search algorithm to find a matrix which is close to C which is positive definite. Once that matrix 

is found, first approach is applied with this adjusted matrix. This approach ensures that the 

model will successfully run while respecting the input correlated matrix. 

Converting to the Final Distribution 

Once the unit normals have been successfully correlated, there is still one final step in 

the simulation process: converting into the final distribution. For defined distributions, this 

process is fairly straight forward: find a function which maps the pth percentile of the unit normal 

to the pth percentile of the desired distribution.7 For stochastic equations, the approach is a 

little more complicated (e.g. it involves estimating the integral over a specified period of time), 

but it essentially boils down to this same idea. The big advantage of this approach is that it 

ensures that the final distribution has the desired shape.8 

The major disadvantage of this approach is that it alters the meaning of the correlation 

matrix. Specifically, because the correlation matrix is being applied before the transformation, 

the final distributions may have a different correlation. The GEMS calibration process handles 

this via an iterative process: determine a target correlation for the final distributions, estimate a 

correlation value for the underlying process(es), determine the actual correlation of the final 

distributions, adjust the parameters and repeat the process, as necessary. While this does make 

the estimation procedure more complicated, the tractability of the final simulation process 

makes this approach much more attractive. 

7 For simplicity purposes, this function is often broken down into two steps: 1. map from the unit normal 

to the uniform distribution and 2. use the inverse of the cumulative distribution function of the final 

distribution to make the final transformation. 

8 For more details about this process, visit https://en.wikipedia.org/wiki/Inverse transform sampling. 

SWORCCPP2018-000183
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Disclosure 

Conning, Inc., Goodwin Capital Advisers, Inc., Conning Investment Products, Inc., a FINRAregistered broker dealer, Conning Asset Management Limited, Cathay Conning Asset 

Management Limited, and Octagon Credit Investors, LLC are all direct or indirect subsidiaries 

of Conning Holdings Limited (collectively, “Conning”) which is one of the family of companies 

owned by Cathay Financial Holding Co., Ltd., a Taiwan-based company. Conning has offices in 

Hartford, New York, London, Cologne, Hong Kong and Tokyo. 

Conning, Inc., Conning Investment Products, Inc., Goodwin Capital Advisers, Inc., and Octagon 

Credit Investors, LLC are registered with the Securities and Exchange Commission (“SEC”) 

under the Investment Advisers Act of 1940 and have noticed other jurisdictions they are 

conducting securities advisory business when required by law. In any other jurisdictions where 

they have not provided notice and are not exempt or excluded from those laws, they cannot 

transact business as an investment adviser and may not be able to respond to individual inquiries 

if the response could potentially lead to a transaction in securities. 

Conning Investment Products, Inc. is also registered with the Ontario Securities Commission. 

Conning Asset Management Limited is Authorised and regulated by the United Kingdom's 

Financial Conduct Authority (FCA#189316), and Cathay Conning Asset Management Limited is 

regulated by Hong Kong’s Securities and Futures Commission for Types 1, 4 and 9 regulated 

activities. Conning primarily provides asset management services for third-party assets. Conning 

predominantly invests client portfolios in fixed income strategies in accordance with guidelines 

supplied by its institutional clients. 

All investment performance information included within this material is historical. Past 

performance is not indicative of future results. Any tax related information contained within 

this presentation is for informational purposes only and should not be considered tax advice. 

You should consult a tax professional with any questions. 

For complete details regarding Conning and its services, you should refer to our Form ADV Part 

2, which may be obtained by calling us. Legal Disclaimer 

©2016 Conning, Inc. This document and software described without are copyrighted with all 

rights reserved. No part of this document may be reproduced, transcribed, transmitted, stored 

in an electronic retrieval system, or translated into any language in any form by any means 

without the prior written permission of Conning. Conning does not make any warranties, express 

or implied, in this document. In no event shall Conning be liable for damages of any kind arising 

out of the use of this document or the information contained within it. This document is not 

intended to be complete, and we do not guarantee its accuracy. 

ADVISE®, FIRM®, and GEMS® are trademarks of Conning, Inc. Copyright 1990-2016 Conning, 

Inc. All rights reserved. ADVISE®, FIRM®, and GEMS® are proprietary software published and 

owned by Conning, Inc. 

This document contains information that is confidential or proprietary to Conning (or their direct 

and indirect subsidiaries). By accepting this document you agree that: (1) if there is any preexisting contract containing disclosure and use restrictions between your company and Conning, 

you and your company will use this information in reliance on and subject to the terms of any 

SWORCCPP2018-000184
 

 

 

 

 

 

 

 

 

such pre-existing contract; or (2) if there is no contractual relationship between you and your 

company and Conning, you and your company agree to protect this information and not to 

reproduce, disclose or use the information in any way, except as may be required by law. 

This material is for informational purposes only and should not be interpreted as an offer to sell, 

or a solicitation or recommendation of an offer to buy any security, product or service, or retain 

Conning for investment advisory services. This information is not intended to be nor should it 

be used as investment advice and should not be copied or distributed without the prior consent 

of Conning. 

• Provide the components of the target portfolio used in the projections, expressed 

in terms of the asset classes used for setting the plan’s investment policy. 

Asset Class Weighting 

US Equity—Large Cap Core 

US Equity—Mid Cap Growth 

US Equity—Small Cap Value 

Non-US Equity—Broad 

Global Low Volatility 

US Fixed Income—Core 

US Fixed Income—High Yield 

Cash Equivalents 

Real Estate—Core 

Commodities 

Private Equity—Fund of Funds 

25% 

6% 

5% 

4% 

6% 

24% 

5% 

2% 

15% 

2% 

6% 

SWORCCPP2018-000185
 

 

 

 

 

 

 

 

 

 

 

 

 

• Allocate the components of the target portfolio among the asset classes listed 

below. If the target portfolio includes an asset class not included in the list, 

identify that asset class and its portfolio weight, and include that asset class in the 

asset class listed below that it most closely resembles in terms of the expected net 

return, standard deviation, and correlations. 

Asset Class Weighting 

US Equity—Large Cap 

US Equity—Small/Mid Cap 

Non-US Equity—Developed 

Non-US Equity—Emerging 

US Corporate Bonds—Core 

US Corporate Bonds—Long Duration 

US Corporate Bonds—High Yield 

Non-US Debt—Developed 

Non-US Debt—Emerging 

US Treasuries (Cash Equivalents) 

TIPS (Inflation-Protected) 

Real Estate 

Hedge Funds 

Commodities 

Infrastructure 

Private Equity 

28% 

11% 

6% 

1% 

24% 

0% 

5% 

0% 

0% 

2% 

0% 

15% 

0% 

2% 

0% 

6% 

The above allocation represented the actual asset allocation of the Pension Fund at the time 

the asset allocation studies were prepared, rounded to the nearest percent. Please note that 

the Pension Fund has a 6% target allocation to global low volatility stocks. For the purposes of 

this table, the allocation was split evenly between US Equity-Large Cap and Non-US EquityDeveloped. 

• If the mix of assets for the target portfolio differs from the current mix of 

assets, identify the extent of the difference and explain the reason for the 

difference. 

The current asset mix as of 10/31/2017 is within +/- 3.5% of the asset mix on the prior page. 

The difference is either due to rounding, market movement, or cash needs over the past 

several months since the studies were prepared. 

• If the mix of assets is expected to vary over time, explain how and why the mix 

of assets is expected to vary. 

Over time, the Pension Fund’s allocation to Private Equity will be reduced as the current 

allocation matures and distributes capital back to the Pension Fund. The Pension Fund also 

expects the allocation to Real Estate to decrease slightly over time due to ongoing cash needs. 

SWORCCPP2018-000186
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• If the net investment return assumptions used for the deterministic projections 

are based on the expected returns for the various asset classes, provide: 

o The expected geometric and arithmetic return, net of fees, for each 

asset class; 

o The standard deviation of returns for each asset class; 

o The correlations for the returns among the asset classes; and 

o To the extent that the net investment return assumptions for the asset 

classes vary over time but the investment return assumptions used for 

the deterministic projections do not, a description of how the investment 

return assumptions used for the deterministic projections take into 

account the assumed amount of plan assets (which reflect prior negative 

or positive assumed cash flows) over time. 

As previously mentioned, Marquette’s asset allocation studies are not deterministic projections, 

but rather stochastic projections of asset class performance across a variety of economic and 

market environments, which capture a diverse set of market returns, including notable down 

markets, as well as bull runs. The software is based on a Monte Carlo simulation of 

macroeconomic factors, which are used to model monthly return outcomes of capital markets. 

The formal name of this process is Markov Analysis, as it analyzes the tendency of one event to 

be followed by another. These simulations naturally create distributions for asset class returns 

over each monthly simulation. 

Though many providers utilize a deterministic building block approach, they do not offer a true 

“stochastic” view of potential market outcomes and largely ignore skewed distributions and tail 

events which feature large market losses. Additionally, they rely on static correlations which do 

not exist in practice. The Markov-chain simulations allow for a more true simulation of market 

returns and critically, dynamic correlations between asset classes as market conditions change. 

The tables on the next page highlight the simulated capital market returns and volatility for the 

asset classes in the most recent asset allocation study provided. It is important to note the data 

below represents output from the simulations generated by the software, and not deterministic 

views of future capital market performance. The first column is the average annualized 10 and 

20-year return of all the simulations. The studies use a geometric average. The second column 

is the average annualized 10 and 20-year volatility of all the simulations. Note that this is not the 

same as the standard deviation of the distribution of the possible annualized 10 and 20 year 

returns. The last three columns indicate the annualized 10 and 20-year returns for the 25th, 50th, 

and 75th percentile; the higher the percentile, the better the performance. 

SWORCCPP2018-000187
 

 

Asset Class 

Average 10 Year 10 Year Annualized Returns 

Annualized Annualized 

Return Volatility 

25th 50th 75th 

Percentile Percentile Percentile 

Broad Fixed Income 2.8% 4.3% 2.3% 2.7% 3.3% 

High Yield 4.9% 6.2% 3.7% 4.3% 5.0% 

91 Day T-Bills 1.6% 1.3% 0.3% 0.9% 1.7% 

US Large-Cap Core 7.1% 17.9% 3.1% 7.3% 11.3% 

US Mid-Cap Growth 7.5% 20.2% 3.1% 7.5% 11.7% 

US Small-Cap Value 8.0% 22.6% 3.0% 8.3% 13.0% 

Global Low Volatility 6.8% 12.9% 3.8% 6.8% 9.9% 

Developed Large-Cap 7.4% 22.6% 2.2% 7.1% 12.2% 

Emerging Market 8.5% 31.4% 0.7% 8.3% 15.3% 

Real Estate - Core 7.4% 5.3% 6.2% 7.5% 9.1% 

Commodities 4.5% 21.8% -0.2% 4.5% 9.5% 

Private Equity - Fund of Funds 11.1% 11.4% 8.7% 11.2% 13.5% 

Asset Class 

Average 20 Year 20 Year Annualized Returns 

Annualized Annualized 

Return Volatility 

25th 50th 75th 

Percentile Percentile Percentile 

Broad Fixed Income 3.3% 5.3% 2.5% 2.8% 3.5% 

High Yield 5.3% 7.5% 4.2% 4.7% 5.7% 

91 Day T-Bills 1.8% 2.0% 0.8% 0.9% 2.0% 

US Large-Cap Core 7.1% 18.1% 4.1% 7.1% 10.0% 

US Mid-Cap Growth 7.6% 20.2% 4.2% 7.6% 10.9% 

US Small-Cap Value 8.1% 22.7% 4.5% 8.3% 11.7% 

Global Low Volatility 6.9% 12.9% 4.9% 6.7% 9.0% 

Developed Large-Cap 7.3% 22.7% 3.9% 7.2% 10.7% 

Emerging Market 8.3% 31.9% 2.8% 8.3% 13.4% 

Real Estate - Core 7.4% 5.4% 6.4% 7.4% 8.4% 

Commodities 4.2% 21.9% 0.8% 4.0% 7.6% 

Private Equity - Fund of Funds 11.2% 11.4% 9.5% 11.2% 13.0% 

• Provide the inflation rate or rates inherent in the net investment returns. 

In terms of inflation, as stated in a prior response, Marquette does not utilize a building block 

approach; rather, the expected inflation is implicitly reflected in the expected nominal returns 

for each asset class. Though not an explicit output of the model, inflation is projected at 1.7% 

10 years and 2.3% over 20 years. 

• Provide the investment-related expense inherent in the net investment return 

for the target portfolio, expressed as a percentage of that portfolio. 

Marquette uses index data in its asset allocation simulations; as a result, the expected returns 

do not reflect active management fees, nor do they reflect any expected benefit from using an 

active investment approach. 

SWORCCPP2018-000188
 

 

 

 

CONFIDENTIALITY NOTICE: This communication, including attachments, is for the exclusive 

use of the addressee and contains proprietary, confidential and/or privileged information; any 

use, copying, disclosure, dissemination or distribution is strictly prohibited. Marquette 

Associates, Inc. retains all proprietary rights they may have in the information. 

The sources of information used in this report are believed to be reliable. Marquette Associates, 

Inc. has not independently verified all of the information and its accuracy cannot be guaranteed. 

Opinions, estimates, projections and comments on financial market trends constitute our 

judgment and are subject to change without notice. Estimates and projections of financial 

market performance do not guarantee future performance. Since the model used to create this 

information relies on market data, results will vary depending on the date of the study. Past 

study results do not guarantee future results and are subject to change as more data becomes 

available. As appropriate, Marquette Associates, Inc. reserves the right to adjust the model 

used to prepare the study reflect improved accuracy of portfolio modeling techniques. Results 

may change if the model is adjusted. 

About Marquette Associates 

Marquette Associates is an independent investment consulting firm that helps institutions guide 

investment programs with a focused three-point approach and carefully researched advice. For 

more than 30 years Marquette has served this mission in close collaboration with clients – 

enabling institutions to be more effective investment stewards. Marquette is a completely 

independent and 100% employee-owned consultancy founded with the sole purpose of 

advising institutions. For more information, please visit www.marquetteassociates.com. 

SWORCCPP2018-000189
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

Addendum 3 to Appendix B 

Document #25.1 

SWORCCPP2018-000190
Appendix B

Addendum 3Southwest Ohio Regional Council of Carpenters Pension PlanTable of Contents

Exhibit I Turnover RatesExhibit II Disability and Retirement RatesExhibit III Development of Payment Form Election AssumptionExhibit IV Assumptions Used to Fill in Missing DataExhibit V Termination Decrement StudyExhibit VI Liability Gain/Loss AnalysisExhibit VII Actual Retirement Rates by AgeExhibit VIII Development of New Entrant Profile
Exhibit I: Turnover Rates

Southwest Ohio Regional Council of Carpenters Pension Plan

Turnover Rates by Age and Service

Age

0

Rates by service

1 2 >=3

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00% 35.00% 1.63%

35.00% 35.00% 3.35%

35.00% 35.00% 4.90%

35.00% 35.00% 6.27%

35.00% 35.00% 7.49%

35.00% 35.00% 8.55%

35.00% 35.00% 9.47%

35.00% 35.00% 10.26%

35.00% 35.00% 10.91%

35.00% 35.00% 11.45%

35.00% 35.00% 11.88%

35.00% 35.00% 12.20%

35.00% 35.00% 12.44%

35.00% 35.00% 12.58%

35.00% 35.00% 12.65%

35.00% 35.00% 12.65%

35.00% 35.00% 12.59%

35.00% 35.00% 12.47%

35.00% 35.00% 12.32%

35.00% 35.00% 12.12%

35.00% 35.00% 11.90%

35.00% 35.00% 11.66%

35.00% 35.00% 11.41%

35.00% 35.00% 11.16%

35.00% 35.00% 10.91%

35.00% 35.00% 10.68%

35.00% 35.00% 10.47%

35.00% 35.00% 10.30%

35.00% 35.00% 10.16%

35.00% 35.00% 10.07%

35.00% 35.00% 10.03%

35.00% 35.00% 10.06%

35.00% 35.00% 10.17%

35.00% 35.00% 10.35%

35.00% 35.00% 10.63%

35.00% 35.00% 11.00%

35.00% 35.00% 11.47%

35.00% 35.00% 12.07%

35.00% 35.00% 12.78%

35.00% 35.00% 13.63%

35.00% 35.00% 14.61%

35.00% 35.00% 15.75%

35.00% 35.00% 17.04%

35.00% 35.00% 18.49%

35.00% 35.00% 20.12%

35.00% 35.00% 21.93%

35.00% 35.00% 23.93%

35.00% 35.00% 26.12%

Age

0

Rates by service

1 2 >=3

63

64

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101

102

103

104

105

106

107

108

109

>=110

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

35.00% 35.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

0.00%

SWORCCPP2018-000192
Exhibit II: Disability and Retirement Rates

Southwest Ohio Regional Council of Carpenters Pension Plan

Disability rates Retirement rates

Age Rate

15 0.06%

16 0.08%

17 0.08%

18 0.08%

19 0.10%

20 0.10%

21 0.10%

22 0.10%

23 0.12%

24 0.12%

25 0.12%

26 0.12%

27 0.14%

28 0.14%

29 0.14%

30 0.14%

31 0.16%

32 0.16%

Age Rate

38 0.24%

39 0.26%

40 0.28%

41 0.32%

42 0.34%

43 0.36%

44 0.38%

45 0.42%

46 0.46%

47 0.50%

48 0.54%

49 0.60%

50 0.66%

51 0.72%

52 0.80%

53 0.88%

54 1.00%

55 1.10%

Actives

Age Rate

Terminated Vested

Age Rate

=<54 0% =<54 0%

55 20% 55 5%

56 15% 56 5%

57 15% 57 5%

58 15% 58 5%

59 10% 59 5%

60 10% 60 5%

61 25% 61 30%

62 35% 62 30%

63 20% 63 20%

64 25% 64 20%

65 50% 65 20%

66 50% 66 20%

67 50% 67 20%

68 50% 68 20%

69 50% 69 20%

>=70 100% >=70 100%

33 0.18% 56 1.22%

34 0.18% 57 1.40%

35 0.20% 58 1.58%

36 0.22% 59 1.74%

37 0.24% >=60 0.00%

SWORCCPP2018-000193
Exhibit III: Development of Payment Form Election Assumption

Southwest Ohio Regional Council of Carpenters Pension Plan

Terminated % of Inc

Payment Form* Actives Disabled Vested Total Total Assumption PJoint & 50% Survivor 17 3 12 32 9.4% 10% 

Joint & 100% Survivor 34 5 72 111 32.6% 30% 

Life Annuity 54 16 82 152 44.6% 45% 

Joint & 75% Survivor 8 2 4 14 4.1% 5% 10 C&C 13 0 19 32 9.4% 10% 

Total 126 26 189 341 100% 100% 

*Based on participant data from January 1, 2012 to January 1, 2017
Exhibit IV: Assumptions Used to Fill in Missing Data

Southwest Ohio Regional Council of Carpenters Pension Plan

Data field Assumption used Status applicable

Member's Date of Birth Valuation date ‐ (30+Vesting Service) For all actives and terminated vested p

Member's Date of BirthMember's SexBeneficiary's Date of Birth

Date of Hire

Valuation date ‐ (60+Vesting Service)

MaleMember's Date of Birth +/‐ 3 years (plus (+) 3 years if member is a female, minus (‐) 3 years if member is a female)

Valuation date ‐ Vesting Service

For current beneficiaries

Applies to everyone

For all terminated vested participants owith Joint & Survivor payment forms

For all actives
Exhibit V: Termination Decrement Study

Southwest Ohio Regional Council of Carpenters Pension Plan

Actual Expected Ratio: Actual

Service Near age Exposed Terminations Terminations Actual q's Expected q's over Expected

<3 <15 0 0 0 0.000000 0.000000 0

15 0 0 0 0.000000 0.000000 0

16 0 0 0 0.000000 0.000000 0

17 0 0 0 0.000000 0.000000 0

18 0 0 0 0.000000 0.000000 0

19 11 0 3.3 0.000000 0.299810 0

20 33 7 9.89 0.212121 0.299809 0.708

21 48 18 14.39 0.375000 0.299807 1.251

22 41 15 12.29 0.365854 0.299806 1.22

23 44 10 13.19 0.227273 0.299774 0.758

24 49 16 14.69 0.326531 0.299772 1.089

25 50 13 14.99 0.260000 0.299771 0.867

26 55 14 16.49 0.254545 0.299767 0.849

27 48 14 14.39 0.291667 0.299736 0.973

28 46 7 13.79 0.152174 0.299735 0.508

29 39 19 11.69 0.487179 0.299732 1.625

30 41 12 12.29 0.292683 0.299688 0.977

31 260 109 77.91 0.419231 0.299648 1.399

32 71 21 21.27 0.295775 0.299637 0.987

33 55 21 16.48 0.381818 0.299598 1.274

34 50 12 14.98 0.240000 0.299590 0.801

35 52 19 15.58 0.365385 0.299549 1.22

36 35 8 10.48 0.228571 0.299508 0.763

37 47 11 14.08 0.234043 0.299470 0.782

38 38 16 11.38 0.421053 0.299464 1.406

39 43 16 12.88 0.372093 0.299431 1.243

40 35 18 10.48 0.514286 0.299394 1.718

41 32 13 9.58 0.406250 0.299329 1.357

42 22 7 6.58 0.318182 0.299292 1.063

43 21 10 6.28 0.476190 0.299252 1.591

44 23 6 6.88 0.260870 0.299213 0.872

45 32 8 9.57 0.250000 0.299144 0.836

46 43 18 12.86 0.418605 0.299074 1.4

47 40 15 11.96 0.375000 0.299002 1.254

48 34 15 10.16 0.441176 0.298930 1.476

49 20 6 5.98 0.300000 0.298827 1.004

50 33 13 9.86 0.393939 0.298726 1.319

51 17 4 5.08 0.235294 0.298603 0.788

52 22 10 6.57 0.454545 0.298450 1.523

53 19 3 5.67 0.157895 0.298296 0.529

54 26 10 7.75 0.384615 0.298079 1.29

55 18 5 5.36 0.277778 0.297864 0.933

56 21 8 6.25 0.380952 0.297591 1.28

57 10 3 2.97 0.300000 0.297231 1.009

58 9 3 2.67 0.333333 0.296856 1.123

59 8 4 2.37 0.500000 0.296527 1.686

60 5 2 1.49 0.400000 0.298994 1.338

61 6 2 1.79 0.333333 0.298820 1.115

62 6 3 1.79 0.500000 0.298672 1.674

63 1 0 0.3 0.000000 0.298484 0

64 3 1 0.89 0.333333 0.298315 1.117

65+ 1 0 0.3 0.000000 0.298113 0

<Total> 1663 565 497.87 0.339747 0.299379 1.135

SWORCCPP2018-000196
Exhibit V: Termination Decrement Study

Southwest Ohio Regional Council of Carpenters Pension Plan

Actual Expected Ratio: Actual

Service Near age Exposed Terminations Terminations Actual q's Expected q's over Expected

3+ <15 0 0 0 0.000000 0.000000 0

15 0 0 0 0.000000 0.000000 0

16 0 0 0 0.000000 0.000000 0

17 0 0 0 0.000000 0.000000 0

18 0 0 0 0.000000 0.000000 0

19 0 0 0 0.000000 0.000000 0

20 0 0 0 0.000000 0.000000 0

21 9 0 0.89 0.000000 0.098834 0

22 22 2 2.16 0.090909 0.098334 0.924

23 36 5 3.52 0.138889 0.097803 1.42

24 55 6 5.35 0.109091 0.097257 1.122

25 76 7 7.35 0.092105 0.096668 0.953

26 80 12 7.68 0.150000 0.096040 1.562

27 100 10 9.54 0.100000 0.095354 1.049

28 118 16 11.17 0.135593 0.094620 1.433

29 142 18 13.32 0.126761 0.093822 1.351

30 138 15 12.82 0.108696 0.092934 1.17

31 157 21 14.44 0.133758 0.091957 1.455

32 172 23 15.63 0.133721 0.090890 1.471

33 203 16 18.21 0.078818 0.089699 0.879

34 218 36 19.27 0.165138 0.088389 1.868

35 210 26 18.26 0.123810 0.086931 1.424

36 214 25 18.26 0.116822 0.085326 1.369

37 225 27 18.8 0.120000 0.083569 1.436

38 236 35 19.27 0.148305 0.081669 1.816

39 235 20 18.71 0.085106 0.079605 1.069

40 268 22 20.74 0.082090 0.077387 1.061

41 281 33 21.07 0.117438 0.074983 1.566

42 290 32 20.99 0.110345 0.072385 1.524

43 265 29 18.44 0.109434 0.069587 1.573

44 270 25 17.98 0.092593 0.066583 1.391

45 286 27 18.12 0.094406 0.063358 1.49

46 268 28 16.04 0.104478 0.059867 1.745

47 268 24 15.02 0.089552 0.056040 1.598

48 296 26 15.34 0.087838 0.051814 1.695

49 311 31 14.66 0.099678 0.047152 2.114

50 306 31 12.87 0.101307 0.042067 2.408

51 292 29 10.7 0.099315 0.036651 2.71

52 289 39 8.98 0.134948 0.031067 4.344

53 276 22 7.04 0.079710 0.025515 3.124

54 285 36 5.76 0.126316 0.020217 6.248

55 11 3 0.17 0.272727 0.015378 17.735

56 5 1 0.06 0.200000 0.011156 17.927

57 5 1 0.04 0.200000 0.007646 26.156

58 2 0 0.01 0.000000 0.004887 0

59 5 2 0.01 0.400000 0.002845 140.576

60 1 0 0 0.000000 0.001460 0

61 3 1 0 0.333333 0.000592 563.339

62 0 0 0 0.000000 0.000000 0

63 1 0 0 0.000000 0.000000 0

64 0 0 0 0.000000 0.000000 0

65+ 0 0 0 0.000000 0.000000 0

<Total> 6930 762 458.7 0.109957 0.066191 1.661

SWORCCPP2018-000197
Exhibit V: Termination Decrement Study

Southwest Ohio Regional Council of Carpenters Pension Plan

Actual Expected Ratio: Actual

Service Near age Exposed Terminations Terminations Actual q's Expected q's over Expected

<Total> <15 0 0 0 0.000000 0.000000 0

15 0 0 0 0.000000 0.000000 0

16 0 0 0 0.000000 0.000000 0

17 0 0 0 0.000000 0.000000 0

18 0 0 0 0.000000 0.000000 0

19 11 0 3.3 0.000000 0.299810 0

20 33 7 9.89 0.212121 0.299809 0.708

21 57 18 15.28 0.315789 0.268075 1.178

22 63 17 14.46 0.269841 0.229451 1.176

23 80 15 16.71 0.187500 0.208887 0.898

24 104 22 20.04 0.211538 0.192673 1.098

25 126 20 22.34 0.158730 0.177264 0.895

26 135 26 24.17 0.192593 0.179040 1.076

27 148 24 23.92 0.162162 0.161640 1.003

28 164 23 24.95 0.140244 0.152152 0.922

29 181 37 25.01 0.204420 0.138189 1.479

30 179 27 25.11 0.150838 0.140291 1.075

31 417 130 92.35 0.311751 0.221452 1.408

32 243 44 36.91 0.181070 0.151882 1.192

33 258 37 34.69 0.143411 0.134445 1.067

34 268 48 34.25 0.179104 0.127792 1.402

35 262 45 33.83 0.171756 0.129130 1.33

36 249 33 28.74 0.132530 0.115432 1.148

37 272 38 32.88 0.139706 0.120876 1.156

38 274 51 30.65 0.186131 0.111874 1.664

39 278 36 31.58 0.129496 0.113607 1.14

40 303 40 31.22 0.132013 0.103031 1.281

41 313 46 30.65 0.146965 0.097919 1.501

42 312 39 27.58 0.125000 0.088385 1.414

43 286 39 24.72 0.136364 0.086450 1.577

44 293 31 24.86 0.105802 0.084844 1.247

45 318 35 27.69 0.110063 0.087085 1.264

46 311 46 28.9 0.147910 0.092941 1.591

47 308 39 26.98 0.126623 0.087593 1.446

48 330 41 25.5 0.124242 0.077275 1.608

49 331 37 20.64 0.111782 0.062359 1.793

50 339 44 22.73 0.129794 0.067052 1.936

51 309 33 15.78 0.106796 0.051062 2.091

52 311 49 15.54 0.157556 0.049981 3.152

53 295 25 12.71 0.084746 0.043084 1.967

54 311 46 13.51 0.147910 0.043446 3.404

55 29 8 5.53 0.275862 0.190714 1.446

56 26 9 6.31 0.346154 0.242507 1.427

57 15 4 3.01 0.266667 0.200703 1.329

58 11 3 2.68 0.272727 0.243771 1.119

59 13 6 2.39 0.461538 0.183573 2.514

60 6 2 1.5 0.333333 0.249405 1.337

61 9 3 1.79 0.333333 0.199411 1.672

62 6 3 1.79 0.500000 0.298672 1.674

63 2 0 0.3 0.000000 0.149242 0

64 3 1 0.89 0.333333 0.298315 1.117

65+ 1 0 0.3 0.000000 0.298113 0

<Total> 8593 1327 956.57 0.154428 0.111319 1.387

SWORCCPP2018-000198
Exhibit V: Termination Decrement Study

Southwest Ohio Regional Council of Carpenters Pension Plan

Near age

<15

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65+

<Total>

Service <3

Old New New Δ Exp.

Rates Rates Exp. Term to Actual

0.35 0.00 0.00

0.35 0.00 0.00

0.35 0.00 0.00

0.35 0.00 0.00

0.35 0.00 0.00

0.35 3.85 3.85

0.3 0.35 11.55 4.55

0.3 0.35 16.80 -1.20

0.3 0.35 14.35 -0.65

0.3 0.35 15.40 5.40

0.3 0.35 17.15 1.15

0.3 0.35 17.50 4.50

0.3 0.35 19.25 5.25

0.3 0.35 16.80 2.80

0.3 0.35 16.10 9.10

0.3 0.35 13.65 -5.35

0.3 0.35 14.35 2.35

0.3 0.35 91.00 -18.00

0.3 0.35 24.85 3.85

0.3 0.35 19.25 -1.75

0.3 0.35 17.50 5.50

0.3 0.35 18.20 -0.80

0.3 0.35 12.25 4.25

0.3 0.35 16.45 5.45

0.3 0.35 13.30 -2.70

0.3 0.35 15.05 -0.95

0.3 0.35 12.25 -5.75

0.3 0.35 11.20 -1.80

0.3 0.35 7.70 0.70

0.3 0.35 7.35 -2.65

0.3 0.35 8.05 2.05

0.3 0.35 11.20 3.20

0.3 0.35 15.05 -2.95

0.3 0.35 14.00 -1.00

0.3 0.35 11.90 -3.10

0.3 0.35 7.00 1.00

0.3 0.35 11.55 -1.45

0.3 0.35 5.95 1.95

0.3 0.35 7.70 -2.30

0.3 0.35 6.65 3.65

0.3 0.35 9.10 -0.90

0.3 0.35 6.30 1.30

0.3 0.35 7.35 -0.65

0.3 0.35 3.50 0.50

0.3 0.35 3.15 0.15

0.3 0.35 2.80 -1.20

0.3 0.35 1.75 -0.25

0.3 0.35 2.10 0.10

0.3 0.35 2.10 -0.90

0.3 0.35 0.35 0.35

0.3 0.35 1.05 0.05

0.3 0.35 0.35 0.35

582.05 17.05

Service 3+

Old New New Δ Exp.

Rates Rates Exp. Term to Actual

0.10431 0.0162796 0.00 0.00

0.10333 0.033511 0.00 0.00

0.10234 0.0489689 0.00 0.00

0.10136 0.0627368 0.00 0.00

0.10037 0.074898 0.00 0.00

0.099384 0.0855359 0.00 0.00

0.098898 0.094734 0.85 0.85

0.098398 0.1025755 2.26 0.26

0.097877 0.1091439 3.93 -1.07

0.097331 0.1145227 6.30 0.30

0.096742 0.1187951 9.03 2.03

0.096114 0.1220445 9.76 -2.24

0.095438 0.1243544 12.44 2.44

0.094704 0.1258082 14.85 -1.15

0.093906 0.1264892 17.96 -0.04

0.093031 0.1264808 17.45 2.45

0.092065 0.1258665 19.76 -1.24

0.091 0.1247295 21.45 -1.55

0.08982 0.1231534 25.00 9.00

0.088511 0.1212214 26.43 -9.57

0.087062 0.1190171 24.99 -1.01

0.085466 0.1166237 24.96 -0.04

0.083717 0.1141247 25.68 -1.32

0.081815 0.1116034 26.34 -8.66

0.079756 0.1091433 25.65 5.65

0.077543 0.1068277 28.63 6.63

0.075151 0.1047401 29.43 -3.57

0.072556 0.1029638 29.86 -2.14

0.06976 0.1015821 26.92 -2.08

0.066758 0.1006786 27.18 2.18

0.06354 0.1003366 28.70 1.70

0.060053 0.1006395 26.97 -1.03

0.056227 0.1016706 27.25 3.25

0.052 0.1035135 30.64 4.64

0.047337 0.1062513 33.04 2.04

0.042247 0.1099676 33.65 2.65

0.036823 0.1147458 33.51 4.51

0.031228 0.1206692 34.87 -4.13

0.025661 0.1278212 35.28 13.28

0.020347 0.1362852 38.84 2.84

0.015488 0.1461447 1.61 -1.39

0.011247 0.1574829 0.79 -0.21

0.007718 0.1703833 0.85 -0.15

0.004939 0.1849293 0.37 0.37

0.002879 0.2012043 1.01 -0.99

0.001465 0.2192916 0.22 0.22

0.000594 0.2392747 0.72 -0.28

0.000152 0.2612369 0.00 0.00

785.42 23.42

SWORCCPP2018-000199
- -

• • • • 

• • • • • • 

Exhibit V: Termination Decrement Study 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Termination Rates (Service 3+) 

0.450000 

0.400000 

0.350000 

0.300000 

0.250000 

0.200000 

0.150000 

0.100000 

0.050000 

0.000000 

20 25 30 35 40 45 50 55 60 65 

-

• 

• 

y = 0.0000138985x3 - 0.0015538549x2 +0.0553800837x - 0.5117117896 / 

: 

• . /

• 

•------• 

: 

• -

- • • • 

• • • • - • • - -

- -

SWORCCPP2018-000200 
Exhibit VI: Liability Gain/(Loss) Analysis

Southwest Ohio Regional Council of Carpenters Pension Plan

1. Year of Analysis 2008 2009 2010 2011 2012 2013 2014 

2. Expected unfunded liability (a) Actuarial liability, beginning of year 408,275,549 412,568,583 404,027,509 408,585,221 399,455,599 404,284,154 409,939,373 408

 (b) Assets, beginning of year 299,238,492 257,480,906 271,248,883 273,272,790 252,282,007 255,562,207 253,226,796 244

 (c) Unfunded liability, beginning of year: (a)‐(b) 109,037,057 155,087,677 132,778,626 135,312,431 147,173,592 148,721,947 156,712,577 163

 (d) Normal cost 3,752,007 3,458,081 2,810,783 2,305,190 2,240,247 2,456,369 2,350,968 2

 (e) Expected expenses, beginning of year 550,000 700,000 650,000 880,000 900,000 765,000 840,000 

 (f) Interest on (c)+(d)+(e) 8,500,430 11,943,432 10,217,956 10,387,322 11,273,538 11,395,749 11,992,766 12

 (g) Actual contributions, with interest to end of year 19,622,757 12,675,293 11,617,941 13,520,160 15,153,020 14,217,936 16,004,518 18

 (h) Expected unfunded liability: (c)+(d)+(e)+(f)‐(g) 102,216,737 158,513,897 134,839,424 135,364,783 146,434,358 149,121,129 155,891,793 161

3. Actual unfunded liability (a) Actuarial liability, end of year 412,516,014 417,161,768 407,707,855 409,551,596 399,143,080 405,335,071 407,636,902 407

 (b) Assets, end of year 257,480,906 271,248,883 273,272,790 252,282,007 255,562,207 253,226,796 244,239,334 235

 (c) Actual unfunded liability: (a)‐(b) 155,035,108 145,912,885 134,435,065 157,269,589 143,580,873 152,108,275 163,397,568 172

4. Total gain/(loss) for the year: (2)(h)‐(3)(c) (52,818,370) 12,601,011 404,359 (21,904,806) 2,853,484 (2,987,146) (7,505,775) (10

5. Total gain/(loss), by source (a) Liability gain/(loss) (577,273) (1,631,090) (2,956,650) (369,169) 116,969 (1,007,232) 2,556,995 2

 (b) Asset gain/(loss) (i) 

Assets, beginning of year 299,238,492 257,480,906 271,248,883 273,272,790 252,282,007 255,562,207 253,226,796 244

 (ii) 

Interest on (i) 22,442,887 19,311,068 20,343,666 20,495,459 18,921,151 19,167,166 18,992,010 18

 (iii) Actual contributions, with interest to end of year

19,622,757 12,675,293 11,617,941 13,520,160 15,153,020 14,217,936 16,004,518 18

 (iv) 

Actual benefit payments, with interest to end of year 30,990,882 31,697,985 32,599,959 32,524,766 32,562,986 32,918,224 33,018,220 32

 (v) 

Actual expenses, with interest to end of year 740,996 681,209 911,992 937,179 793,450 869,756 817,001 

 (vi) 

Assets, end of year 257,480,906 271,248,883 273,272,790 252,282,007 255,562,207 253,226,796 244,239,334 235

       (vii) Asset gain/(loss): (vi) ‐ [(i)+(ii)+(iii)‐(iv)‐(v)] (52,091,352) 14,160,810 3,574,251 (21,544,457) 2,562,465 (1,932,533) (10,148,769) (12

 (c) Expense gain/(loss) (i) 

Expected expenses, beginning of year 550,000 700,000 650,000 880,000 900,000 765,000 840,000 

 (ii) 

Interest on (i) 41,250 52,500 48,750 66,000 67,500 57,375 63,000 

 (iii) Actual expenses, with interest to end of yea

r 740,996 681,209 911,992 937,179 793,450 869,756 817,001 

 (iv) 

Expense gain/(loss): (i)+(ii)‐(iii) (149,746) 71,291 (213,242) 8,821 174,050 (47,381) 85,999 

4. Total gain/(loss) fromn all sources: (5)(a)+(5)(b)+(5)(c) (52,818,370) 12,601,011 404,359 (21,904,806) 2,853,484 (2,987,146) (7,505,775) (10
Exhibit VII: Actual Retirement Rates by Age

Southwest Ohio Regional Council of Carpenters Pension Plan

Active decrementsRetirement probabilities

Actual Expected Actual Expected Ratio: Actual Old New New Exp. Δ Exp. to 

Near age Exposed Retirements Retirements q's q's over Expected Rates Rates Retire Actual

<55 0 0 0 0 0 0 0% 0% 0.00 0.0

55 215 40 32.01 0.18605 0.148899 1.249 15% 20% 43.00 3.056 183 26 18.15 0.14208 0.099187 1.432 10% 15% 27.45 1.457 164 24 24.37 0.14634 0.148615 0.985 15% 15% 24.60 0.658 138 21 20.49 0.15217 0.148447 1.025 15% 15% 20.70 -0.3

59 107 11 5.29 0.1028 0.049428 2.08 5% 10% 10.70 -0.360 89 11 13.31 0.1236 0.149535 0.827 15% 10% 8.90 -2.161 72 20 17.94 0.27778 0.249127 1.115 25% 25% 18.00 -2.062 47 17 47 0.3617 1 0.362 100% 35% 16.45 -0.563 27 6 27 0.22222 1 0.222 100% 20% 5.40 -0.664 21 5 21 0.2381 1 0.238 100% 25% 5.25 0.2

65 16 8 16 0.5 1 0.5 100% 50% 8.00 0.0

66 6 3 6 0.5 1 0.5 100% 50% 3.00 0.067 3 2 3 0.66667 1 0.667 100% 50% 1.50 -0.5

68 1 0 1 0 1 0 100% 50% 0.50 0.5

69 1 0 1 0 1 0 100% 50% 0.50 0.5

 70+ 0 0 0 0 0 0 100% 100% 0.00 0.0

<Total> 1090 194 253.56 0.17798 0.232622 0.765 193.95 -0.0

Terminated Vested decrementsRetirement probabilities

Actual Expected Actual Expected Ratio: Actual Old New New Exp. Δ Exp. to 

Near age Exposed Retirements Retirements q's q's over Expected Rates Rates Retire Actual

<55 0 0 0 0 0 0 0% 0% 0.00 0.0

55 286 18 42.59 0.06294 0.148901 0.423 0% 5% 14.30 -3.7

56 268 9 26.58 0.03358 0.099188 0.339 0% 5% 13.40 4.4

57 255 7 37.9 0.02745 0.148617 0.185 0% 5% 12.75 5.758 251 13 37.26 0.05179 0.148446 0.349 0% 5% 12.55 -0.4

59 210 7 10.38 0.03333 0.049428 0.674 0% 5% 10.50 3.5

60 179 9 26.77 0.05028 0.149535 0.336 0% 5% 8.95 -0.0

61 184 48 45.84 0.26087 0.249128 1.047 0% 30% 55.20 7.2

62 123 37 123 0.30081 1 0.301 100% 30% 36.90 -0.1

63 73 6 73 0.08219 1 0.082 100% 20% 14.60 8.6

64 53 10 53 0.18868 1 0.189 100% 20% 10.60 0.6

65 41 8 41 0.19512 1 0.195 100% 20% 8.20 0.2

66 24 5 24 0.20833 1 0.208 100% 20% 4.80 -0.2

67 10 2 10 0.2 1 0.2 100% 20% 2.00 0.0

68 9 1 9 0.11111 1 0.111 100% 20% 1.80 0.8

69 10 2 10 0.2 1 0.2 100% 20% 2.00 0.0

 70+ 64 8 64 0.125 1 0.125 100% 100% 64.00 56.0

<Total> 2040 190 634.31 0.09314 0.310937 0.3 272.55 82.5
Exhibit VIII: Development of New Entrant Profile

Southwest Ohio Regional Council of Carpenters Pension Plan

Annual Accrued Benefit V

Age 2013 2014 2015 2016 2017 Total Age 2013 2014 2015 

 x < 20 Count: 2 0 0 1 2 5 x < 20 Count: 2 0 0 

Mean: 347.34 0.00 0.00 458.04 257.76 333.65 Mean: 0.750 0.000 0.000 

20 <= x < 25 Count: 11 8 24 29 22 94 20 <= x < 25 Count: 11 8 24 

Mean: 293.48 350.72 482.63 436.38 429.32 422.52 Mean: 0.664 0.825 0.942 

25 <= x < 30 Count: 14 3 25 38 28 108 25 <= x < 30 Count: 14 3 25 

Mean: 416.49 498.24 424.39 428.86 411.69 423.70 Mean: 0.843 1.133 0.920 

30 <= x < 35 Count: 25 10 28 48 27 138 30 <= x < 35 Count: 25 10 28 

Mean: 502.83 659.83 429.82 487.05 394.64 472.74 Mean: 1.000 0.900 0.843 

35 <= x < 40 Count: 21 5 18 63 35 142 35 <= x < 40 Count: 21 5 18 

Mean: 787.91 1,047.31 323.35 462.98 426.99 505.04 Mean: 0.781 1.240 0.717 

40 <= x < 45 Count: 16 4 20 49 26 115 40 <= x < 45 Count: 16 4 20 

Mean: 644.82 877.23 457.29 447.65 352.09 470.10 Mean: 0.838 1.200 0.845 

45 <= x < 50 Count: 17 7 19 39 23 105 45 <= x < 50 Count: 17 7 19 

Mean: 852.05 782.47 486.79 533.20 399.24 563.70 Mean: 0.776 0.971 0.868 

50 <= x < 55 Count: 9 1 14 34 33 91 50 <= x < 55 Count: 9 1 14 

Mean: 1,577.56 326.64 365.48 615.66 414.09 596.03 Mean: 0.722 0.700 0.714 

55 <= x < 60 Count: 3 0 11 10 14 38 55 <= x < 60 Count: 3 0 11 

Mean: 557.00 0.00 406.17 480.02 831.20 594.10 Mean: 0.867 0.000 0.782 

60 <= x Count: 2 1 3 6 6 18 60 <= x Count: 2 1 3 

Mean: 2,685.48 362.64 689.88 350.64 359.74 670.31 Mean: 1.100 1.000 1.033 

50 <= x Count: 68 92 8 6 174 50 <= x Count: 68 92 8 

Mean: 368.128 385.101 290.775 278.58 370.46 Mean: 0.784 0.790 0.63

 (missing) Count: 188 131 170 323 216 1,028 (missing) Count: 188 131 170 

Mean: 584.82 467.48 426.02 477.38 430.02 477.32 Mean: 0.815 0.849 0.837 

 <Total> Count: 854 <Total> Count: 

Mean: 597.09 372.93 450.91 605.09 467.48 426.02 Mean: 0.90 0.86 0.82 

Count (Net missing): 854 Count (Net missing): 
Exhibit VIII: Development of New Entrant Profile

Southwest Ohio Regional Council of Carpenters Pension Plan

1/1/2017 New Entrant

Count Weight

Age A

Range Count (Net 60+) Weight (Net 60+) Age DOB * 

Below 20 5 5 1% 1% 19.1 12/1/1997 

20-24 94 94 11% 11% 22.7 5/1/1994 

25-29 108 108 13% 13% 27.5 7/1/1989 

30-34 138 138 16% 16% 32.5 7/1/1984 

35-39 142 142 17% 17% 37.3 9/1/1979 

40-44 115 115 13% 14% 42.5 7/1/1974 

45-49 105 105 12% 13% 47.3 9/1/1969 

50-54 91 91 11% 11% 52.5 7/1/1964 

55-59 38 38 4% 4% 57.0 5/1/1959 

60 and over 18 2% 62.1 12/1/1954 

Total 854 836 100% 100%

* Rounded to nearest month
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 25.1 

Addendum 4 to Appendix B 

Document #25.1 

SWORCCPP2018-000205
Appendix B

Addendum 4

Southwest Ohio Regional Council of Carpenters Pension Plan

History for 5% employers

The following summarizes the history requested in Appendix B of Revenue Procedure 2017‐43 for 5% employers.

2016 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 233,430 $6.95 $1,622,336

OK Interiors Corp 210,718 $6.87 $1,446,822

2015 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 300,372 $6.81 $2,046,857

OK Interiors Corp 215,699 $6.67 $1,438,845

Solid Platforms 154,858 $6.82 $1,056,079

Combs Interior Specialties 152,194 $6.86 $1,044,095

2014 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 215,415 $6.59 $1,420,543

OK Interiors Corp 215,699 $6.33 $1,365,061

Baker Concrete Construction 79,397 $6.58 $522,163

Combs Interior Specialties 90,288 $6.55 $590,958

2013 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 218,981 $6.35 $1,390,828

OK Interiors Corp 148,074 $6.17 $913,806

Baker Concrete Construction 149,982 $6.31 $945,980

Combs Interior Specialties 112,314 $6.19 $695,256

Kokosing Construction 122,281 $6.40 $781,990

2012 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 193,047 $6.03 $1,163,997

OK Interiors Corp 148,114 $5.85 $866,234

Baker Concrete Construction 243,750 $6.10 $1,485,964

2011 plan year 5% employers

Contribution Base  Average Contribution 

Name Units (Hours) Rate ($/Hour) Total Contributions

Valley Industrial Systems 165,021 $5.57 $919,811

OK Interiors Corp 158,281 $5.62 $889,709

Baker Concrete Construction 112,798 $5.88 $663,766

Kokosing Construction 153,490 $5.82 $893,419

SWORCCPP2018-000206
SWORCCPP2018-000207

Appendix B

Addendum 4

Southwest Ohio Regional Council of Carpenters Pension Plan

History for 5% employers

2010 plan year 5% employers

Name

Valley Industrial Systems

OK Interiors Corp

Contribution Base 

Units (Hours)

226,922

188,245

Average Contribution 

Rate ($/Hour)

$5.33

$5.34

Total Contributions

$1,210,142

$1,004,633

2009 plan year 5% employers

Name

Valley Industrial Systems

OK Interiors Corp

Contribution Base 

Units (Hours)

271,596

285,712

Average Contribution 

Rate ($/Hour)

$4.85

$4.33

Total Contributions

$1,316,666

$1,238,176
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #26 – 6.03 Plan's Experience with Certain Critical Assumptions 

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: 

▪ total contributions; 

▪ total contribution base units; 

▪ average contribution rates; 

▪ withdrawal liability payments; and 

▪ the rate of return on plan assets? 

See Section 6.04 of Revenue Procedure 2017-43. 

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: 

▪ total contributions; 

▪ total contribution base units; 

▪ average contribution rates; 

▪ withdrawal liability payments; and 

▪ the rate of return on plan assets 

are set forth in Exhibit I of the Supplemental Actuarial Information document attached as Document 6.1. 

SWORCCPP2018-000208
 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #27 – 6.04 Deterministic Projections of the Sensitivity of the Plan's Solvency Ratio 

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

throughout the extended period by taking into account more conservative assumptions of investment 

experience and future contribution base units than assumed elsewhere in the application? 

See Section 6.05 of Revenue Procedure 2017-43. 

The deterministic projections of the sensitivity of the Plan's solvency ratio throughout the extended period 

taking into account more conservative assumptions of investment experience and future contribution base 

units than assumed elsewhere in the application are included within Exhibits VII, VIII, IX and X of the 

Supplemental Actuarial Information document attached as Document 6.1. 

SWORCCPP2018-000209
 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #28 – 6.05 Deterministic Projections for Each Year of Extended Period 

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 Revenue Procedure 2017-43. 

The 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 

are set forth in Exhibit XI of the Supplemental Actuarial Information document attached as 

Document 6.1. 

SWORCCPP2018-000210
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #29 – 6.06 Certification of Plan Amendment 

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 measure continue to be taken to avoid 

insolvency; and (ii) that the plan would not be projected to avoid insolvency without a 

suspension; 

▪ to require that any future benefit improvements must satisfy §432(e)(9)(E); and 

▪ to specify that the plan sponsor will not modify these amendments, notwithstanding any other 

provision of the plan document? 

See Section 6.07 of Revenue Procedure 2017-43. 

Attached as Document 29.1 is a certification by the Board of Trustees of the Southwest Ohio Regional 

Council of Carpenters Pension Plan that if it receives the Treasury Department's final authorization to 

suspend and then chooses to implement the suspension, the Board of Trustees shall 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 measure continue to be taken to avoid 

insolvency; and (ii) that the plan would not be projected to avoid insolvency without a 

suspension; 

▪ to require that any future benefit improvements must satisfy §432(e)(9)(E); and 

▪ to specify that the plan sponsor will not modify these amendments, notwithstanding any other 

provision of the plan document. 

Attached as Document 29.2 is a draft Amendment implementing the proposed suspension of benefits. 

Attached as Document 29.3 is a draft Amendment modifying the Plan's total and permanent disability 

benefit. 

SWORCCPP2018-000211
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 29.1 

Certification 

TI1e Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan 

certifies that if it receives the United States Treasury Department's final authorization to implement the 

proposed suspension set forth in this application and described in Section 432(e)(9)(H)(vi) ofthe Internal 

Revenue Code of 1986, as amended, and then chooses to implement the suspension, the Board ofTrustees 

shall amend the Plan to adopt the suspension of benefits as described in this application. In addition, the 

Board ofTrustees shall timely amend the Plan as follows: 

(1) The suspension of benefits shall cease upon the plan sponsor's failure to maintain a 

written record of its determination that both: 

(a) All reasonable measures continue to be taken to avoid insolvency during the 

period of benefit suspension; and 

(b) The plan would not be projected to avoid insolvency if no suspension of benefits 

were applied under the plan. 

(2) Any future benefit improvements must satisfy § 432(e)(9)(E) of the Internal Revenue 

Code; and 

(3) The plan sponsor shall not modify these amendments, notwithstanding any other 

provision ofthe plan document. 

~~-- Date: __(o_ -_'Z_ '1_-_l_B__ Steve Schramm 

Authorized Trustee Representative for the 

Southwest Ohio Regional Council of 

Carpenters Pension Plan 

Document #29 .1 

SWORCCPP2018-000212 
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 29.2 

Draft Amendment re. Suspension of Benefits 

SWORCCPP2018-000213
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AMENDMENT TO THE 

SOUTHWEST OHIO REGIONAL COUNCIL 

OF CARPENTERS PENSION PLAN 

Re: Suspension of Benefits under Multiemployer Pension 

Reform Act of 2014 

THIS AMENDMENT TO THE SOUTHWEST OHIO REGIONAL COUNCIL OF 

CARPENTERS PENSION PLAN ("Amendment") is made by the Board of Trustees of the 

Southwest Ohio Regional Council of Carpenters Pension Plan ("Trustees") on this ____ day of 

____, 201__. 

WHEREAS, the Trustees sponsor and maintain the Southwest Ohio Regional Council of 

Carpenters Pension Plan, restated effective January 1, 2014 ("Plan"); 

WHEREAS, Section 6.1 of the Plan permits the Trustees to amend the Plan under certain 

circumstances; 

WHEREAS, the Plan was in critical and declining funding status as described by Section 

432(e)(9) of the Internal Revenue Code of 1986, as amended; 

WHEREAS, the Trustees applied to the Department of Treasury for permission to 

implement benefit suspensions under the Multiemployer Pension Reform Act of 2014 

("MPRA"); and 

WHEREAS, the Department of Treasury approved the Trustees' application for benefit 

suspensions under MPRA and the Secretary of Treasury has certified that a majority of 

participants voted in favor of the benefit suspensions under Treas. Reg. §1.432(e)(9)-1(h)(2)(v). 

NOW, THEREFORE, the Plan is hereby amended to adopt and implement the 

requested benefit suspensions, effective March 31, 2019, unless otherwise stated, as follows: 

1. Effective March 31, 2019, the Plan is hereby amended by the addition of 

Section 4.10, Adjustment of Benefits and Implementation of Benefit Suspensions, which 

shall read as follows: 

"Section 4.10 – Adjustment of Benefits and Implementation of Benefit Suspensions 

Effective March 31, 2019, the monthly benefit earned through March 31, 2019 of any 

Participant, Beneficiary, or any other individual entitled to or receiving a benefit from the 

Plan shall be adjusted for payments after the effective date as follows: 

(a) Participants, Beneficiaries and Other Individuals that Commenced 

Payment from the Plan prior to April 1, 2019. 

(1) Elimination of Early Retirement Subsidy. The monthly benefit of 

any Participant, Beneficiary or other individual that commenced payment 

from the Plan prior to April 1, 2019, shall be recalculated to apply the 

Plan's provisions applicable to benefits commencing on or after January 1, 

2013, including, but not limited to, any actuarial reductions applicable to 

the commencement of benefits prior to Normal Retirement Date, and the 

elimination of any subsidies for years of service. 

SLK_TOL:#3162057v2 

SWORCCPP2018-000214
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(2) Application of Eight Percent Reduction. For any Participant, 

Beneficiary or other individual that commenced payment from the Plan 

prior to April 1, 2019, following the application of subsection 4.10(a)(1) 

of the Plan, the monthly benefit of any Participant, Beneficiary or other 

individual shall be further reduced by eight percent (8%). 

(b) Participants, Beneficiaries and Other Individuals that Commence Payment 

from the Plan after March 31, 2019. 

(1) Application of Eight Percent Reduction of PBGC Multiemployer 

Guarantee Benefit. For any Participant, Beneficiary or other individual 

that commences payment from the Plan on or after April 1, 2019, the 

monthly benefit of such Participant, Beneficiary or other individual 

accrued through March 31, 2019, shall be reduced by eight percent (8%). 

(c) Limitation of Eight Percent Reduction to Benefits Accrued Through 

March 31, 2019. 

The adjustment made to monthly benefits pursuant to this Section 4.10 

shall be limited to benefits accrued through March 31, 2019, and shall not 

apply to nor adjust any benefits accrued on or after April 1, 2019. 

2. The Plan is hereby amended by the addition of Section 4.11, Application of 

Benefit Suspensions to Qualified Domestic Relations Orders, which shall read as follows: 

"Section 4.11 – Application of Benefit Suspensions to Qualified Domestic Relations 

Orders 

Section 4.11 shall be applied to any alternate payee who has been assigned a separate 

interest in a Participant’s benefits via a Qualified Domestic Relations Order (“QDRO”), 

without regard to whether the alternate payee has or has not yet commenced benefits as 

of March 31, 2019. Each alternate payee subject to this Section 4.11 shall be treated as an 

"other individual" as set forth in Section 4.10, and shall be subject to the benefit 

suspensions set forth therein, including the application of any actuarial reductions 

applicable to the commencement of benefits prior to Normal Retirement Date, and the 

elimination of any early retirement subsidies. 

Any alternate payee who has been assigned a shared interest in a Participant’s pension 

benefit, where such interest is set forth in the QDRO as a percentage of the Participant's 

monthly benefit, shall be subject to a pro rata share of the reductions applied to the 

Participant's benefit under Section 4.10. Any alternate payee with a shared interest 

pension benefit described in a QDRO as a specified dollar amount (i.e., $100.00 per 

month) shall not have his or her monthly benefit changed by the reductions applied to the 

Participant's monthly benefit under Section 4.10, unless otherwise required by the terms 

of the QDRO, or as modified by a subsequent QDRO." 

3. The Plan is hereby amended by the addition of Section 4.12, Limitations of 

Applications of Benefit Suspensions, which shall read as follows: 

"Section 4.12 – Limitations of Application of Benefit Suspensions 

SWORCCPP2018-000215
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The application of any reduction pursuant to Section 4.10 and 4.11 to any Participant, 

Beneficiary, or other individual's monthly benefit shall be limited by the following: 

(a) No Participant, Beneficiary or other individual's monthly benefit shall be 

reduced more than to 110% of the amount of payment the Participant, Beneficiary 

or other individual would receive from the Pension Benefit Guaranty Corporation 

under its multiemployer guarantee program under ERISA §4022A if the Plan 

went insolvent, as described by and applied in compliance with Treas. Reg. 

§1.432(e)(9)-1(d)(2); 

(b) No Participant, Beneficiary or other individual who has attained age 75 as 

of March 31, 2019, shall have his or her monthly benefit reduced below the 

applicable percentage as described by and in compliance with Treas. Reg. 

§1.432(e)(9)-1(d)(3); and 

(c) No Participant, or their Beneficiary, who received a Disability Benefit 

under Section 3.4 of the Plan shall have his or her monthly benefit reduced under 

Section 4.10 pursuant to the limitations described in and imposed by Treas. Reg. 

§1.432(e)(9)-1(d)(4)." 

4. The Plan is hereby amended by the addition of Section 4.13, Cessation of 

Benefit Suspensions, which shall read as follows: 

"Section 4.13 – Cessation of Benefit Suspensions 

The suspension and reduction of benefits set forth in Sections 4.10 through 4.12 of the 

Plan shall cease as of the first day of the first Plan Year following the Plan Year in 

which the Board of Trustees fails to maintain a written determination that both: 

(a) All reasonable measures to avoid insolvency continue to be taken during 

the period of benefit suspension; and 

(b) The Plan would not be projected to avoid insolvency if no suspension of 

benefits were applied under Sections 4.10 through 4.12 of the Plan." 

5. Effective March 31, 2019, the Plan is hereby amended by the addition of 

Section 4.14, Limitation of Future Benefit Improvements, which shall read as follows: 

"Section 4.14 – Limitation of Future Benefit Improvements 

Any future improvements to the Accrued Benefit of any Participant, Beneficiary or 

Alternate Payee, including, but not limited to any subsidy, shall satisfy the requirements 

of Section 432(e)(9) of the Code, and the regulations promulgated thereunder." 

6. Effective March 31, 2019, the Plan is hereby amended by the addition of 

Section 4.15, Modification of Amendments, which shall read as follows: 

"Section 4.15 – Modification of Amendments 

SWORCCPP2018-000216
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Notwithstanding any other provision of the Plan to the contrary, Sections 4.10 through 

Section 4.14 shall not be amended except in accordance with the cessation of the 

suspension of benefits pursuant to Section 432(e)(9) of the Code, and the regulations 

promulgated thereunder." 

7. Effective March 31, 2019, the Plan is hereby amended by the restatement of 

Section 1.23 in its entirety, which shall read as follows: 

"Section 1.23 – Joint and Survivor Annuity 

"Joint and Survivor Annuity" means an immediate annuity providing monthly 

payments for life to the Participant and monthly payments for life to the spouse to whom 

the Participant was married at the time payments to the Participant commenced, in an 

amount equal to 50 percent or 100 percent (as elected by the Participant) of the amount 

being paid to the Participant (provided such spouse survives the Participant). 

If none of the foregoing percentages is elected as provided herein, the percentage 

shall be 100. The Qualified Joint and Survivor Annuity of the Plan shall be the 100 

percent Joint and Survivor Annuity. The Qualified Optional Joint and Survivor Annuity 

shall be the 50 percent Joint and Survivor Annuity." 

8. Effective March 31, 2019, the Plan is hereby amended by the restatement of 

Section 1.36 in its entirety, which shall read as follows: 

"Section 1.36 – Ten Year Certain and Life Benefit 

"Ten Year Certain and Life Benefit" means a form of benefit payment providing 

monthly payments for the life of the Participant, with the provision that if the Participant 

dies before having received 120 monthly payments, the remainder shall be paid to the 

Beneficiary as provided in section 3.9(d). Effective for Annuity Starting Dates after 

March 31, 2019, the Ten Year Certain and Life Benefit optional form of distribution shall 

no longer be available. " 

9. Effective March 31, 2019, the Plan is hereby amended by the restatement of 

Section 3.7 in its entirety, which shall read as follows: 

"Section 3.7 – Form of Payment 

(a) Joint and Survivor Annuity. Unless an optional form of benefit described in 

subparagraph (b) has been elected pursuant to a Qualified Election during the 180 day period (or 

90 day period for notices given prior to January 1, 2007) preceding the Annuity Starting Date or 

unless the Participant is eligible for the Total and Permanent Disability Retirement Benefit or for 

the Trade Disability Benefit (in which case benefits shall be paid in the form of a Straight Life 

Annuity), a Participant who is married on his or her Annuity Starting Date shall receive benefits 

in the form of a Joint and Survivor Annuity. 

SWORCCPP2018-000217
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Joint and Survivor Annuity and the optional form of benefits described in 

subparagraph (b) shall have the same Actuarial Value. A Joint and Survivor Annuity shall not be 

available to an alternate payee under a Qualified Domestic Relations Order [as defined in section 

414(p) of the Code]. 

(b) Other Forms of Payment. If a Participant is not married on his or her Annuity 

Starting Date or, if such person is married, pursuant to a Qualified Election, a Participant (other 

than a Participant who is eligible for the Total and Permanent Disability Retirement Benefit or 

the Trade Disability Benefit) may elect during the 180 day period (or 90 day period for notices 

given prior to January 1, 2007) preceding the Annuity Starting Date to receive retirement 

benefits in one of the following forms: 

For Annuity Starting Dates on or before March 31, 2019: 

(i) Straight Life Annuity. 

(ii) Ten Year Certain and Life Benefit. 

For Annuity Starting Dates after March 31, 2019: 

(i) Straight Life Annuity. 

The following paragraph shall apply only to Participants who retire prior to April 30, 

2010. A Participant who is eligible to elect one of the foregoing forms of benefit payments and 

who has not attained the Normal Retirement Date when his or her monthly benefit begins may 

elect to receive a monthly benefit, the amount of which is $800 higher (or such lesser amount, 

but in multiples of $100, as elected by the Participant) than the benefit payable at the Normal 

Retirement Date under the form of benefit payment elected and that has the same Actuarial 

Value as the form of benefit elected prior to the adjustment for increased benefits before the 

Normal Retirement Date. When such Participant attains his or her Normal Retirement Date, the 

monthly benefit payable to the Participant thereafter shall be reduced by the amount of the 

previously-elected increase and paid to the Participant thereafter in the form of benefit elected. If 

the Participant dies before the Normal Retirement Date, the higher monthly benefit shall be 

reduced by the amount of the previously-elected increase and the amount of the monthly benefit 

(if any) payable to the Beneficiary shall be based on the reduced amount. Notwithstanding the 

foregoing, an election to increase the monthly benefit payable under the form of benefit payment 

elected shall not be effective if the amount of the monthly benefit that would be payable to the 

Participant immediately after the Participant's Normal Retirement Date would be less than $200. 

Any post-retirement benefit increase applicable to a Participant who is receiving a monthly 

benefit in the form described in this paragraph will be applied uniformly to both the pre age 62 

and the post age 62 portions of such benefit. If such increase is a flat dollar monthly amount, 

such amount shall be added to both the pre age 62 and the post age 62 benefit. If such increase is 

a percentage of the monthly amount, such percentage shall also be applied to the pre age 62 and 

the post age 62 benefit. The benefit described in this paragraph shall not be available to an 

alternate payee under a Qualified Domestic Relations Order [as defined in section 414(p) of the 

Code]. 

No change in the form of payment shall be permitted after the Annuity Starting 

Date except (i) to the extent required by a Qualified Domestic Relations Order [as defined in 

section 414(p) of the Code] or (ii) as provided in section 3.6." 

SWORCCPP2018-000218
 

 

 

 

 

IN WITNESS WHEREOF, the Board of Trustees has approved this Amendment and 

has authorized its execution by duly authorized officers on this ____ day of _______, 201__, 

effective as of March 31, 2019. 

SOUTHWEST OHIO REGIONAL COUNCIL 

OF CARPENTERS PENSION PLAN 

By:_______________________________________ 

Chairman 

By:_______________________________________ 

Secretary 

SWORCCPP2018-000219
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 29.3 

Draft Amendment re. Modification of Disability Benefits 

SWORCCPP2018-000220
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AMENDMENT TO THE 

SOUTHWEST OHIO REGIONAL COUNCIL 

OF CARPENTERS PENSION PLAN 

Re: Amendment to Disability Provisions Contingent Upon 

Approval of Application for Suspension of Benefits 

Under the Multiemployer Pension Reform Act of 2014 

THIS AMENDMENT TO THE SOUTHWEST OHIO REGIONAL COUNCIL OF 

CARPENTERS PENSION PLAN ("Amendment") is made by the Board of Trustees of the 

Southwest Ohio Regional Council of Carpenters Pension Plan ("Trustees") on this ____ day of 

____, 201__. 

WHEREAS, the Trustees sponsor and maintain the Southwest Ohio Regional Council of 

Carpenters Pension Plan, restated effective January 1, 2014 ("Plan"); 

WHEREAS, Section 6.1 of the Plan permits the Trustees to amend the Plan under certain 

circumstances; 

WHEREAS, the Plan was in critical and declining funding status as described by Section 

432(e)(9) of the Internal Revenue Code of 1986, as amended; 

WHEREAS, the Trustees applied to the Department of Treasury for permission to 

implement benefit suspensions under the Multiemployer Pension Reform Act of 2014 

("MPRA"); 

WHEREAS, the Board of Trustees desires to amend the Plan's disability benefit 

provisions; and 

WHEREAS, the Department of Treasury approved the Trustees' application for benefit 

suspensions under MPRA and the Secretary of Treasury has certified that a majority of 

participants voted in favor of the benefit suspensions under Treas. Reg. §1.432(e)(9)-1(h)(2)(v). 

NOW, THEREFORE, effective March 31, 2019, unless otherwise stated, the Plan is 

hereby amended as follows: 

1. Effective March 31, 2019, Section 3.4 is hereby restated in its entirety as 

follows: 

"Section 3.4 – Disability Retirement Benefit 

A Participant who has at least five (5) Years of Vesting Service, 

who is not eligible for a Normal Retirement Benefit, who incurs a 

Total and Permanent Disability prior to July 1, 2010, and on whose 

behalf Employer contributions were made during the 12-month 

period immediately preceding the date of his or her Total and 

Permanent Disability is entitled to a Total and Permanent 

Disability Retirement Benefit equal to the sum of the following: 

(a) the benefit such person had accrued in the Southwest Ohio 

District Council of Carpenters Pension Plan-Cincinnati, in 

SLK_TOL:#3162057v2 

SWORCCPP2018-000221
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

the Southwest Ohio District Council of Carpenters –

Dayton Pension Plan, or both, at December 31, 1998, and 

(b) $99 per Year of Credited Service through December 31, 

2001, $80 per Year of Credited Service through May 31, 

2003, and $50 per Year of Credited Service thereafter. 

A Participant who has at least five (5) Years of Vesting Service, 

who is not eligible for an Early Retirement Benefit, who incurs a 

Total and Permanent Disability on or after July 1, 2010 and prior 

to April 1, 2019, and on whose behalf Employer contributions 

were made during the 12-month period immediately preceding the 

date of his or her Total and Permanent Disability is entitled to a 

Total and Permanent Disability Retirement Benefit equal to the 

sum of the following: 

(a) the benefit such person had accrued in the Southwest Ohio 

District Council of Carpenters Pension Plan-Cincinnati, in 

the Southwest Ohio District Council of Carpenters –

Dayton Pension Plan, or both, at December 31, 1998, and 

(b) $99 per Year of Credited Service through December 31, 

2001, $80 per Year of Credited Service through May 31, 

2003, and $50 per Year of Credited Service thereafter. 

Such sum shall be reduced based on actuarial equivalent reductions 

from the Participant's Normal Retirement Date. 

A Participant who has at least five (5) Years of Vesting Service, 

who is not eligible for a Normal Retirement Benefit or an Early 

Retirement Benefit, who incurs a Total and Permanent Disability 

on or after April 1, 2019 and on whose behalf Employer 

contributions were made during the 12-month period immediately 

preceding the date of his or her Total and Permanent Disability is 

entitled to receive their Accrued Benefit as a Total and Permanent 

Disability Retirement Benefit equal to the Participant's Normal 

Retirement Benefit reduced by eight (8%) percent and further 

reduced based on actuarial equivalent reductions from the 

Participant's Normal Retirement Date. 

The Total and Permanent Disability Retirement Benefit shall 

commence as of the first day of the month coincident with or next 

following the date the disability occurred, as determined by the 

Social Security Administration." 

SWORCCPP2018-000222
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2. Effective March 31, 2019, Section 3.6 is hereby restated in its entirety as 

follows: 

"Section 3.6 - Cessation of Disability Retirement Benefit 

Any Participant receiving the Disability Retirement Benefit who 

subsequently ceases to be totally and permanently disabled may 

apply for an Early Retirement Benefit (provided such person is 

eligible therefore), in which case the Early Retirement Benefit 

shall become payable for the month immediately following the 

month in which the Disability Retirement Benefit terminates. 

Furthermore, the Disability Retirement Benefit shall cease with the 

payment due for the month immediately preceding the Participant's 

Normal Retirement Date, as of which he or she shall be deemed 

eligible for the Normal Retirement Benefit, reduced by such 

amounts received by the Participant as the Disability Retirement 

Benefit. 

The Disability Retirement Benefit shall cease as of the end of the 

month in which the Participant is no longer satisfies the definition 

of Total and Permanently Disability." 

In all other respects, the provisions of the Plan shall remain in full force and effect. 

IN WITNESS WHEREOF, the Board of Trustees has approved this Amendment and 

has authorized its execution by duly authorized officers on this ____ day of _______, 201__, 

effective as of March 31, 2019. 

SOUTHWEST OHIO REGIONAL COUNCIL 

OF CARPENTERS PENSION PLAN 

By:_______________________________________ 

Chairman 

By:_______________________________________ 

Secretary 

SWORCCPP2018-000223
 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #30 – 6.08 Plan Described in §432(e)(9)(D)(vii) 

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

that is reflected in the proposed benefit suspension? 

See Section 6.08 of Revenue Procedure 2017-43. 

The Southwest Ohio Regional Council of Carpenters Pension Plan is not a plan described in 

§432(e)(9)(D)(vii) of the Internal Revenue Code of 1986, as amended, and, as a result, the application 

does not contain any separate provisions relating to withdrawn employers. 

SWORCCPP2018-000224
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #31 – 6.09 Narrative Statement of Reasons for Critical Declining Status 

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

status? 

See Section 6.09 of Revenue Procedure 2017-43. 

Attached as Document 31.1 is a narrative statement of the reasons the Plan is in critical and declining 

status. 

SWORCCPP2018-000225
 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 31.1 

Narrative Statement of Reasons for Critical and Declining Status 

The significant reduction of hours of service for which contributions are due, the annual payments for 

legacy benefit costs, and a rising annual negative percentage of cash flow has resulted in the critical and 

declining funded status of the Southwest Ohio Regional Council of Carpenters Pension Plan. 

At the beginning of the 2000 Plan Year, the Southwest Ohio Regional Council of Carpenters Pension Plan 

was well-funded at 101% on a market basis, with over 4,500,000 hours of service worked by contributing 

active union members. The average hours of service for which contributions were due for the 10 years 

from 2000 through 2009 was 3,294,478. In Plan Years 2009 through 2015, the average hours of service 

for which contributions were due were 2,237,699, including a low of 1,966,833 in 2010 during the 

recession following the financial crisis. 

The Plan has had negative cash flow for many years. In 2000, the negative cash flow was 3.5%; however, 

the negative cash flow has continued to worsen over the years, reaching 8.4% in 2009, 9.3% in 2010, 

9.1% in 2011, 8.2% in 2012, and 8.5% in 2013. The continual negative cash flow has eroded the Plan's 

funding status such that it is now critical and declining. 

The investment returns on assets have been significantly reduced due to the losses during the 2008 

financial crisis, and have not been sufficient to remediate the Plan's negative cash flow. Nor are they 

likely to do so in the forseeable future in the absence of the approval and implementation of this requested 

suspension of benefits application. 

Document #31.1 

SWORCCPP2018-000226
 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #32 – 7.01 Plan Identification Information 

Does the application include the required plan sponsor identification information? 

See Section 7.01 of Revenue Procedure 2017-43. 

Plan Sponsor Identification Information: 

Plan Sponsor: Board of Trustees of the Southwest Ohio Regional Council of Carpenters Pension Plan 

Address: 700 Tower Drive, Suite 300, Troy, Michigan 48098 

Telephone No.: (800) 435-2388 

(330) 779-8862 

Facsimile No.: (248) 813-9898 

Email: The Board of Trustees does not have a separate email address. Correspondence may be sent to the 

Fund Administrative Manager via electronic mail to eryka.stamatakos@benesys.com. 

Employer Identification No.: 31-6127287 

Plan Number: 001 

SWORCCPP2018-000227
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #33 – 7.02 Plan Identification Information 

Does the application include the required plan identification information? 

See Section 7.02 of Revenue Procedure 2017-43. 

Plan Identification Information: 

Plan Name: Southwest Ohio Regional Council of Carpenters Pension Plan 

Plan No. 001 

Plan Employer Identification Number: 31-6127287 

SWORCCPP2018-000228
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #34 – 7.03 Retiree Representative Information 

Does the application include the required retiree representative information (if applicable)? 

See Section 7.03 of Revenue Procedure 2017-43. 

Not Applicable. The Southwest Ohio Regional Council of Carpenters Pension Plan is not a plan described 

in Internal Revenue Code Section 432(e)(9)(B)(v)(I); thus, a retiree representative is not required to be 

appointed. 

SWORCCPP2018-000229
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #35 – 7.04 Enrolled Actuary Information 

Does the application include the required enrolled actuary information? 

See Section 7.04 of Revenue Procedure 2017-43. 

Required Enrolled Actuary Information: 

Jason Birkle, EA, MAAA, ASA 

Cuni, Rust & Strenk 

4555 Lake Forest Drive, Suite 620 

Cincinnati, Ohio 45242 

Phone: (513) 985-6184 

Fax: (513) 985-6185 

Jason.birkle@crsact.com 

Enrollment No. 17-07856 

SWORCCPP2018-000230
Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN: 31-6127287 

Checklist Item #36 - 7.05 and Appendix C Designation ofPower ofAttorney 

Does the application include a designation ofpower ofattorney for each authorized representative who 

will represent the plan sponsor in connection with the application? 

See Section 7.05 and Appendix Ca/Revenue Procedure 2017-43 

The executed designation of power of attorney for two authorized representatives, Scott Newsom and 

Jason Birkle, who will represent the Board of Trustees of the Southwest Ohio Regional Council of 

Carpenters Pension Plan in connection with this application, is attached as Document 36.1. 

SWORCCPP2018-000231 
Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 36.1 

POWER OF ATTOR.l~EY AND DECLARATION OF REPRESENTATIVE 

BEFORE THE DEPARTMENT OF THE TREASURY 

Applicant Information: 

Plan Name: Southwest Ohio Regional Council ofCarpenters Pension Plan 

Plan Address: 700 Tower Drive, Suite 300 

Troy, Michigan 48098 

Plan Number: 001 

Employer 

fdentification Number: 31-6127287 

Plan Contact: Steve Schramm, Authorized Trustee 

11 100 Ashburn Road 

Cincinnati, Ohio 45240 

P: 513-742-3278 

E: sschramm@okinteriors.com 

F: 513-595-8493 

Applicant hereby appoints the following representatives as attorney-in-fact to represent the taxpayer 

before the Department of the Treasury and perform acts related to the attached application dated 

June ...z.g_, 20 I 8 for suspension of benefits under § 432(e )(9) of the Internal Revenue Code of 1986, as 

amended. 

Representative Information No. I: 

Name: Scott D. Newsom 

Title: Partner 

Address: Shumaker, Loop & Kendrick, LLP 

1000 Jackson Street 

Toledo, Ohio 43604 

Employer 

Identification Number: 34-433949 l 

Telephone Number: 419-241-9000 

E-Mail Address: snewsom@slk-law.com 

Fax Number: 419-241-6894 

Send copies of notices and communications to representative: Yes 

Document #36.1 

SWORCCPP2018-000232 
With the exception ofthe acts described below, I authorize my representative to receive and inspect my 

confidential tax. infonnation and to perform acts that I can perfonn with respect to the attached application 

dated June ..1L, 2018 for suspension of benefits under § 432(e)(9). For example, my representative 

shall have the authority to sign any agreements, consents, or similar documents. 

Specific acts not authorized: None 

Signature of Applicant and Date: 

Date: W_.z7- JB, 

Board ofTrustees ofthe Southwest Ohio 

Regional Council of Carpenters Pension Plan 

Deel a ration ofRepresentative: 

Under penalties of perjury, by my signature below I declare that: 

I am not currently suspended or disbarred from practice before the Internal Revenue 

Service; 

• I am authorized to represent the Applicant for the matter(s) specified in this Power of 

Attorney and Declaration ofRepresentative; and 

I am an attorney and a member in good standing of the bar of the highest court of the 

jurisdiction shown below. 

Jurisd iction ofLicense: State of Ohio; State ofIndiana 

Bar Number: 0067087;23699-76 

IRS CAF Number: 0200-46096R 

s· t ofRe t f d D t -

-- ... - - ... .. _,. 

Shumaker, Loop & Kendrick, LLP 

Date:_---'~'--• -~--'i_-__._1~2-----

Representative Information No. 2: 

Name: Jason Birkle, EA, MAAA, ASA 

Address: Cuni, Rust & Strenk 

4555 Lake Forest Drive, Suite 620 

Cincinnati, Ohio 43242 

Document #36. I 

SWORCCPP2018-000233 
Employer 

Identification Number: 31-1227755 

Telephone Number: 513-985-6184 

E-Mail Address: jason.birkle@crsact.com 

Fax N umber: 513-985-6185 

With the exception of the acts described below, I authorize my representative to receive and inspect my 

confidential tax information and to perform acts that I can perform with respect to the attached application 

dated June t 4. , 2018 for suspension of benefits under § 432( e )(9). For example, my representative 

shall have the authority to sign any agreements, consents, or similar documents. 

Specific acts not authorized: None 

Board ofTrustees ofthe Southwest Ohio 

Regional Council ofCarpenters Pension Plan 

Declaration ofRepresentative: 

Under penalties of perjury, by my signature below I declare t hat: 

• 1 am not currently suspended or disbarred from practice before the Internal Revenne 

Service; 

• I am authorized to represent the Applicant for the matters specified in this Power of 

Attorney and Declaration ofRepresentative; and 

I am enrolled as an actuary by the Joint Board for the Enrollment of Actuaries under 29 

U.S.C. 1242 (the authority to practice before the Internal Revenue Service is limited by 

Section 10.3( d) ofCircular 230). 

Enrollment Number: 17-07856 

Date: Ct/'J. ')/ 'c).o I'? I i 

Document #36.1 

SWORCCPP2018-000234 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #37 – 7.06 Required Plan Documents 

Does the application include: 

▪ the required plan documents; 

▪ any recent amendments; 

▪ the summary plan description (SPD); 

▪ the summary of material modifications; and 

▪ the most recent determination letter? 

See Section 7.06 of Revenue Procedure 2017-43. 

The application includes the following documents attached: 

Document 37.1 – The most recent determination letter issued on the Southwest Ohio Regional 

Council of Carpenters Pension Plan, dated September 2, 2015. 

Document 37.2 – The Southwest Ohio Regional Council of Carpenters Pension Plan, dated 

January 1, 2014, and an amendment to the Plan adopted June 7, 2018 effective August 1, 2018. 

Document 37.3 – The most recent Summary Plan Description, dated January 1, 2017, and a copy 

of the Notice of Adjustable Benefits Reduction/Summary of material modifications dated 

June 29, 2018. 

SWORCCPP2018-000235
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 37.1 

The most recent determination letter issued on the Southwest Ohio Regional Council of Carpenters 

Pension Plan, dated September 2, 2015. 

Document #37.1 

SWORCCPP2018-000236
INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY

P.O. BOX 2508 

CINCINNATI, OH 45201 

Employer Identification Number: 

Date: SEP O2 2015 31-6127287 

DLN:

BOARD OF TRUSTEES OF SOUTHWEST OHIO 17007035086015

REGIONAL COUNCIL OF CARPENTERS Person to contact:

c/o SHUMAKER LOOP & KENDRICK LLP SHERRETTE LAZENBY ID# 52100

SCOTT D NEWSOM Contact Telephone Number:

1000 JACKSON ST (804) 916-8259

TOLEDO, OH 43604 Plan Name: 

SOUTHWEST OHIO REGIONAL COUNCIL OF

CARPENTERS PENSION PLAN

Plan Number: 001 

Dear Applicant: 

Based on the information you provided, we are issuing this favorable

determination letter for your plan listed above. However, our favorable

determination only applies to the status of your plan under the Internal

Revenue Code and is not a determination on the effect of other federal or local

statutes. To use this letter as proof of the plan's status, you must keep this

letter, the application forms, and all correspondence with us about your

application. 

Your determination letter does not apply to any qualification changes that

become effective, any guidance issued, or any statutes enacted after the dates

specified in the cumulative List of Changes in Plan Requirements (the

cumulative List) for the cycle you submitted your application under, unless the

new item was identified in the Cumulative List. 

Your plan's continued qualification in its present form will depend on its

effect in operation (Section 1.401-l(b) (3) of the Income Tax Regulations). We

may review the status of the plan in operation periodically. 

You can find more information on favorable determination letters in Publication

794, Favorable Determination Letter, including: 

The significance and scope of reliance on this letter,

The effect of any elective determination request in your application

materials, 

The reporting requirements for qualified plans, and

Examples of the effect of a plan's operation on its qualified status. 

You can get a copy of Publication 794 by visiting our website at

www.irs.gov/formspubs or by calling 1-800-TAX-FORM (1-800-829-3676) to request

a copy. 

This determination letter applies to the amendments dated on

12/04/14 & 01/24/14. 

This determination letter also applies to the amendments dated on 

Letter 5274 

SWORCCPP2018-000237
-2-

BOARD OF TRUSTEES OF SOUTHWEST OHIO 

09/06/12 & 12/08/11. 

This determination letter also applies to the amendments dated on

09/08/11 & 06/03/10. 

You can't rely on this letter after the end of the plan's first five-year

remedial amendment cycle that ends more than 12 months after we received the

application. This letter expires on January 31, 2020. This letter considered

the 2013 cumulative List of Changes in Plan Qualification Requirements. 

The information on the enclosed addendum is an integral part of this

determination. Please be sure to read it and keep it with this letter. 

If you submitted a Form 2848, Power of Attorney and Declaration of

Representative, or Form 8821, Tax Information Authorization, with your

application and asked us to send your authorized representative or appointee

copies of written communications, we will send a copy of this letter to him or

her. 

If you have any questions, you can contact the person listed at the top of this

letter. 

Sincerely, 

6

.

1/,;1..JN,,...._ .TVl ..

g?·. AAA~ r /VV~~ ~ 

Karen D. Truss 

Director, EP Rulings & Agreements

Addendum 

Letter 5274 

SWORCCPP2018-000238
-3-

BOARD OF TRUSTEES OF SOUTHWEST OHIO 

This determination letter does not apply to any portions of the document that

incorporate the terms of an auxiliary agreement (collective bargaining,

reciprocity, or participation agreement), unless you append to the plan

document the exact language of the sections that you incorporated by reference. 

This determination also applies to the amendment dated 04/29/10. 

Letter 5274 

SWORCCPP2018-000239
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 37.2 

The Southwest Ohio Regional Council of Carpenters Pension Plan, dated January 1, 2014, and an 

amendment to the Plan adopted June 7, 2018, effective August 1, 2018. 

Document #37.2 

SWORCCPP2018-000240
SOUTHWEST OHIO REGIONAL COUNCIL OF CARPENTERS 

PENSION PLAN 

as amended and restated 

effective January 1, 2014* 

*Except as otherwise noted. 

SLK_TOL: #2505331 v3 

SWORCCPP2018-000241
TABLE OF CONTENTS 

ARTICLE 1 - DEFINITIONS .................................................................................................................................... 2 

Section 1.1 - Accrual Computation Period............................................................................................................. 2 

Section 1.2 - Accrued Benefit ................................................................................................................................ 2 

Section 1.3 - Actuarial Value ................................................................................................................................. 2 

Section 1.4 - Annuity Stmiing Date ....................................................................................................................... 2 

Section 1.5 - Association........................................................................................................................................ 2 

Section 1.6 - Beneficiary ........................................................................................................................................ 2 

Section 1.7 - Board ofTrustees .............................................................................................................................. 3 

Section 1. 8 - Break in Service ................................................................................................................................ 3 

Section 1.9- Code .................................................................................................................................................. 3 

Section 1.10 - Collective Bargaining Agreement ................................................................................................... 3 

Section 1.11 - Compensation ................................................................................................................................. 3 

Section 1.12 - Contiguous Non-Covered Employment .......................................................................................... 5 

Section 1.13 - Council ............................................................................................................................................ 5 

Section 1.14 - Covered Employment...................................................................................................................... 5 

Section 1.15 - Early Retirement Date ..................................................................................................................... 5 

Section 1.16 - Eligibility Computation Period ....................................................................................................... 5 

Section 1.17 - Employee ........................................................................................................................................ 5 

Section 1.18 - Employer ......................................................................................................................................... 5 

Section 1.19 - ERlSA ............................................................................................................................................. 6 

Section 1.20 - Forfeiture of Service ....................................................................................................................... 6 

Section 1.21 - Hour of Service ............................................................................................................................... 6 

Section 1.22 - Inactive Employee........................................................................................................................... 7 

Section 1.23 - Joint and Survivor Annuity ............................................................................................................. 7 

Section 1.24 - Leased Employee ............................................................................................................................ 7 

Section 1.25 - Limitation Year ............................................................................................................................... 8 

Section 1.26 - Non-Covered Employment ............................................................................................................. 8 

Section 1.27 - Normal Retirement Age .................................................................................................................. 8 

Section 1.28 - Normal Retirement Date ................................................................................................................. 8 

Section 1.29 - Participant ....................................................................................................................................... 8 

Section 1.30 - Plan ................................................................................................................................................. 8 

Section 1.31 - Plan Year......................................................................................................................................... 8 

Section 1.32 - Qualified Election ........................................................................................................................... 8 

Section 1.33 - Qualified Military Service............................................................................................................... 9 

Section 1.34 - Social Security Retirement Age ...................................................................................................... 9 

Section 1.3 5 - Straight Life Annuity ...................................................................................................................... 9 

Section 1.36 -Ten-Year Certain and Life Benefit.................................................................................................. 9 

Section 1.3 7 - Total and Permanent Disability ....................................................................................................... 9 

Section 1.38 - Trade Disability............................................................................................................................. 10 

Section 1.39 - Union ............................................................................................................................................. I 0 

Section 1.40 - Vesting Computation Period ......................................................................................................... 10 

Section 1.41 - Year of Credited Service ............................................................................................................... 10 

Section 1.42 - Years of Vesting Service............................................................................................................... 10 

SLK_TOL: #250533lv3 

SWORCCPP2018-000242
ARTICLE 2 - PARTICIPATION ............................................................................................................................ 11 

Section 2.1 - Time of Participation ...................................................................................................................... 11 

Section 2.2 - Cessation ofParticipation ............................................................................................................... 11 

Section 2.3 - Reemployed Participant .................................................................................................................. 11 

Section 2.4 - Transfer from Contiguous Non-Covered Employment................................................................... 12 

Section 2.5 - Self-Employed Individuals.............................................................................................................. 12 

Section 2.6 - Provisions Relating to Leased Employees ...................................................................................... 12 

ARTICLE 3 - BENEFIT ELIGIBILITY AND AMOUNTS.................................................................................. 12 

Section 3.1 - Normal Retirement Benefit ............................................................................................................. 12 

Section 3.2 - Early Retirement Benefit................................................................................................................. 13 

Section 3.3 - Deferred Vested Benefit.................................................................................................................. 14 

Section 3.4 - Disability Retirement Benefit ......................................................................................................... 14 

Section 3.5 - Determination ofEligibility for Disability Retirement Benefit....................................................... 16 

Section 3.6 - Cessation of Disability Retirement Benefit..................................................................................... 16 

Section 3.7 - Form ofPayment.............................................................................................................................. 16 

Section 3. 8 - Pre-Retirement Death Benefit ......................................................................................................... 17 

Section 3.9 - Post-Retirement Death Benefit ....................................................................................................... 17 

Section 3.10 - Non-Duplication ............................................................................................................................ 18 

Section 3.11 - Payment of Small Benefit and Payment ofBenefit Pursuant to a Qualified Domestic Relations 

Order ............................................................................................................................................................. 18 

Section 3.12 - Restrictions on Maximum Amount ofBenefit.............................................................................. 19 

Section 3.13 - Provisions Relating to Certain Military Service............................................................................ 30 

Section 3.14 - Partial Pensions ............................................................................................................................. 30 

Section 3.15 - Benefit Adjustments........................................................................................................................ 31 

Section 3.16 - In-Service Distribution for Accruals after Normal Retirement Age .................................................. 32 

Section 3.17 - Modification to Restrictions on Maximum Amount ofBenefit ........................................................ 32 

ARTICLE 4 - APPLICATIONS, BENEFIT PAYMENTS, RETIREMENT AND BENEFIT SUSPENSIONS 

.....................................................................................................................................................................................32 

Section 4.1 - Applications .................................................................................................................................... 32 

Section 4.2 - Information and Proof..................................................................................................................... 32 

Section 4.3 - Action ofBoard ofTrustees ............................................................................................................ 32 

Section 4.4- Right ofAppeal ....................................................................: .......................................................... 32 

Section 4.5 - Benefit Payments Generally............................................................................................................ 33 

Section 4.6 - Distribution Requirements .............................................................................................................. 34 

Section 4.7 - Suspension ofBenefits .................................................................................................................... 37 

Section 4.8 - Benefit Payments Following Suspension ........................................................................................ 41 

Section 4.9 - Direct Rollovers .............................................................................................................................. 42 

ARTICLE 5 - MISCELLANEOUS .......................................................................................................................... 43 

Section 5.1 - Non-Reversion ................................................................................................................................ 43 

Section 5.2 - Limitation ofLiability..................................................................................................................... 44 

Section 5.3 - No Specific Interest......................................................................................................................... 44 

Section 5.4 - Participants' Rights.......................................................................................................................... 44 

Section 5.5 - Forfeitures ....................................................................................................................................... 44 

Section 5.6 - Duties ofBoard of Trustees with Respect to Certain Payments...................................................... 44 

SLK_TOL: #250533lv3 ii 

SWORCCPP2018-000243
Section 5.7 - Valuation ofPlan Assets ................................................................................................................. 45 

Section 5.8 - Merger, Consolidation or Transfer ofAssets .................................................................................. 45 

Section 5.9 - Inalienability ofBenefits ................................................................................................................. 45 

Section 5.10 - Top-Heavy Provisions................................................................................................................... 45 

Section 5.11 - Governing Law ............................................................................................................................. 49 

Section 5.12 - Marriage Equality Requirement .................................................................................................... 49 

Section 5.13 - Recovery and Offset for Overpayment or Erroneous Payment.....................................................49 

Section 5.14 - Dispute Resolution Forum for Withdrawal Liability .................................................................... 49 

ARTICLE 6 - AMENDMENT AND TERMINATION.......................................................................................... 49 

Section 6.1 -Amendment..................................................................................................................................... 49 

Section 6.2 -Termination ..................................................................................................................................... 50 

Section 6.3 - Restrictions in Event of Plan Termination ...................................................................................... 50 

SLK_TOL: #250533lv3 iii 

SWORCCPP2018-000244
PREAMBLE 

WHEREAS, pursuant to collective bargaining, the Miami Valley Carpenters Pension Plan (subsequently 

known as the Southwest Ohio District Council of Carpenters - Dayton Pension Plan) was established effective 

May 1, 1964; and 

WHEREAS, pursuant to collective bargaining, the Ohio Valley Carpenters District Council Pension Plan 

(subsequently known as the Southwest Ohio District Council of Carpenters - Cincinnati Pension Plan) was 

established effective June 1, 1962; and 

WHEREAS, effective January 1, 1999, the Southwest Ohio District Council of Carpenters - Cincinnati 

Pension Plan was merged into the Southwest Ohio District Council of Carpenters - Dayton Pension Plan, and the 

name of the latter was changed to the Southwest Ohio Regional Council of Carpenters Pension Plan; and 

WHEREAS, said latter Plan was then amended by restatement effective January 1, 1999 to reflect the 

foregoing; and 

WHEREAS, the Plan was then again amended by restatement to ensure its continuing qualification under 

section 401(a) of the Internal Revenue Code of 1986, as amended by the Uruguay Round Agreements Act, the 

Uniformed Services Employment and Reemployment Rights Act of 1994, the Small Business Job Protection Act of 

1996, the Taxpayer Relief Act of 1997 and the Internal Revenue Service Restructuring and Reform Act of 1998 

("GUST"); and 

WHEREAS, the Plan was amended by restatement to reflect certain benefit increases as well as guidance 

issued by the Internal Revenue Service relating to GUST; and 

WHEREAS, the Plan was amended by restatement to ensure its continuing qualification under section 

40l(a) of the Internal Revenue Code of 1986, as amended by the Economic Growth and Tax Relief Reconciliation 

Act of2001 ("EGTRRA"); and 

WHEREAS, the Trustees desire to again amend the Plan by restatement to ensure its continuing 

qualification under section 401(a) ofthe Internal Revenue Code of 1986, as amended. 

NOW, THEREFORE, it is agreed that the Plan again be amended by restatement effective January 1, 

2014 (except as otherwise noted), to provide as follows. 

The provisions of this amended and restated Plan shall apply to individuals who are, or who become, 

participants on or after January 1, 2014, unless the provisions hereof specifically provide otherwise. Any rights and 

benefits of other individuals shall be determined by the provisions of the Plan in effect on the date participation 

therein ceased. 

SLK_TOL: #2505331v3 

SWORCCPP2018-000245
ARTICLE 1 

DEFINITIONS 

Section 1.1 - Accrual Computation Period 

"Accrual Computation Period" means the Plan Year. 

Section 1.2 - Accrued Benefit 

"Accrued Benefit" means the monthly pension benefit that an individual has earned at any particular time 

(expressed in terms of a Straight Life Annuity beginning at the Normal Retirement Date), based on the benefit 

formula in section 3.1. 

If an individual incurs a Forfeiture of Service, the Accrued Benefit attributable to service prior to such 

event shall be zero. In addition, if a lump sum payment is made pursuant to section 3.1, section 3.2, section 3.3 or 

section 3.11, the Accrued Benefit attributable to service before such distribution shall be zero, subject to the 

repayment provisions ofsuch sections. 

Except to the extent benefits are suspended in accordance with section 4.7, the amount of any form of 

benefit shall have the same Actuarial Value as the Accrued Benefit in the form of a Straight Life Annuity beginning 

at the Normal Retirement Date. 

As a result of the adoption by the Board of Trustees of a "free look" withdrawal provision, the Accrued 

Benefit of an Employee whose Employer ceases contributions to the Plan and, as a result of the "free look" rule in 

section 4210 of ERISA, owes no withdrawal liability, shall not be paid to the extent such Accrued Benefit reflects 

service with the Employer before the Employer had an obligation to contribute to the Plan. 

Section 1.3 - Actuarial Value 

"Actuarial Value" means an amount or series of amounts of equivalent value determined by the 

assumptions in Appendix I. 

Section 1.4 - Annuity Starting Date 

"Annuity Starting Date" means the first day ofthe first period for which an amount is paid as an annuity or 

any other form. However, in no event shall the Annuity Starting Date be later than the Required Beginning Date, as 

defined in section 4.6(o). 

Section 1.5 - Association 

"Association" means (i) the West Central Ohio Division, Associated General Contractors of Ohio, Inc., 

Associated General Contractors of America, (ii) the Labor Relations Division, Cincinnati Division, Ohio Building 

Chapter, Associated General Contractors of America, or (iii) both, as the context requires. 

Section 1.6 - Beneficiary 

"Beneficiary" means the person or entity properly designated to receive benefits that may be payable after 

death pursuant to the provisions hereof. Notwithstanding the foregoing, however, the Beneficiary shall be the spouse 

to whom the deceased individual was married at death, subject to a Qualified Election. If no valid Beneficiary 

designation form has been filed with the Board of Trustees at the date ofthe death of an individual on whose behalf 

a survivorship benefit is payable or if such deceased individual is not survived by the Beneficiary he or she has 

designated, the Beneficiary shall be deemed to be: 

(a) the surviving spouse ofthe decedent or, ifthe decedent has no surviving spouse, 

SLK_TOL: #2505331 v3 2 

SWORCCPP2018-000246
(b) the estate of the decedent. 

Notwithstanding the foregoing, the Beneficiary of a Participant or Former Participant shall be the spouse to 

whom the Participant or Former Participant was married at death, subject to a Qualified Election. Furthermore, 

effective January 1, 2010, if a Participant or Former Participant designates his or her spouse as the Beneficiary, and 

of such the Participant or Former Participant and such spouse are legally divorced subsequent to the date 

designation, the designation of such spouse as a Beneficiary hereunder will be deemed null and void unless the 

Participant or Former Participant, subsequent to the legal divorce, reaffirms such designation by completing a new 

Beneficiary designation form. 

Section 1.7 - Board of Trustees 

"Board of Trustees" means the entity comprised of an equal number of union trustees and management 

trustees, as required by the Labor-Management Relations Act of 1947, as amended, which entity is responsible for 

administering the Plan. The Board of Trustees is the "administrator," as that term is used in ERISA. 

Section 1.8 - Break in Service 

"Break in Service" means the failure to complete at least one Hour of Service with an Employer during the 

Accrual Computation Period, the Eligibility Computation Period or the Vesting Computation Period, as the case 

maybe. 

Effective on and after December 12, 1994, no Participant shall incur a Break in Service as a result of a 

period of Qualified Military Service if he or she returns to Covered Employment with an Employer after such · 

military service ends and within such time as his or her reemployment rights are guaranteed by federal law. 

Section 1.9 - Code 

"Code" means the Internal Revenue Code of 1986, as amended. 

Section 1.10 - Collective Bargaining Agreement 

"Collective Bargaining Agreement" means the written agreement that governs the wages, hours and 

working conditions of Employees working in Covered Employment. 

Section 1.11 - Compensation 

Compensation means wages, salaries, and fees for professional services and other amounts received 

(without regard to whether or not an amount is paid in cash) for personal services actually rendered in the course of 

employment with an Employer to the extent that the amounts are includible in gross income (including, but not 

limited to, commissions paid to salespersons, compensation for services on the basis of a percentage of profits, 

commissions on insurance premiums, tips, bonuses, fringe benefits, and reimbursements or other expense 

allowances under a nonaccountable plan [as described in section l.62-2(c) of the regulations], and excluding the 

following: 

(1) employer contributions [other than elective contributions described in section 402(e)(3), 

408(k)(6), 408(p)(2)(A)(i), or 457(b) of the Code] to a plan of deferred compensation [including a 

or a simple retirement simplified employee pension described in section 408(k) of the Code 

account described in section 408(p) of the Code, and whether or not qualified] to the extent such 

contributions are not includible in the Employee's gross income for the taxable year in which 

contributed, and any distributions (whether or not includible in gross income when distributed) 

from a plan of deferred compensation (whether or not qualified), other than amounts received 

during the year by an Employee pursuant to a nonqualified unfunded deferred compensation plan 

to the extent includible in gross income; 

SLK_TOL: #250533lv3 3 

SWORCCPP2018-000247
(2) amounts realized from the exercise of a nonstatutory stock option [that is, an option other than a 

statutory stock option as defined in section 1.421-1 (b) of the regulations], or when restricted stock 

( or property) held by the Employee either becomes freely transferable or is no longer subject to a 

substantial risk offorfeiture; 

(3) amounts realized from the sale, exchange or other disposition of stock acquired under a statutory 

stock option; 

(4) other amounts that receive special tax benefits, such as premiums for group-term life insurance 

(but only to the extent that the premiums are not includible in the gross income of the Employee 

and are not salary reduction amounts that are described in section 125 ofthe Code); and 

(5) other items ofremuneration that are similar to any of the items listed in (1) through (4) above. 

For any self-employed individual, Compensation shall mean earned income. 

Except as provided herein, Compensation for a Limitation Year is the Compensation actually paid or made 

available (or, if earlier, includible in gross income) during such Limitation Year. Compensation for a Limitation 

Year shall include amounts earned but not paid during the Limitation Year solely because of the timing of pay 

periods and pay dates, provided the amounts are paid during the first few weeks of the next Limitation Year, the 

amounts are included in a uniform and consistent basis with respect to all similarly situated Employees, and no 

Compensation is included in more than one Limitation Year. 

For Limitation Years beginning on or after July 1, 2007, Compensation for a Limitation Year shall also 

include Compensation paid by the later of 2 1/2 months after an Employee's severance from employment with an 

Employer or the end of the Limitation Year that includes the date of the Employee's severance from employment 

with an Employer, if the payment is regular Compensation for services during the Employee's regular working 

hours, or Compensation for services outside the Employee's regular working hours (such as overtime or shift 

differential), commissions, bonuses, or other similar payments, and, absent a severance from employment, the 

payments would have been paid to the Employee while the Employee continued in employment with an Employer. 

Any payments not described above shall not be considered Compensation if paid after severance from 

employment, even if they are paid by the later of 2 1/2 months after the date of severance from employment or the 

end of the Limitation Year that includes the date of severance from employment, except payments to an individual 

who does not currently perform services for an Employer by reason of Qualified Military Service [ within the 

meaning of section 414(u)(l) of the Code] to the extent these payments do not exceed the amounts the individual 

would have received if the individual had continued to perform services for an Employer rather than entering 

Qualified Military Service. 

as Back pay, within the meaning of section l.415(c)-2(g)(8) of the regulations, shall be treated 

Compensation for the Limitation Year to which the back pay relates to the extent the back pay represents wages and 

compensation that would otherwise be included in this definition. 

For Limitation Years beginning after December 31, 1997, Compensation paid or made available during 

such Limitation Year shall include amounts that would otherwise be included in Compensation but for an election 

under section 125(a), 132(f)(4), 402(e )(3), 402(h)(l )(B), 402(k), or 457(b) of the Code. 

Compensation shall not include amounts paid as Compensation to a nonresident alien, as defined in section 

770l(b)(l)(B) of the Code, who is not a Participant to the extent the Compensation is excludible from gross income 

and is not effectively connected with the conduct of a trade or business within the United States. 

The annual compensation of each participant taken into account in determining benefit accruals in any Plan 

Year beginning after December 31, 2001, shall not exceed $200,000. Annual compensation means compensation 

during the Plan Year or such other consecutive 12-month period over which compensation is otherwise determined 

under the Plan (the determination period). For purposes of determining benefit accruals in a Plan Year beginning 

after December 31, 2001, compensation for any prior determination period shall be $150,000 for any determination 

SLK_TOL: #250533lv3 4

SWORCCPP2018-000248
period beginning in 1996 or earlier; $160,000 for any determination period beginning in 1997, 1998 or 1999; and 

$170,000 for any determination period beginning in 2000 or 2001. The $200,000 limit on annual compensation 

shall be adjusted for cost-of-living increases in accordance with section 401(a)(17)(B) of the Code. The cost-ofliving adjustment in effect for a calendar year applies to annual compensation for the determination period that 

begins with or within such calendar year. In determining benefit accruals in the Plan Years beginning after 

December 31, 2001, the annual compensation limit in this paragraph for determination periods beginning before 

January 1, 2002, shall be $150,000 for any determination period beginning in 1996 or earlier, $160,000 for any 

determination period beginning in 1997, 1998 or 1999, and $170,000 for any determination period beginning in 

2000 or 2001. 

Section 1.12 - Contiguous Non-Covered Employment 

"Contiguous Non-Covered Employment" means Non-Covered Employment that precedes or follows 

Covered Employment, provided no quit, discharge, or retirement occurs between such Covered Employment and 

Non-Covered Employment. However, Contiguous Non-Covered Employment shall not include service with a 

person or entity while such person or entity was not an Employer. 

Section 1.13 - Council 

"Council" means the Indiana-Kentucky-Ohio Regional Council of Carpenters, and any successor. 

Section 1.14 - Covered Employment 

"Covered Employment" means the classification of employment, as defined in the Collective Bargaining 

Agreement or other written agreement, for which contributions to the Plan are required of an Employer. 

Section 1.15 - Early Retirement Date 

"Early Retirement Date" means the first day of any month prior to the Normal Retirement Date as of which 

a Participant attains the age of at least 50 years and has completed at least five Years ofVesting Service. 

Section 1.16 - Eligibility Computation Period 

"Eligibility Computation Period" means the 12-month period that begins on .the date the Employee first 

completes an Hour of Service for an Employer. Thereafter, Eligibility Computation Period means the Plan Year, 

beginning with the Plan Year that includes the last day ofthe first Eligibility Computation Period. 

Section 1.17 - Employee 

"Employee" means any person whose legal status is that of a common-law employee, including Leased 

Employees to the extent provided in section 1.24. 

Section 1.18 - Employer 

"Employer" means: 

(a) Any individual, firm, association, partnership or corporation that is a member of the 

Association (or is represented in collective bargaining by the Association), that is bound by the Collective 

Bargaining Agreement and in accordance therewith is obligated to make contributions to the Plan. 

(b) Any individual, firm, association, partnership or corporation that is not a member of nor 

represented in collective bargaining by the Association, but that has executed or is otherwise bound by the 

Collective Bargaining Agreement and in accordance therewith is obligated to make contributions to the 

Plan. 

SLK_TOL: #2505331 v3 5 

SWORCCPP2018-000249
(c) The Council or any Union ( or both) to the extent that it acts in the capacity of an 

employer of its employees on whose behalf it is obligated to make contributions to the Plan in accordance 

with the Collective Bargaining Agreement or other written agreement. 

(d) The Board of Trustees to the extent that it acts in the capacity of an employer of its 

employees on whose behalf contributions to the Plan are required in accordance with the Collective 

Bargaining Agreement or other written agreement. 

(e) Any board of trustees, committee or other agency established to administer fringe benefit, 

apprenticeship or related funds or other programs established through collective bargaining with the 

Council to the extent such entity acts in the capacity of an employer of its employees on whose behalf 

contributions to the Plan are required in accordance with the Collective Bargaining Agreement or other 

written agreement. 

Section 1.19 - ERISA 

"BRISA" means the Employee Retirement Income Security Act of 1974, as amended. 

Section 1.20 - Forfeiture of Service 

"Forfeiture of Service" means: 

(a) prior to January 1, 1999, the permanent loss of service under the Southwest Ohio District 

Council of Carpenters - Cincinnati Pension Plan or under the Southwest Ohio District Council of 

Carpenters - Dayton Plan (as the case may be), based on the provisions thereof in effect at the applicable 

time; and 

(b) after December 31, 1998, the occurrence of five consecutive Breaks in Service. 

However, an individual will not incur a Forfeiture of Service, and will continue to be credited with his or her 

pre-break Years of Vesting Service, ifhe or she (a) separates from service with at least five Years of Vesting Service, or 

(b) separates from service with less than five Years of Vesting Service but is reemployed before incurring five 

consecutive one year Breaks in Service. 

Section 1.21 - Hour of Service 

"Hour of Service" means: 

(a) each hour for which an Employee is paid, or entitled to payment, for the performance of 

duties for the Employer. These hours shall be credited to the Employee for the computation period in which 

the duties are performed; 

(b) each hour for which an Employee is paid, or entitled to payment by the Employer, on 

account of a period of time during which no duties are performed (irrespective of whether the employment 

relationship has terminated) due to vacation, holiday, illness, incapacity (including disability), layoff, jury 

duty, military duty or leave of absence. However, no more than one Hour of Service shall be credited under 

this subparagraph for any single continuous period (whether or not the period occurs in a single 

computation period). Hours under this subparagraph shall be calculated and credited pursuant to 

Department of Labor Reg. Sec. 2530.200b-2, which is incorporated herein by this reference; and 

(c) each hour for which back pay, irrespective of mitigation of damages, is either awarded or 

agreed to by the Employer. The same Hours of Service shall not be credited both under subparagraph (a) or 

subparagraph (b), as the case may be, and under this subparagraph. These hours shall be credited to the 

Employee for the computation period or periods to which the award or agreement pertains, rather than the 

computation period in which the award, agreement or payment is made. No more than one Hour of Service 

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will be credited for payments of back pay, to the extent back pay is agreed to or awarded for a period of 

time during which the Employee did not or would not have performed duties. 

Hours of Service shall be credited for employment with other members of an affiliated service group [ under 

section414(m) of the Code], a controlled group of corporations [under section414(b) ofthe Code], or a group of 

trades or businesses under common control [under section 414(c) of the Code] of which the Employer is a member, 

and any other entity required to be aggregated with the Employer pursuant to section 414(o) of the Code. 

Hours of Service will also be credited for any individual considered an Employee for purposes of the Plan 

under section 414(n) or section 414(0) of the Code. 

Solely for purposes of determining whether a Break in Service has occurred for participation and vesting 

purposes in a computation period, an individual who is absent from work for maternity or paternity reasons shall 

receive credit for the Hours of Service that would otherwise have been credited to such individual but for such 

absence or, in any case in which such Hours of Service cannot be determined, eight Hours of Service per day of such 

absence. For purposes of this paragraph, an absence from work for maternity or paternity reasons means an absence 

(1) by reason of the pregnancy ofthe individual, (2) by reason of a birth of a child of the individual, (3) by reason of 

the placement of a child with the individual in connection with the adoption of such child by such individual, or ( 4) 

for purposes of caring for such child for a period beginning immediately following such birth or placement. The 

Hours of Service credited under this paragraph shall be credited either in the computation period in which the 

absence begins (if the crediting is necessary to prevent a Break in Service in that period) or, in all other cases, the 

following computation period. However, the provisions of this paragraph shall not apply unless such individual was 

in the active service of an Employer immediately prior to such absence, nor to any Plan Year that begins before 

January 1, 1985. 

If the Board of Trustees enters into a "money follows the man" reciprocity agreement, any money and 

hours transferred to the Plan pursuant to such reciprocity agreement shall be credited to the Participant in the manner 

determined by the Board of Trustees for the purpose of determining his or her Accrued Benefit. Any money and 

hours transferred from the Plan pursuant to such reciprocity agreement shall not be considered when determining the 

value ofthe affected person's Accrued Benefit nor the vested status thereof. 

* * * 

Department of Labor Regulation section 2520.200b-2(b) and section 2520.200b-2(c) are hereby 

incorporated by reference. 

Section 1.22 - Inactive Employee 

"Inactive Employee" means a person (other than a Beneficiary or an alternate payee under a Qualified 

Domestic Relations Order) whose participation in the Plan has ceased pursuant to section 2.2, but who is entitled (or 

may · be entitled) to a benefit from the Plan, either currently or at a later date. 

Section 1.23 - Joint and Survivor Annuity 

"Joint and Survivor Annuity" means an immediate annuity providing monthly payments for life to the 

Participant and monthly payments for life to the spouse to whom the Participant was married at the time payments to 

the Participant commenced, in an amount equal to 50 percent, 75 percent or 100 percent (as elected by the 

Participant) ofthe amount being paid to the Participant (provided such spouse survives the Participant). 

Ifnone of the foregoing percentages is elected as provided herein, the percentage shall be 100. 

Section 1.24 - Leased Employee 

"Leased Employee" means any person (other than an employee of the recipient) who pursuant to an 

agreement between the recipient and any other person ("leasing organization") has performed services for the 

recipient [or for the recipient and related persons determined in accordance with section 414(n)(6) of the Code] on a 

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substantially full-time basis for a period of at least one year, and such services are performed under primary 

direction or control by the recipient ( or, prior to January 1, 1997, such services are of a type historically performed 

by employees in the business field of the recipient). Contributions or benefits provided a Leased Employee by the 

leasing organization that are attributable to services performed for the recipient employer shall be treated as 

provided by the recipient employer. 

A Leased Employee shall not be considered an employee of the recipient if: (i) such employee is covered 

by a money purchase pension plan providing: (1) a nonintegrated employer contribution rate of at least 10 percent of 

compensation, as defined in section415(c)(3) of the Code, but including amounts contributed pursuant to a salary 

reduction agreement that are excludable from the employee's gross income under section 125, section 402(e)(3), section 402(h) or section 403(b) of the Code, (2) immediate participation, and (3) full and immediate vesting; and 

(ii) Leased Employees do not constitute more than 20 percent ofthe recipient's nonhighly compensated workforce. 

Section 1.25 - Limitation Year 

"Limitation Year" means the Plan Year. 

Section 1.26 - Non-Covered Employment 

"Non-Covered Employment" means employment for which contributions by an Employer to the Plan are 

not required by either the Collective Bargaining Agreement or by any other written agreement permitting 

participation in the Plan. 

Section 1.27 - Normal Retirement Age 

"Normal Retirement Age" means the later of age 62 or the fifth anniversary of the participation 

commencement date. The participation commencement date is the first day of the first Plan Year in which the 

Participant commenced participation in the Plan. The anniversary date for Participants who first commenced participation in the Plan beginning before the first Plan Year beginning on or after January 1, 1988, shall be the earlier of 

(a) the tenth anniversary of the Participant's participation commencement date, or (b) the fifth anniversary of the 

participation commencement date beginning on or after January 1, 1988. For purposes of the foregoing, the 

participation commencement date shall be the first day of the Plan Year in which the Employee became a 

Participant. In all cases, however, participation before a Forfeiture of Service shall be disregarded. 

Section 1.28 - Normal Retirement Date 

"Normal Retirement Date" means the first day ofthe month following the Normal Retirement Age. 

Section 1.29 - Participant 

"Participant" means an Employee who, at the particular time, has satisfied the eligibility requirements of 

Article II for participation, and who is not an Inactive Employee. 

Section 1.30 - Plan 

"Plan" means the Southwest Ohio Regional Council of Carpenters Pension Plan, including any 

amendments. 

Section 1.31- Plan Year 

"Plan Year" means the calendar year. 

Section 1.32 - Qualified Election 

"Qualified Election" means a waiver ofthe Joint and Survivor Annuity or the death benefit payment to the 

spouse in the event of death. Any waiver of a Joint and Survivor Annuity or a death benefit payment shall not be 

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effective unless (a) the spouse consents in writing to the election; (b) the election designates a specific alternate 

Beneficiary, including any class of beneficiaries or any contingent beneficiaries, that may not be changed without 

spousal consent ( or the spouse expressly permits designations by the Participant without any further spousal 

consent); (c) the spouse's consent acknowledges the effect of the election; and (d) the spouse's consent is witnessed 

by a Plan representative or notary public. Additionally, a waiver of the Joint and Survivor Annuity will not be 

effective unless the election designates a form of benefit payment that may not be changed without spousal consent 

(or the spouse expressly permits designations without any further spousal consent). If it is established to the 

satisfaction of a Plan representative that such written consent may not be obtained because there is no spouse or the 

spouse cannot be located, a waiver will be deemed a Qualified Election. If the spouse is legally incompetent, a 

Qualified Election may be given by the spouse's legal guardian ( even if the Participant is the legal guardian). 

Finally, if the Participant is legally separated or has been abandoned (within the meaning of local law) and has a 

court order to that effect, spousal consent is not required for a Qualified Election, unless a Qualified Domestic 

Relations Order provides otherwise. 

Any consent by a spouse obtained under this provision (or establishment that the consent of a spouse may 

not be obtained) shall be effective only with respect to such spouse. A consent that permits designations by the 

Participant without any requirement of further consent by such spouse must acknowledge that the spouse has the 

right to limit consent to a specific Beneficiary, and a specific form of benefit where applicable, and that the spouse 

voluntarily elects to relinquish either or both of such rights. A revocation of a prior waiver may be made by a 

Participant without the consent of the spouse at any time prior to the commencement of benefits. The number of 

revocations prior to the commencement ofbenefits shall not be limited. 

For purposes hereof, a former spouse will be treated as a spouse or surviving spouse and a current spouse 

will not be treated as a spouse or surviving spouse to the extent provided in a Qualified Domestic Relations Order 

[as defined in section 414(p) of the Code]. 

Section 1.33 - Qualified Military Service 

"Qualified Military Service" means any service in the United States uniformed services (as defined in Chapter 

43 of Title 38, United States Code) by any Employee if such Employee is entitled to reemployment rights under such 

chapter ofthe United States Code with respect to such service. 

Section 1.34 - Social Security Retirement Age 

"Social Security Retirement Age" means the age used as the retirement age for the Participant under section 216(1) of the Social Security Act except that such section shall be applied without regard to the age increase 

factor, and as if the early retirement age under section 216(1)(2) of such Act were 62. 

Section 1.35 - Straight Life Annuity 

"Straight Life Annuity" means a monthly benefit payment for the life of the recipient with no monthly 

survivorship benefits. 

Section 1.36 - Ten-Year Certain and Life Benefit 

"Ten-Year Certain and Life Benefit" means a form of benefit payment providing monthly payments for the 

life of the Participant, with the provision that if the Participant dies before having received 120 monthly payments, 

the remainder shall be paid to the Beneficiary as provided in section 3.9(d). 

Section 1.37 - Total and Permanent Disability 

"Total and Permanent Disability" means that based on medical evidence satisfactory to the Board of 

Trustees, a person is totally unable, as a result of bodily injury or disease, to engage in any further employment or 

gainful pursuit for the remainder of his or her life. 

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Section 1.38 - Trade Disability 

"Trade Disability" means that based on medical evidence satisfactory to the Board of Trustees a person is 

unable, as a result of bodily injury or disease, to perform any of the work described in the Collective Bargaining 

Agreement for the remainder of his or her life. 

Section 1.39 - Union 

"Union" means any local union affiliated with the Indiana-Kentucky-Ohio Regional Council of Carpenters, 

which union is a party to a Collective Bargaining Agreement requiring contributions to the Plan. 

Section 1.40 - Vesting Computation Period 

"Vesting Computation Period" means the Plan Year. 

Section 1.41 - Year of Credited Service 

"Year of Credited Service" means a Plan Year (beginning January 1, 1999) during which Employer 

hours of work in Covered Employment at the base contributions for an individual are required for 1,500 

journeyman's contribution rate. If Employer contributions for an individual are required for more or less than 1,500 

hours of work during a Plan Year at the base journeyman's contribution rate, the credited service for that Plan Year 

shall be a fraction, the numerator of which is the number of hours for which Employer contributions at the base 

journeyman's contribution rate are required on behalf of such person and the denominator of which is 1,500. (If 

Employer contributions are required for an individual during a Plan Year at a contribution rate other than the base 

journeyman's rate, the credited service for that Plan Year shall be earned on a pro-rata basis, determined as a ratio of 

the required hourly contribution rate to the base journeyman's rate.) 

Notwithstanding the foregoing, no periods of self-employment shall be taken into account when 

determining credited service, and all Years of Credited Service prior to a Forfeiture of Service shall be disregarded. 

Section 1.42 - Years of Vesting Service 

"Years of Vesting Service" means the sum of the following: 

(a) the number of years of service an individual had earned as of December 31, 1998, under 

the Southwest Ohio District Council of Carpenters - Cincinnati Pension Plan or the Southwest Ohio District 

Council of Carpenters - Dayton Pension Plan (as the case may be) for vesting purposes, and 

(b) after December 31, 1998, the number of Plan Years during which an Employee 

Employment or in Contiguous Non-Covered completes at least 1,000 Hours of Service in Covered 

Employment, with partial credit being granted as follows: 

Hours of Service in 

Covered Employment and 

in Contiguous Non-Covered Years of 

Employment During a Plan Year Vesting Service 

900-999 .9 

800-899 .8 

700-799 .7 

600-699 .6 

500-599 .5 

400-499 .4 

300-399 .3 

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Hours of Service in 

Covered Employment and 

in Contiguous Non-Covered Years of 

Employment During a Plan Year Vesting Service 

200-299 .2 

100-199 .1 

Less than I 00 -0-

* * * 

Notwithstanding the foregoing, no periods of self-employment shall be taken into account when 

determining Years of Vesting Service, and Years of Vesting Service prior to a Forfeiture of Service shall be

disregarded. 

ARTICLE2 

PARTICIPATION 

Section 2.1-Time of Participation 

Each person who was participating in the Plan on January I, 2014, shall remain a Participant until his or her 

participation ceases pursuant to section 2.2. 

A person who first completes an Hour of Service after December 31, 2013, and on whose behalf a 

contribution to the Plan is required by the Collective Bargaining Agreement or other written agreement shall become 

a Participant on the first day of the month following the completion of 500 Hours of Service during his or her 

Eligibility Computation Period, provided such person is working in Covered Employment at the time participation 

would otherwise begin. However, no person shall become a Participant if, prior to the time an obligation to make a 

contribution to the Plan for such person is required, contributions are to be reciprocated to another tax-qualified 

plan. 

Section 2.2 - Cessation of Participation 

A person who has satisfied the participation requirements of section 2.1 shall cease being a Participant in 

the Plan upon the occurrence of any of the following: 

(a) Death. 

(b) Incurring a Break in Service. 

(c) The occurrence of an obligation by the Board of Trustees to reciprocate Employer 

contributions made on such person's behalf to another tax-qualified plan. 

However, such person may thereupon become an Inactive Employee. 

Section 2.3 - Reemployed Participant 

If an Employee satisfies the participation requirements of section 2.1, terminates employment with an 

Employer, and is later reemployed by an Employer, the Employee will become a Participant as of the day 

contributions to the Plan are first required for him or her pursuant to the Collective Bargaining Agreement or other 

written agreement, unless such person has incurred a Forfeiture of Service when he or she is reemployed. In such 

case, the Employee will become a Participant in accordance with the provisions of the second paragraph of 

section 2.1. 

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Section 2.4 - Transfer from Contiguous Non-Covered Employment 

If an Employee transfers from Contiguous Non-Covered Employment with an Employer to Covered 

account to Employment, Hours of Service in such Contiguous Non-Covered Employment will be taken into 

determine if the Employee has satisfied the participation requirements of section 2.1. 

Section 2.5 - Self-Employed Individuals 

Notwithstanding any provision in this Article II, no person who is self-employed shall be a Participant. 

Section 2.6 - Provisions Relating to Leased Employees 

(a) Safe-Harbor. Notwithstanding any other provisions of the Plan, for purposes of the 

pension requirements of section414(n)(3) of the Code, employees of the Employer shall include 

individuals defined as Leased Employees in section 1.24. 

(b) Participation and Accrual. A Leased Employee shall not become a Participant in, nor 

accrue benefits under, the Plan based on service as a Leased Employee unless the Collective Bargaining 

Agreement or other written agreement between the Council and an Employer provides otherwise. 

ARTICLE3 

BENEFIT ELIGIBILITY AND AMOUNTS 

Section 3.1 - Normal Retirement Benefit 

Subject to section 3.7, section 3.11 and article 4, a Participant who retires on his or her Normal 

Retirement Age after December 31, 2013, is entitled to a lifetime monthly retirement benefit equal to the sum of the 

following: 

(a) The benefit such person had accrued in the Southwest Ohio District Council of 

Carpenters-Cincinnati Pension Plan, in the Southwest Ohio District Council of Carpenters - Dayton

Pension Plan, or both, at December 31, 199 8. 

(b) $99 per Year of Credited Service through December 31, 2001, $80 per Year of Credited 

Service through May 31, 2003, and $50 per Year of Credited Service thereafter. 

The Accrued Benefit shall be totally nonforfeitable at a Participant's Normal Retirement Age and at all 

times thereafter. 

If a Participant does not retire at his or her Normal Retirement Age and if the Annuity Starting Date is after 

the Normal Retirement Date, the monthly benefit payable to such Participant upon retirement shall be greater of: 

(a) an amount that has the same Actuarial Value as the Accrued Benefit that would have 

been payable to the Participant at his or her Normal Retirement Date; or 

(b) the Accrued Benefit at his or her actual retirement date. 

If the Participant first becomes entitled to additional benefits after the Normal Retirement Date, the 

actuarial increase in such benefits will start from the date such benefits would first have been paid, not from the 

Normal Retirement Date. Such payment date shall be the February 1 of the calendar year that follows the calendar 

year in which the additional accruals were earned or, in the case of a benefit increase, the date specified in the 

amendment adopting the increase. 

Notwithstanding the foregoing, ifthe Participant has been notified of the Plan's suspension of benefit rules, 

and if payment of benefits has been suspended pursuant to section4.7(b), the Actuarial Value of the Accrued 

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Benefit at his or her Normal Retirement Age shall be actuarially increased only for that number of months (if any) 

between the Participant's Normal Retirement Date and his or her Annuity Starting Date during which benefits were 

not properly suspended pursuant to section 4.7. 

If a Participant does not continue to work beyond his or her Normal Retirement Date and if the Annuity 

Starting Date is after the Normal Retirement Date, the monthly benefit will be the Accrued Benefit at the Normal 

Retirement Date, actuarially increased for each month for which benefits were not paid between the Normal 

Retirement Date and the Annuity Starting Date, and then converted as of the Annuity Starting Date to the form of 

benefit elected in the pension application or, if none, to the Joint and Survivor Annuity. 

If the Actuarial Value of the Accrued Benefit of a Participant who retires on or after his or her Normal 

Retirement Date exceeds $5,000 but does not exceed $10,000, and if the Participant so requests, the Actuarial Value 

of such Accrued Benefit shall be paid to the Participant in a lump sum. The foregoing, however, shall be subject to 

the receipt of a Qualified Election, and the Plan being permitted to pay lump sum benefits pursuant to Section 432 of 

the Code. 

If an individual who received a lump sum payment pursuant to the prior paragraph again becomes a 

Participant, he or she shall have the right to restore his or her Accrued Benefit (including all optional forms of 

benefits and subsidies relating to such benefits) to the extent forfeited upon repayment to the Plan of the full amount 

of the distribution plus interest, compounded annually from the date of distribution at the rate determined for 

purposes of section 41 l(c)(2)(C) of the Code. Such repayment must be made before the earlier of five years after the 

first date on which such person subsequently becomes a Participant or the date such person incurs five consecutive 

Breaks in Service following the date of distribution. 

Section 3.2 - Early Retirement Benefit 

Subject to section 3.7, section 3.11 and article 4, a Participant who retires on an Early Retirement Date is 

entitled to a lifetime monthly retirement benefit equal to the sum ofthe following: 

(a) the benefit such person had accrued in the Southwest Ohio District Council of 

Carpenters-Cincinnati Pension Plan, in the Southwest Ohio District Council of Carpenters - Dayton 

Pension Plan, or both, at December 31, 1998. 

(b) $99 per Year of Credited Service through December 31, 2001, $80 per Year of Credited 

Service through May 31, 2003, and $50 per Year of Credited Service thereafter. 

For retirements with a benefit commencement date prior to September 1, 2010, benefits accrued prior to January 1, 

2009, shall be reduced by .0025 for each month and benefits accrued after December 31, 2008, shall be reduced by 

.003 for each month by which the commencement of the Early Retirement Benefit precedes the Normal Retirement 

Date, unless at the time of early retirement the Participant had retired from active employment (as defined herein) on 

an Early Retirement Date after December 31, 1999, had attained the age of at least 50 years and the sum of (a) his or 

her age and Years of Credited Service or (b) his or her age and years of continuous membership in the United 

Brotherhood of Carpenters and Joiners of America through December 31, 2008, equaled at least 80, in which case 

the monthly amount of benefits shall not be reduced. 

For retirements with a benefit commencement date on or after September 1, 2010, but prior to January 1, 2013, 

benefits shall be reduced by .003 for each month by which the commencement of the Early Retirement Benefit 

precedes the Normal Retirement Date, unless: 

(1) at the time of early retirement, the Participant had retired from active 

employment (as defined herein) on an Early Retirement Date on or after September 1, 2010, had 

attained the age ofat least 55 years and the sum of(a) his or her age and Years of Credited Service 

equaled at least 85, and (b) he or she had at least 1,000 hours of contributions to the Plan for work 

in Covered Employment during the 24-month period immediately preceding his or her Early 

Retirement Date in which case the monthly amount ofbenefits shall not be reduced; or 

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(2) the Participant did not retire from active employment (as defined herein) and has 

case the benefits shall be reduced based on actuarial incurred a Break in Service, in which 

equivalent reductions from the Participant's Normal Retirement Date. 

For retirements with a benefit commencement date on or after January 1, 2013, benefits shall be reduced based on 

actuarial equivalent reductions from the Participant's Normal Retirement Date. 

In the case of an individual whose eligibility for an unreduced early retirement is based on years of continuous 

membership in the United Brotherhood of Carpenters and Joiners of America, such person must have at least 

15 Years of Credited Service. However, effective January 1, 2009 (but only for benefits accrued on or after that 

date), years of continuous membership in the United Brotherhood of Carpenters and Joiners of America shall not be 

taken into consideration for purposes of determining eligibility for an unreduced Early Retirement Benefit. 

For purposes of the foregoing, an individual shall be deemed to have retired from "active employment" 

at least 1,000 hours of work in Covered only if Employer contributions were made on his or her behalf for 

Employment during the 24-month period preceding the effective date ofhis or her early retirement. 

If an individual who received a lump sum payment again becomes a Participant, he or she shall have the 

right to restore his or her Accrued Benefit (including all optional forms of benefits and subsidies relating to such 

benefits) to the extent forfeited upon repayment to the Plan of the full amount of the distribution plus interest, 

compounded annually from the date of distribution at the rate determined for purposes of section 4 l l(c)(2)(C) of the 

on which such person Code. Such repayment must be made before the earlier of five years after the first date 

subsequently becomes a Participant or the date such person incurs five consecutive Breaks in Service following the 

date of distribution. 

Section 3.3 - Deferred Vested Benefit 

Subject to section 3. 7, section 3.11 and article 4, a Participant who terminates employment after 

December 31, 2008, with at least five Years of Vesting Service, for any reason other than death, disability, or early 

or normal retirement, is entitled to a lifetime monthly retirement benefit equal to the sum of the following: 

(a) The benefit such person had accrued in the Southwest Ohio District Council of 

Carpenters-Cincinnati Pension Plan, in the Southwest Ohio District Council of Carpenters - Dayton

Pension Plan, or both, at December 31, 1998. 

(b) $99 per Year of Credited Service through December 31, 2001, $80 per Year of Credited 

Service through May 31, 2003, and $50 per Year of Credited Service thereafter. 

Payment of such benefit shall begin as of the Normal Retirement Date, as of the Early Retirement Date or as of the 

first day of any subsequent month that is prior to the Normal Retirement Date. However, if such payment begins 

prior to the Normal Retirement Date, the reduction described in section 3.2 shall apply. 

If an individual who received a lump sum payment again becomes a Participant, he or she shall have the 

right to restore his or her Accrued Benefit (including all optional forms of benefits and subsidies relating to such 

benefits) to the extent forfeited upon repayment to the Plan of the full amount of the distribution plus interest, 

compounded annually from the date of distribution at the rate determined for purposes of section 41 l(c)(2)(C) ofthe 

on which such person Code. Such repayment must be made before the earlier of five years after the first date 

subsequently becomes a Participant or the date such person incurs five consecutive Breaks in Service following the 

date of distribution. 

Section 3.4 - Disability Retirement Benefit 

A Participant who has at least five Years of Vesting Service, who is not eligible for a Normal Retirement Benefit, 

who incurs a Total and Permanent Disability prior to July 1, 2010 and on whose behalf Employer contributions were 

made during the 12-month period immediately preceding the date of his or her Total and Permanent Disability is 

entitled to a Total and Permanent Disability Retirement Benefit equal to the sum of the following: 

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the benefit such person had accrued in the Southwest Ohio District Council of Carpenters (a) 

Dayton Pension Plan, or Pension Plan-Cincinnati, in the Southwest Ohio District Council of Carpenters -

both, at December 31, 1998, and 

(b) $99 per Year of Credited Service through December 31, 2001, $80 per Year of Credited 

Service through May 31, 2003, and $50 per Year of Credited Service thereafter. 

A Participant who has at least five Years of Vesting Service, who is not eligible for an Early Retirement Benefit, 

who incurs a Total and Permanent Disability on or after July 1, 2010 and on whose behalf Employer contributions 

were made during the 12-month period immediately preceding the date of his or her Total and Permanent Disability 

is entitled to a Total and Permanent Disability Retirement Benefit equal to the sum of the following: 

the benefit such person had accrued in the Southwest Ohio District Council of Carpenters (a) 

Dayton Pension Plan, or Pension Plan-Cincinnati, in the Southwest Ohio District Council of Carpenters -

both, at December 31, 1998, and 

(b) $99 per Year of Credited Service through December 31, 2001, $80 per Year of Credited 

Service through May 31, 2003, and $50 per Year of Credited Service thereafter. 

Such sum shall be reduced based on actuarial equivalent reductions from the Participant's Normal Retirement Date. 

A Participant who has at least five Years of Vesting Service, who is not eligible for an Early Retirement Benefit, 

who incurs a Total and Permanent Disability on or after July 1, 2010 and on whose behalf Employer contributions 

were made during the 12-month period immediately preceding the date of his or her Total and Permanent Disability 

is entitled to a Total and Permanent Disability Retirement Benefit equal to the Participant's Early Retirement Benefit 

determined under Section 3.2. 

If the Board of Trustees determines that the Participant is entitled to a Total and Permanent Disability 

Retirement Benefit based on a disability award from the Social Security Administration, the Total and Permanent 

Disability Retirement Benefit shall commence as of the first day of the month coincident with or next following the 

date the disability occurred, as determined by the Social Security Administration. If the Board of Trustees 

determines that the Participant is entitled to a Total and Permanent Disability Retirement Benefit, but the Participant 

has not received a disability award from the Social Security Administration, the Total and Permanent Disability 

Retirement Benefit shall commence as of the first day of the month coincident with or next following the later of 

(1) the receipt by the Board of Trustees of an application for the Total and Permanent Disability Retirement Benefit 

or (2) the date the Participant incurred the Total and Permanent Disability, as determined by the Board of Trustees. 

However, if a Participant applying for the Total and Permanent Disability Retirement Benefit is also eligible for an 

Early Retirement Benefit, such person may elect to have the Early Retirement Benefit commence as provided in section 3.3. In such event, if the Participant is subsequently determined to be eligible for the Total and Permanent 

Disability Retirement Benefit, his or her future monthly retirement benefit shall be adjusted to reflect the amount of 

the Total and Permanent Disability Retirement Benefit, and a lump sum payment equal to the product of (a) the 

difference between the monthly amount of the Total and Permanent Disability Retirement Benefit and the Early 

Retirement Benefit and (b) the number of months for which the Early Retirement Benefit was paid, shall be paid to 

such person. 

A Participant who has at least five Years of Vesting Service, who is not eligible for a Normal or Early 

Retirement Benefit, who incurs a Trade Disability and on whose behalf Employer contributions were made during 

the 12-month period immediately preceding the date his or her Trade Disability was incurred, is entitled to a Trade 

Disability Benefit equal to the Actuarial Equivalent of his or her Accrued Benefit determined as of the date the 

Trade Disability Benefit commences. 

The Trade Disability Benefit shall commence as of the first day of the month coincident with or next 

following the later of (1) the receipt by the Board of Trustees of an application for the Trade Disability Benefit or 

(2) the date the Participant incurred the Trade Disability, as determined by the Board of Trustees. 

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If a Participant who is receiving a Trade Disability Benefit is subsequently determined by the Social 

Security Administration to be entitled to a disability benefit under the Old Age and Survivors Disability Insurance 

(OASDI) program, the Trade Disability Benefit shall be converted to a Total and Permanent Disability Retirement 

Benefit effective on the first day of the month coincident with or next following the date of disability, as determined 

by the Social Security Administration, and a lump sum payment shall be made to the Participant if necessary to 

reflect the conversion from the Trade Disability Benefit to the Total and Permanent Disability Retirement Benefit. 

Notwithstanding the foregoing, however such conversion shall occur only if the date of disability determined by the 

Social Security Administration is within 12 months of the date Employer contributions were made for such 

Participant. 

Section 3.5 - Determination of Eligibility for Disability Retirement Benefit 

The Board of Trustees shall determine the type of disability benefit to which a Participant may be entitled. 

The Board of Trustees may accept the certification of any duly licensed medical practitioner acceptable to the Board 

of Trustees that the applicant is either totally and permanently disabled or is disabled for work in the trade, or the 

Board of Trustees may require that the applicant submit to an examination by a physician or physicians selected by 

the Board of Trustees and, additionally, may require a person receiving the Total and Permanent Disability 

Retirement Benefit or the Trade Disability Benefit to submit to re-examination periodically, to provide such 

evidence of earnings, or both, as the Board of Trustees may direct. Failure to so submit or provide shall be a basis 

for suspension or termination of such benefit. The Board of Trustees may accept as evidence of Total and Permanent 

Disability a determination by the Social Security Administration that the applicant is entitled to a disability benefit 

under the Old Age and Survivors Disability Insurance (OASDI) program. 

Upon the attainment of age 62, a Participant receiving the Disability Retirement Benefit shall not be 

required to submit continuing proof of disability. 

Section 3.6 - Cessation of Disability Retirement Benefit 

Any Participant receiving the Disability Retirement Benefit who subsequently ceases to be totally and 

permanently disabled or disabled for work in the trade (as the case may be) may apply for an Early Retirement 

Benefit (provided such person is eligible therefore), in which case the Early Retirement Benefit shall become 

payable for the month immediately following the month in which the Disability Retirement Benefit terminates. 

Furthermore, the Disability Retirement Benefit shall cease with the payment due for the month immediately 

preceding the Participant's Normal Retirement Date, as of which he or she shall be deemed eligible for the Normal 

Retirement Benefit. 

Section 3.7 - Form of Payment 

(a) Joint and Survivor Annuity. Unless an optional form of benefit described in subparagraph (b) has been elected pursuant to a Qualified Election during the 180 day period ( or 90 day period for 

notices given prior to January 1, 2007) preceding the Annuity Starting Date or unless the Participant is 

eligible for the Total and Permanent Disability Retirement Benefit or for the Trade Disability Benefit (in 

which case benefits shall be paid in the form of a Straight Life Annuity), a Participant who is married on 

his or her Annuity Starting Date shall receive benefits in the form of a Joint and Survivor Annuity. 

The Joint and Survivor Annuity and the optional form of benefits described in subparagraph (b) 

shall have the same Actuarial Value. A Joint and Survivor Annuity shall not be available to an alternate 

payee under a Qualified Domestic Relations Order [as defined in section 4l 4(p) of the Code]. 

(b) Other Forms of Payment. If a Participant is not married on his or her Annuity Starting 

Date or, if such person is married, pursuant to a Qualified Election, a Participant ( other than a Participant 

who is eligible for the Total and Permanent Disability Retirement Benefit or the Trade Disability Benefit) 

may elect during the 180 day period ( or 90 day period for notices given prior to January 1, 2007) preceding 

the Annuity Starting Date to receive retirement benefits in one of the following forms: 

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SWORCCPP2018-000260
(i) Straight Life Annuity. 

(ii) Ten-Year Certain and Life Benefit. 

The following paragraph shall apply only to Participants who retire prior to April 30, 2010. A Participant 

who is eligible to elect one of the foregoing forms of benefit payments and who has not attained the Normal 

Retirement Date when his or her monthly benefit begins may elect to receive a monthly benefit, the amount of 

which is $800 higher ( or such lesser amount, but in multiples of $100, as elected by the Participant) than the benefit 

payable at the Normal Retirement Date under the form of option elected and that has the same Actuarial Value as 

the form of benefit elected prior to the adjustment for increased benefits before the Normal Retirement Date. When 

such Participant attains his or her Normal Retirement Date, the monthly benefit payable to the Participant thereafter 

shall be reduced by the amount ofthe increase previously elected and paid to the Participant thereafter in the form of 

benefit elected. If the Participant dies before the Normal Retirement Date, the higher monthly benefit shall be 

reduced by the amount of the increase previously elected and the amount of the monthly benefit (if any) payable to 

the Beneficiary shall be based on the reduced amount. Notwithstanding the foregoing, an election to increase the 

monthly benefit payable under the form of option elected shall not be effective if the amount of the monthly benefit 

that would be payable to the Participant immediately after the Participant's Normal Retirement Date would be less 

than $200. Any post-retirement benefit increase applicable to a Participant who is receiving a monthly benefit in the 

form described in this paragraph will be applied uniformly to both the pre-age 62 and the post-age 62 portions of 

such benefit. Ifsuch increase is a flat-dollar monthly amount, such amount shall be added to both the pre-age 62 and 

the post-age 62 benefit. Ifsuch increase is a percentage of the monthly amount, such percentage shall also be applied 

to the pre-age 62 and the post-age 62 benefit. The benefit described in this paragraph shall not be available to an 

alternate payee under a Qualified Domestic Relations Order [as defined in section 4 l 4(p) of the Code]. 

No change in the form of payment shall be permitted after the Annuity Starting Date except (i) to the extent 

required by a Qualified Domestic Relations Order [as defined in section 414(p) of the Code] or (ii) as provided in 

section 3.6. 

Section 3.8 - Pre-Retirement Death Benefit 

(a) A death benefit shall be payable to the surviving spouse of a Participant who dies (i) on 

or after July 1, 2010, (ii) with at least five Years of Vesting Service, but (iii) prior to the Annuity Starting 

Date of an Early Retirement Benefit, if eligible. The death benefit shall be a monthly payment to the 

surviving spouse for life equal to the amount that would have been payable to the deceased Participant if he 

or she had retired and begun to receive benefits in the form of a Joint and Survivor Annuity (with a 50 

percent survivor factor) on the day before the death, or, if later, the Participant's Earliest Retirement Age. 

Such benefit shall commence as of the first day of the month following the month in which the Participant 

dies, or the first day of the month following the month in which the Participant would have attained his or 

her Earliest Retirement Age if later, and shall cease following the payment due for the month in which the 

death of such spouse occurs. 

(b) Any provision in this section to the contrary notwithstanding, if a Participant dies while 

receiving the monthly Total and Permanent Disability Retirement Benefit, he or she shall be deemed to 

have been working in Covered Employment at the date of death for purposes of determining the eligibility 

for, and the amount of, the pre-retirement death benefit. 

(c) Notwithstanding the foregoing provisions of this section, if any Participant or Former 

Participant dies while performing Qualified Military Service, the Beneficiary of such Participant or Former 

Participant shall be entitled to any additional benefits (other than benefit accruals), including any applicable 

pre-retirement death benefit under this section 3.8 provided by the Plan as if the Participant or Former 

Participant had resumed Covered Employment and then terminated employment on account of death. 

Section 3.9 - Post-Retirement Death Benefit 

If a Participant dies after the Annuity Starting Date ( other than that relating to the Total and Permanent 

Disability Retirement Benefit or the Trade Disability Benefit), any death benefit shall be governed by the 

SLK_TOL: #250533lv3 17 

SWORCCPP2018-000261
survivorship provisions (if any) applicable to the form of retirement benefit that the Participant elected, or is deemed 

to have elected. 

(a) If such form of benefit is the Joint and Survivor Annuity with a 100 percent survivor 

factor, the surviving spouse to whom the deceased Participant was married when monthly benefit payments 

to the Participant commenced shall receive monthly benefits for life, in an amount equal to 100 percent of 

the amount being paid to the Participant. Such benefits shall commence as of the first day of the month 

following the Participant's death and shall cease following the payment due for the month in which the 

death of such spouse occurs. 

(b) If such form of benefit is the Joint and Survivor Annuity with a 75 percent survivor 

factor, the surviving spouse to whom the deceased Participant was married when monthly benefit payments 

to the Participant commenced shall receive monthly benefits for life, in an amount equal to 75 percent of 

the amount being paid to the Participant. Such benefits shall commence as of the first day of the month 

following the Participant's death and shall cease following the payment due for the month in which the 

death of such spouse occurs. 

(c) If such form of benefit is the Joint and Survivor Annuity with a 50 percent survivor 

factor, the surviving spouse to whom the deceased Participant was married when monthly benefit payments 

to the Participant commenced shall receive monthly benefits for life, in an amount equal to 50 percent of 

the amount being paid to the Participant. Such benefits shall commence as of the first day of the month 

following the Participant's death and shall cease following the payment due for the month in which the 

death of such spouse occurs. 

(d) If such form of benefit is the Ten-Year Certain and Life Benefit, and if the Participant 

dies before receiving 120 monthly payments, monthly payments in the amount being received by the 

Participant shall be paid to the Beneficiary of the Participant until a total of 120 monthly payments has 

been made to the Participant and Beneficiary in the aggregate. If the Participant dies after receiving 

120 monthly payments, no further benefits shall be payable. 

Section 3.10 - Non-Duplication 

Benefits available to a Participant shall be reduced to the extent necessary to prevent a duplication of 

benefits, other than the Total and Permanent Disability Retirement Benefit or the Trade Disability Benefit. 

Section 3.11 - Payment of Small Benefit and Payment of Benefit Pursuant to a Qualified Domestic Relations 

Order 

If the Actuarial Value of a Participant's vested Accrued Benefit does not exceed $5,000 at the time he or 

she has applied for (and otherwise is entitled to receive) the Normal Retirement Benefit, the Early Retirement 

Benefit or the Deferred Vested Benefit, the Participant will receive a distribution of the Actuarial Value of the entire 

vested portion of such Accrued Benefit, and the non vested portion will be treated as a forfeiture. However, in lieu of 

such distribution, the Participant may elect to have such amount transferred directly to an eligible retirement plan in 

the manner described in section 4.9. For purposes of the foregoing, if the Actuarial Value of a Participant's vested 

Accrued Benefit is zero, he or she shall be deemed to have received a distribution thereof. In the event of a 

mandatory distribution greater than $1,000 in accordance with the preceding provisions of this paragraph, if the 

Participant or Former Participant does not elect to have such distribution paid directly to an eligible retirement plan 

specified by the Participant or Former Participant in a direct rollover or to receive the distribution directly in 

accordance with this section 3.11, then the Board of Trustees will cause the distribution to be paid in a direct 

rollover to an individual retirement plan designated by the Board of Trustees.. 

If a Participant receives a distribution pursuant to the prior paragraph and again becomes a Participant, he 

or she shall have the right to restore his or her Accrued Benefit (including all optional forms of benefits and 

subsidies relating to such benefits) to the extent forfeited upon repayment to the Plan of the full amount of the 

distribution plus interest, compounded annually from the date of distribution at the rate determined for purposes of 

section 411 (c )(2)(C) of the Code. Such repayment must be made before the earlier of five years after the first date on 

SLK_TOL: #2505331v3 18 

SWORCCPP2018-000262
which such person subsequently becomes a Participant or the date such person incurs five consecutive Breaks in 

Service following the date of distribution. 

If the Actuarial Value of the pre-retirement surviving spouse's annuity described in section 3.8 does not 

exceed $5,000, the Actuarial Value thereof shall be paid as soon as administratively feasible to the surviving spouse 

to whom the decedent was married at the date of death in full satisfaction of the Plan's obligation to such survivor or, 

if such surviving spouse so elects, shall instead be transferred directly to an eligible retirement plan in the manner 

described in section 4.9. 

If the Actuarial Value of the vested benefit assigned to an alternate payee under a Qualified Domestic 

Relations Order does not exceed $5,000 and if the Qualified Domestic Relations Order so provides, the Actuarial 

Value thereof shall be 

 distributed to the alternate payee in lump sum at such time as is provided in the order in lieu of 

any other benefit assigned by the Qualified Domestic Relations Order or provided by the Plan, 

 if otherwise permissible, transferred directly to an eligible retirement plan in the manner described 

in section 4.9. 

Section 3.12 - Restrictions on Maximum Amount of Benefit 

The limitations of this section shall apply in Limitation Years beginning on or after July 1, 2007, except as 

otherwise provided herein. 

(a) Definitions. For the purpose of determining the benefit limitation set forth in this section, 

the following terms are defined: 

Annual Benefit means a benefit that is payable annually in the form of a Straight Life 

Annuity. Except as provided below, where a benefit is payable in a form other than a 

Straight Life Annuity, the benefit shall be adjusted to an actuarially equivalent Straight 

Life Annuity that begins at the same time as such other form of benefit and is payable on 

the first day of each month, before applying the limitations of this section. For a 

Participant who has or will have distributions commencing at more than one Annuity 

Starting Date, the Annual Benefit shall be determined as of each such Annuity Starting 

Date (and shall satisfy the limitations of this section as of each such date), actuarially 

adjusting for past and future distributions of benefits commencing at the other Annuity 

Starting Dates. For this purpose, the determination of whether a new starting date has 

occurred shall be made without regard to section 1.40l(a)-20, Q&A l0(d), and with 

regard to section l.415(b)-l(b)(l)(iii)(B) and (C) of the regulations. 

No actuarial adjustment to the benefit shall be made for (i) survivor benefits payable to a 

surviving spouse under a qualified joint and survivor annuity to the extent such benefits 

would not be payable if the Participant's benefit were paid in another form; (ii) benefits 

that are not directly related to retirement benefits (such as a qualified disability benefit, 

preretirement incidental death benefits, and post-retirement medical benefits); or (iii) the 

inclusion in the form of benefit of an automatic benefit increase feature, provided the 

form of benefit is not subject to section 417(e)(3) of the Code and would otherwise 

satisfy the limitations of this section, and the Plan provides that the amount payable 

under the form of benefit in any Limitation Year shall not exceed the limits of this 

section applicable at the Annuity Starting Date, as increased in subsequent years pursuant 

to section 415(d) of the Code. For this purpose, an automatic benefit increase feature is 

included in a form of benefit if the form of benefit provides for automatic periodic 

increases to the benefits paid in that form. 

The determination of the Annual Benefit shall take into account Social Security 

supplements described in section 41 l(a)(9) of the Code and benefits transferred from 

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SWORCCPP2018-000263
another defined benefit plan, other than transfers of distributable benefits pursuant to 

section 1.4ll(d)-4, Q&A-3(c), of the regulations, but shall disregard benefits attributable 

to employee contributions or rollover contributions. 

Effective for distributions in Plan Years beginning after December 31, 2003, the 

determination of actuarial equivalence of forms of benefit other than a Straight Life 

Annuity shall be made in accordance with (1) or (2) below: 

(1) Benefit Forms Not Subject to Code Section 417(e)(3). The Straight Life Annuity 

that is actuarially equivalent to the Participant's form of benefit shall be 

determined under this subparagraph (1) if the form of the Participant's benefit is 

either (i) a nondecreasing annuity ( other than a Straight Life Annuity) payable 

for a period of not less than the life of the Participant ( or, in the case of a 

qualified preretirement survivor annuity, the life of the surviving spouse), or 

(ii) an annuity that decreases during the life of the Participant merely because of 

(a) the death of the survivor annuitant (but only if the reduction is not below 50 

percent of the benefit payable before the death of the survivor annuitant), or 

(b) the cessation or reduction of Social Security supplements or qualified 

disability payments [as defined in section 401(a)(l 1) ofthe Code]. 

(i) Limitation Years beginning before July I, 2007. For Limitation Years 

beginning before July 1, 2007, the actuarially equivalent Straight Life 

Annuity is equal to the annual amount of the Straight Life Annuity 

commencing at the same Annuity Starting Date that has the same 

actuarial present value as the Participant's form of benefit computed 

using whichever of the following produces the greater annual amount: 

A. the interest rate and the mortality table ( or other tabular factor) 

specified in Appendix I of the Plan for adjusting benefits in 

the same form; and 

B. a 5 percent interest rate assumption and the mortality table 

described in the model amendment to the Plan reflecting Rev. 

Rul. 2001-62 for that Annuity Starting Date. 

(ii) Limitation Years beginning on and after July 1, 2007. For Limitation 

Years beginning on and after July 1, 2007, the actuarially equivalent 

Straight Life Annuity is equal to the greater of: 

A. the annual amount of the Straight Life Annuity (if any) 

payable to the Participant under the Plan commencing at the 

same Annuity Starting Date as the Participant's form of 

benefit; and 

B. the annual amount of the Straight Life Annuity commencing at 

the same Annuity Starting Date that has the same actuarial 

present value as the Participant's form of benefit, computed 

using a 5 percent interest rate assumption and the mortality 

table described in the model amendment to the Plan reflecting 

Rev. Rul. 2001-62 for that Annuity Starting Date. 

(2) Benefit Forms Subject to Code Section 4 l 7(e)(3). The Straight Life Annuity that 

is actuarially equivalent to the Participant's form of benefit shall be determined 

under this subparagraph (2) if the form of the Participant's benefit is other than a 

benefit form described in subparagraph (1) above. In this case, the actuarially 

equivalent Straight Life Annuity shall be determined as follows: 

SLK_TOL: #2505331 v3 20 

SWORCCPP2018-000264
(i) 

(ii) 

Annuity Starting Date in Plan Years Beginning After 2005. If the 

Annuity Starting Date of the Participant's form of benefit is in a Plan 

Year beginning after 2005, the actuarially equivalent Straight Life 

Annuity is equal to the greatest of 

A. the annual amount ofthe Straight Life Annuity commencing at 

the same Annuity Starting Date that has the same actuarial 

present value as the Participant's form of benefit, computed 

using the interest rate and the mortality table ( or other tabular 

factor) specified in Appendix I of the Plan for adjusting 

benefits in the same form; 

B. the annual amount of the Straight Life Annuity commencing at 

the same Annuity Starting Date that has the same actuarial 

present value as the Participant's form of benefit, computed 

using a 5.5 percent interest rate assumption and the mortality 

table mortality table described in the model amendment to the 

Plan reflecting Rev. Rul. 2001-62; and 

C. the annual amount of the Straight Life Annuity commencing at 

the same Annuity Starting Date that has the same actuarial 

present value as the Participant's form of benefit, using the 

Applicable Interest Rate described herein and the applicable 

mortality table described in the model amendment to the Plan 

reflecting Rev.. Rul. 2001-62, divided by 1.05. 

Annuity Starting Date in 2004 and 2005. If the Annuity Starting Date 

of the Participant's form of benefit is in 2004 or 2005, the actuarially 

equivalent Straight Life Annuity is equal to the annual amount of the 

Straight Life Annuity commencing at the same Annuity Starting Date 

that has the same actuarial present value as the Participant's form of 

benefit, computed using whichever of the following produces the 

greater annual amount: 

A. the interest rate and the mortality table (or other tabular factor) 

specified in Appendix I of the Plan for adjusting benefits in 

the same form; and 

B. 5.5 percent interest rate assumption and the mortality table 

described in the model amendment to the Plan reflecting Rev. 

Ru!. 2001-62. 

Ifthe Annuity Starting Date of the Participant's benefit is in 2004, the 

application of this subparagraph (2)(ii) shall not cause the amount 

payable under the Participant's form of benefit to be less than the 

benefit calculated under the Plan taking into account the limitations of 

this section, except that the actuarially equivalent Straight Life Annuity 

is equal to the annual amount of the Straight Life Annuity commencing 

at the same Annuity Starting Date that has the same actuarial present 

value as the Participant's form of benefit, computed using whichever of 

the following produces the greatest annual amount: 

C. the interest rate and the mortality table ( or other tabular factor) 

specified in Appendix I of the Plan for adjusting benefits in 

the same form; 

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SWORCCPP2018-000265
D. the applicable interest rate in Appendix I of the Plan and the 

mortality table described in the model amendment to the Plan 

reflecting Rev. Rul. 2001-62; and 

E. the applicable interest rate in Appendix I of the Plan (as in 

effect on the last day of the last Plan Year beginning before 

January 1, 2004, under the provisions of the Plan then adopted 

and in effect) and the mortality table described in the model 

amendment to the Plan reflecting Rev. Rul. 2001-62. 

Applicable Interest Rate (see Appendix I) means, for Plan Years beginning on or after 

July 1, 2000 but prior to January 1, 2008, the rate of interest on 30-year Treasury 

securities as specified by the Commissioner for the look-back month for the stability 

period. The look-back month applicable to the stability period is the calendar month 

preceding the first day of the stability period. The stability period is the successive period 

of one Plan Year that contains the Annuity Starting Date for the distribution and for 

which the Applicable Interest Rate remains constant. For Plan Years beginning after 

December 31, 2007, Applicable Interest Rate shall instead mean the rate described in 

section417(e)(3)(C) of the Code (and as amplified by any guidance issued by the 

Commissioner) for the foregoing look-back month and stability period. 

A Plan amendment that changes the date for determining the Applicable Interest Rate 

(including an indirect change such as the results of a change in Plan Year when the 

stability period is the Plan Year), shall not be given effect with respect to any distribution 

during the period commencing one year after the later of the amendment's effective date 

or adoption date, if, during such period and as a result of such amendment, the 

Participant's distribution would be reduced. 

Applicable Mortality Table (see Appendix I) means, on any date, the table according to 

the method set forth in section 417(e) of the Code, as amplified by Rev. Rul. 2007-67 and 

any future guidance issued by the Commissioner. 

Defined Benefit Compensation Limitation means 100 percent of a Participant's High 

Three-Year Average Compensation, payable in the form of a Straight Life Annuity. 

In the case of a Participant who is rehired after a Severance from Employment, the 

Defined Benefit Compensation Limitation is the greater of 100 percent of the 

Participant's High Three-Year Average Compensation, as determined prior to the 

Severance from Employment, or 100 percent of the Participant's High Three-Year 

Average Compensation, as determined after the Severance from Employment under the 

definition of High Three-Year Average Compensation. 

Defined Benefit Dollar Limitation means, effective for Limitation Years ending after 

December 31, 2001, $160,000, automatically adjusted under section 415(d) of the Code, 

effective January 1 of each year, as published in the Internal Revenue Bulletin, and 

payable in the form of a Straight Life Annuity. The new limitation shall apply to 

Limitation Years ending with or within the calendar year of the date of the adjustment, 

but a Participant's benefits shall not reflect the adjusted limit prior to January 1 of that 

calendar year. The automatic annual adjustment of the Defined Benefit Dollar Limitation 

under section 415(d) of the Code shall not apply to Participants who have had a 

Severance from Employment. 

Employer means, for purposes of this section, the Employer that adopts or contributes to 

this Plan, and all members of a controlled group of corporations [as defined in section 

414(b) of the Code, as modified by section 415(h) of the Code], all commonly controlled 

SLK_TOL: #2505331 v3 22 

SWORCCPP2018-000266
trades or businesses [as defined in section 414(c) ofthe Code], as modified, except in the 

case of a brother-sister group of trades or businesses under common control, by section 

415(h) of the Code], or affiliated service groups [as defined in section 414(m) of the 

Code] of which the adopting or contributing Employer is a part, and any other entity 

required to be aggregated with the Employer pursuant to section 414(o) ofthe Code. 

Formerly Affiliated Plan means a plan that, immediately prior to the cessation of 

affiliation, was actually maintained by an Employer and immediately after the cessation 

of affiliation, is not actually maintained by an Employer. For this purpose, cessation of 

affiliation means the event that causes an entity to no longer be considered an Employer, 

such as the sale of a member of a controlled group of corporations, as defined in section 

414(b) of the Code, as modified by section 415(h) of the Code, to an unrelated 

corporation, or that causes a plan to not actually be maintained by the Employer, such as 

a transfer ofplan sponsorship outside a controlled group. 

High Three-Year Average Compensation means the average Compensation for the 

three consecutive years of service (or if the Participant has less than three consecutive 

years of service, the Participant's longest consecutive period of service, including 

fractions of years, but not less than one year) with the Employer that produces the highest 

average. A year of service with an Employer is the 12-consecutive month period ending 

on the last day of each Limitation Year. In the case of a Participant who is rehired by an 

Employer after a Severance from Employment, the Participant's High Three-Year 

Average Compensation shall be calculated by excluding all years for which the 

Participant performs no services for and receives no Compensation from an Employer 

(the break period) and by treating the years immediately preceding and following the 

break period as consecutive. A Participant's Compensation for a year of service shall not 

include Compensation in excess of the limitation under section 40l(a)(l7) of the Code 

that is in effect for the calendar year in which such year ofservice begins. 

Maximum Permissible Benefit means, except as otherwise provided in this section, the 

lesser of the Defined Benefit Dollar Limitation or the Defined Benefit Compensation 

Limitation (both adjusted where required, as provided below). 

(1) Adjustment for Less Than Ten Years of Participation or Years of Service. Ifthe 

Participant has less than ten Years of Participation in the Plan, the Defined 

Benefit Dollar Limitation shall be multiplied by a fraction, (i) the numerator of 

which is the number of Years of Participation ( or part thereof, but not less than 

one year) in the Plan, and (ii) the denominator of which is ten. In the case of a 

Participant who has less than ten Years of Service with the Employers the 

Defined Benefit Compensation Limitation shall be multiplied by a fraction, 

(i) the numerator of which is the number ofYears of Service (or part thereof, but 

not less than one year), and (ii) the denominator of which is ten. 

(2) Adjustment of Defined Benefit Dollar Limitation for Benefit Commencement 

Before Age 62 or After Age 65. Effective for benefits commencing in 

Limitation Years ending after December 31, 2001, the Defined Benefit Dollar 

Limitation shall be adjusted if the Annuity Starting Date of the Participant's 

benefit is before age 62 or after age 65. Ifthe Annuity Starting Date is before 

age 62, the Defined Benefit Dollar Limitation shall be adjusted under 

subparagraph (2)(i) below, as modified by subparagraph (2)(iii) below. If the 

Annuity Starting Date is after age 65, the Defined Benefit Dollar Limitation 

shall be adjusted under subparagraph (2)(ii) below, as modified by subparagraph 

(2)(iii) below. 

SLK_TOL: #2505331 v3 23 

SWORCCPP2018-000267
(i) Adjustment of Defined Benefit Dollar Limitation for Benefit 

Commencement Before Age 62. 

A. Limitation Years Beginning Before July 1. 2007. If the 

Annuity Starting Date for the Participant's benefit is prior to 

age 62 and occurs in a Limitation Year beginning before 

July 1, 2007, the Defined Benefit Dollar Limitation for the 

Participant's Annuity Starting Date is the annual amount of a 

benefit payable in the form of a Straight Life Annuity 

commencing at the Participant's Annuity Starting Date that is 

the actuarial equivalent of the Defined Benefit Dollar 

Limitation [adjusted under subparagraph (1) above for Years 

of Participation less than ten, if required], with actuarial 

equivalence computed using whichever of the following 

produces the smaller annual amount: (i) the interest rate and 

the mortality table ( or other tabular factor) specified in 

Appendix I; or (ii) a 5 percent interest rate assumption and the 

Applicable Mortality Table. To the extent the Plan does not 

specify an interest rate and mortality table (or other tabular 

factor) or for ages for which no tabular factor is specified, a 5 

percent interest rate and the Applicable Mortality Table shall 

be used to determine actuarial equivalence. 

B. Limitation Years Beginning On or After July 1, 2007. 

I. Plan Does Not Have Immediately Commencing 

Straight Life Annuity Payable at Both Age 62 and the 

Age of Benefit Commencement. If the Annuity 

Starting Date for the Participant's benefit is prior to 

age 62 and occurs in a Limitation Year beginning on 

or after July 1, 2007, and the Plan does not have an 

immediately commencing Straight Life Annuity 

payable at both age 62 and the age of benefit 

commencement, the Defined Benefit Dollar 

Limitation for the Participant's Annuity Starting Date 

is the annual amount of a benefit payable in the form 

of a Straight Life Annuity commencing at the 

Participant's Annuity Starting Date that is the 

actuarial equivalent of the Defined Benefit Dollar 

Limitation [adjusted under subparagraph (1) above 

for Years of Participation less than ten, if required], 

with actuarial equivalence computed using a 5 

percent interest rate assumption and the Applicable 

Mortality Table for the Annuity Starting Date (and 

expressing the Participant's age based on completed 

calendar months as ofthe Annuity Starting Date). 

II. Plan Has Immediately Commencing Straight Life 

Annuity Payable at Both Age 62 and the Age of 

Benefit Commencement. Ifthe Annuity Starting Date 

for the Participant's benefit is prior to age 62 and 

occurs in a Limitation Year beginning on or after 

July 1, 2007, and the Plan has an immediately 

commencing Straight Life Annuity payable at both 

age 62 and the age of benefit commencement, the 

Defined Benefit Dollar Limitation for the 

SLK_TOL: #2505331 v3 24 

SWORCCPP2018-000268
Participant's Annuity Starting Date is the lesser of the 

limitation determined under subparagraph (2)(i)B.I. 

above and the Defined Benefit Dollar Limitation 

[adjusted under subparagraph (1) above for Years of 

Participation less than ten, if required], multiplied by 

the ratio of the annual amount of the immediately 

commencing Straight Life Annuity under the Plan at 

the Participant's Annuity Starting Date to the annual 

amount of the immediately commencing Straight Life 

Annuity under the Plan at age 62, both determined 

without applying the limitations ofthis section. 

C. The provisions of this subparagraph (2) shall be modified as 

provided in section 415(b)(9) of the Code for Participants who 

are commercial airline pilots. 

D. Notwithstanding any other provision of this subparagraph (2), 

the age adjusted Defined Benefit Dollar Limitation applicable 

to a Participant does not decrease on account of an increase in 

age or the performance of additional service. 

(ii) Adjustment of Defined Benefit Dollar Limitation for Benefit 

Commencement After Age 65: 

A. Limitation Years Beginning Before July 1, 2007. If the 

Annuity Starting Date for the Participant's benefit is after age 

65 and occurs in a Limitation Year beginning before July 1, 

2007, the Defined Benefit Dollar Limitation for the 

Participant's Annuity Starting Date is the annual amount of a 

benefit payable in the form of a Straight Life Annuity 

commencing at the Participant's Annuity Starting Date that is 

the actuarial equivalent of the Defined Benefit Dollar 

Limitation [adjusted under subparagraph (1) above for Years 

of Participation less than ten, if required], with actuarial 

equivalence computed using whichever of the following 

produces the smaller annual amount: (i) the interest rate and 

the mortality table (or other tabular factor) specified in the 

Plan for purposes of determining actuarial equivalence for late 

retirement benefits; or (ii) a 5 percent interest rate assumption 

and the Applicable Mortality Table. 

B. Limitation Years Beginning On or After July 1, 2007. 

I. Plan Does Not Have Immediately Commencing 

Straight Life Annuity Payable at Both Age 65 and the 

Age of Benefit Commencement. If the Annuity 

Starting Date for the Participant's benefit is after age 

65 and occurs in a Limitation Year beginning on or 

after July 1, 2007, and the Plan does not have an 

immediately commencing Straight Life Annuity 

payable at both age 65 and the age of benefit 

commencement, the Defined Benefit Dollar 

Limitation at the Participant's Annuity Starting Date 

is the annual amount of a benefit payable in the form 

of a Straight Life Annuity commencing at the 

Participant's Annuity Starting Date that is the 

SLK_TOL: #250533lv3 25 

SWORCCPP2018-000269
actuarial equivalent of the Defined Benefit Dollar 

Limitation [adjusted under subparagraph (1) above 

for Years of Participation less than ten, if required], 

with actuarial equivalence computed using a 5 

percent interest rate assumption and the Applicable 

Mortality Table for that Annuity Starting Date (and 

expressing the Participant's age based on completed 

calendar months as of the Annuity Starting Date). 

II. Plan Has Immediately Commencing Straight Life 

Annuity Payable at Both Age 65 and the Age of 

Benefit Commencement. If the Annuity Starting Date 

for the Participant's benefit is after age 65 and occurs 

in a Limitation Year beginning on or after July 1, 

2007, and the Plan has an immediately commencing 

Straight Life Annuity payable at both age 65 and the 

age of benefit commencement, the Defined Benefit 

Dollar Limitation at the Participant's Annuity Starting 

Date is the lesser of the limitation determined under 

subparagraph (2)(ii)B .I. above and the Defined 

Benefit Dollar Limitation [adjusted under 

subparagraph (1) above for Years of Participation 

less than ten, if required], multiplied by the ratio of 

the annual amount of the adjusted immediately 

commencing Straight Life Annuity under the Plan at 

the Participant's Annuity Starting Date to the annual 

amount of the adjusted immediately commencing 

Straight Life Annuity under the Plan at age 65, both 

determined without applying the limitations of this 

section. For this purpose, the adjusted immediately 

commencing Straight Life Annuity under the Plan at 

the Participant's Annuity Starting Date is the annual 

amount of such annuity payable to the Participant, 

computed disregarding the Participant's accruals after 

age 65 but including actuarial adjustments even if 

those actuarial adjustments are used to offset 

accruals; and the adjusted immediately commencing 

Straight Life Annuity under the Plan at age 65 is the 

annual amount of such annuity that would be payable 

under the Plan to a hypothetical Participant who is 

age 65 and has the same accrued benefit as the 

Participant. 

(iii) Notwithstanding the other requirements of this subparagraph (2), in 

adjusting the Defined Benefit Dollar Limitation for the Participant's 

Annuity Starting Date under subparagraphs (2)(i)(A), (2)(i)(B)(I), 

(2)(ii)(A) and (2)(ii)(B)(I), no adjustment shall be made to reflect the 

probability of a Participant's death between the Annuity Starting Date 

and age 62, or between age 65 and the Annuity Starting Date, as 

applicable, if benefits are not forfeited upon the death of the Participant 

prior to the Annuity Starting Date. To the extent benefits are forfeited 

upon death before the Annuity Starting Date, such an adjustment shall 

be made. For this purpose, no forfeiture shall be treated as occurring 

upon the Participant's death if the Plan does not charge Participants for 

providing a qualified preretirement survivor annuity, as defined in 

section 417(c) ofthe Code, upon the Participant's death. 

SLK_TOL: #250533lv3 26 

SWORCCPP2018-000270
SLK_TOL: #2505331v3 

(3) Minimum Benefits Permitted. Notwithstanding anything else in this definition 

to the contrary, the benefit otherwise accrued or payable to a Participant under 

this Plan shall be deemed not to exceed the Maximum Permissible Benefit if: 

(i) the retirement benefits payable for a Limitation Year under any form of 

benefit with respect to such Participant under this Plan and under all 

other defined benefit plans (without regard to whether a plan has been 

terminated) ever maintained by the Employer do not exceed $10,000 

multiplied by a fraction, (1) the numerator of which is the Participant's 

number of Years of Service ( or part thereof, but not less than one year) 

with the Employer (not to exceed ten), and (2) the denominator of 

which is 10; and 

(ii) the Employer or a Predecessor Employer) has not at any time 

maintained a defined contribution plan in which the Participant 

participated. [For this purpose, mandatory employee contributions 

under a defined benefit plan, individual medical benefit accounts under 

section 40l(h) of the Code, and accounts for post-retirement medical 

benefits established under section 419A(d)(I) of the Code are not 

considered a separate defined contribution plan]. 

Predecessor Employer means, with respect to a Participant, a former employer if the 

Employer maintains a plan that provides a benefit which the Participant accrued while 

performing services for the former employer. Predecessor Employer also means, with 

respect to a Participant, a former entity that antedates the Employer if, under the facts and 

circumstances, the Employer constitutes a continuation of all or a portion of the trade or 

business ofthe former entity. 

Severance from Employment means an Employee has ceased to be an Employee of an 

Employer. An Employee does not have a Severance from Employment if, in connection 

with a change of employment, the Employee's new employer contributes to the plan with 

respect to the employee. 

Year of Participation means, for purposes of the definition of Maximum Permissible 

Benefit, one year (computed to fractional parts of a year) for each Plan Year for which 

the following conditions are met: 

(1) the Participant is credited with a year of service for benefit accrual purposes, and 

(2) the Participant is included as a Participant under the eligibility provisions of the 

Plan for at least one day ofthe Plan Year. 

If these two conditions are met, the portion of a Year of Participation credited to the 

Participant shall equal the amount of accrual service credited to the Participant for such 

Plan Year. A Participant who is totally and permanently disabled within the meaning of 

section 415(c)(3)(C)(i) of the Code for a Plan Year shall receive a Year of Participation 

with respect to that period. In addition, for a Participant to receive a Year of Participation 

(or part thereof) for a Plan Year, the Plan must be established no later than the last day of 

such Plan Year. In no event will more than one Year of Participation be credited for any 

12-month period. 

Year of Service means, for purposes of the definition of Maximum Permissible Benefit, 

one year (computed to fractional parts of a year) for each Plan Year for which the 

Participant is credited with at least the number of Hours of Service for benefit accrual 

purposes, taking into account only service with the Employer or a Predecessor Employer. 

27 

SWORCCPP2018-000271
(b) The Annual Benefit otherwise payable to a Participant at any time will not exceed the 

Maximum Permissible Benefit. Ifthe benefit the Participant would otherwise accrue in a 

Limitation Year would produce an Annual Benefit in excess ofthe Maximum Permissible 

Benefit, the benefit shall be limited ( or the rate of accrual reduced) to a benefit that does 

not exceed the Maximum Permissible Benefit. 

(c) If the Participant is, or has ever been, a participant in another qualified defined benefit 

plan (without regard to whether the plan has been terminated) maintained by the 

Employer or a Predecessor Employer, the sum of the Participant's Annual Benefits from 

all such plans may not exceed the Maximum Permissible Benefit. Where the Participant's 

employer-provided benefits under all such defined benefit plans ( determined as of the 

same age) would exceed the Maximum Permissible Benefit applicable at that age, the 

benefit shall be limited (or the rate of accrual reduced) in the plan most recently 

established to the extent necessary so that the sum of the Participant's Annual Benefits 

from all such plan(s) does not exceed the Maximum Permissible Benefit. 

(d) The application of the provisions of this section shall not cause the Maximum 

Permissible Benefit for any Participant to be less than the Participant's accrued benefit 

under all the defined benefit plans of the Employer or a Predecessor Employer as of the 

end of the last Limitation Year beginning before July 1, 2007 under the provisions of the 

plans that were both adopted and in effect before April 5, 2007. The preceding sentence 

applies only if the provisions of such defined benefit plans that were both adopted and in 

effect before April 5, 2007 satisfied the applicable requirements of statutory provisions, 

regulations, and other published guidance relating to section 415 ofthe Code in effect as 

of the end of the last Limitation Year beginning before July 1, 2007, as described in 

section l.415(a)-1 (g)(4) ofthe regulations. 

(e) The limitations of this section shall be determined and applied taking into account the 

rules in (f) below. 

(f) Other Rules. 

(1) Benefits under Terminated Plans. If a defined benefit plan maintained by the 

Employer has terminated with sufficient assets for the payment of benefit 

liabilities of all plan participants and a participant in the plan has not yet 

commenced benefits under the plan, the benefits provided pursuant to the 

annuities purchased to provide the participant's benefits under the terminated 

plan at each possible annuity starting date shall be taken into account in 

applying the limitations of this section. If there are not sufficient assets for the 

payment of ail participants' benefit liabilities, the benefits taken into account 

shall be the benefits that are actually provided to the participant under the 

terminated plan. 

(2) Benefits Transferred From the Plan. If a participant's benefits under a defined 

benefit plan maintained by the Employer are transferred to another defined 

benefit plan maintained by the Employer and the transfer is not a transfer of 

distributable benefits pursuant to section 1.41 l(d)-4, Q&A-3(c) of the 

regulations, the transferred benefits are not treated as being provided under the 

transferor plan (but are taken into account as benefits provided under the 

transferee plan). If a participant's benefits under a defined benefit plan 

maintained by the Employer are transferred to another defined benefit plan that 

is not maintained by the Employer and the transfer is not a transfer of 

distributable benefits pursuant to section 1.411(d)- 4, Q&A-3(c), of the 

regulations, the transferred benefits are treated by the Employer's plan as if such 

benefits were provided under annuities purchased to provide benefits under a 

SLK_TOL: #250533 lv3 28 

SWORCCPP2018-000272
plan maintained by the Employer that terminated immediately prior to the 

transfer with sufficient assets to pay all participants' benefit liabilities under the 

plan. If a participant's benefits under a defined benefit plan maintained by the 

Employer are transferred to another defined benefit plan in a transfer of 

distributable benefits pursuant to section 1.41l(d)- 4, Q&A-(c), of the 

regulations, the amount transferred is treated as a benefit paid from the 

transferor plan. 

(3) Formerly Affiliated Plans of the Employer. A Formerly Affiliated Plan of the 

Employer shall be treated as a plan maintained by the Employer, but the 

Formerly Affiliated Plan shall be treated as if it had terminated immediately 

prior to the cessation of affiliation with sufficient assets to pay participants' 

benefit liabilities under the plan and had purchased annuities to provide benefits. 

(4) Plans of a Predecessor Employer. If the Employer maintains a defined benefit 

plan that provides benefits accrued by a participant while performing services 

for a Predecessor Employer, the participant's benefits under a plan maintained 

by a Predecessor Employer shall be treated as provided under a plan maintained 

by the Employer. However, for this purpose, the plan of the Predecessor 

Employer shall be treated as if it had terminated immediately prior to the event 

giving rise to the Predecessor Employer relationship with sufficient assets to pay 

participants' benefit liabilities under the plan, and had purchased annuities to 

provide benefits; the Employer and the Predecessor Employer shall be treated as 

if they were a single employer immediately prior to such event and as unrelated 

employers immediately after the event; and if the event giving rise to the 

predecessor relationship is a benefit transfer, the transferred benefits shall be 

excluding in determining the benefits provided under the plan of the Predecessor 

Employer. 

(5) Special Rules. The limitations of this section shall be determined and applied 

taking into account the rules in section l .4 l 5(f)-1 ( d), ( e ), and (h) of the 

regulations. 

(6) Multiemployer Plans. 

(i) Only the benefits under this multiemployer plan shall be treated as 

benefits provided under a plan maintained by the Employer for 

purposes of this section. 

(ii) Effective for Limitation Years ending after December 31, 2001, any 

other multiemployer plan shall be disregarded for purposes of applying 

the compensation limitation of the Defined Benefit Compensation 

Limitation definition and subparagraph (1) of the Maximum 

Permissible Benefit definition in subparagraph (a) above to a plan that 

is not a multiemployer plan. 

For purposes of computing the defined benefit plan fraction for any Limitation Year, the numerator shall be 

the Participant's projected annual benefit under the defined benefit plan as of the end of the Limitation Year and the 

denominator shall be the lesser of: 

(1) the product of 1.25 multiplied by the maximum permissible dollar amount of benefit in 

effect under section 415(b )(l)(A) ofthe Code for such year, or; 

(2) the product of 1.4 multiplied by the maximum permissible percentage of compensation 

limitation of the amount of benefit in effect under section 415(b )(l)(B) ofthe Code for such year. 

SLK_TOL: #250533lv3 29 

SWORCCPP2018-000273
If the preceding limitations are exceeded for any person, the Board of Trustees shall notify the 

administrator of each defined contribution plan in which such person is a participant of such condition and shall 

adjust accruals hereunder to comply with the limitations of this section to the extent necessary to ensure that 

contributions to the defined contribution plan are not affected. 

For any Plan Year in which the Plan is "top-heavy" within the meaning of section 416(g) of the Code and the 

requirements of section 416(h)(2) of the Code are not met, the preceding two paragraphs shall be applied by substituting 

"1.0" for "1.25" in subparagraphs (a) and (1) above. 

In the case of an individual who was a Participant in the Plan as of the beginning of the first Limitation Year 

beginning after December 31, 1986, whose current Accrued Benefit, as of the close of such Limitation Year, exceeded 

the dollar limitation of Code section 415(b), as amended by the Tax Reform Act of 1986, the Participant's current 

Accrued Benefit shall be the applicable dollar limitation for purposes of applying the limitations of Code sections 415(b) 

and 415( e); provided that the Plan satisfied the requirements of section 415 of the Code for all Limitation Years ending 

prior to January 1, 1987. 

Section 3.13 - Provisions Relating to Certain Military Service 

Notwithstanding any provision of the Plan to the contrary, contributions, benefits and service credit with 

respect to Qualified Military Service will be provided in accordance with section 414(u) of the Code. 

Notwithstanding the foregoing provisions ofthis section, if any Participant or Former Participant dies while 

performing Qualified Military Service [as defined in section 414(u) of the Code], the Beneficiary of such Participant 

or Former Participant shall be entitled to any additional benefits (other than benefit accruals), relating to the period 

of Qualified Military Service provided by the Plan as if the individual had resumed Covered Employment and then 

terminated employment on account of death. 

Section 3.14 - Partial Pensions 

(a) Purpose. Partial Pensions are provided under the Plan for Participants who would otherwise 

lack sufficient service credit to be eligible for any pension because their years of employment were divided 

between or among different pension plans or, if eligible, whose pensions would be less than the full amount 

because of such division of employment. 

The Plan is a party to Exhibit A (partial pensions) and Exhibit B (money-follows-the-man) of the United 

Brotherhood of Carpenters and Joiners of America International Reciprocal Agreement for Carpenters Pension Funds 

(the "Carpenters Reciprocal Agreement"). A copy of the Carpenters Reciprocal Agreement is attached as Appendix II 

and the provisions ofExhibit A are incorporated herein by reference. The terms ofthis section 3 .14 shall be construed in 

a manner consistent with the terms ofthe Carpenters Reciprocal Agreement. 

(b) Related Plans. For purposes ofthis section 3 .14, the Board of Trustees will recognize one or 

more other pension plans that have become parties to the Carpenters Reciprocal Agreement or any other partial 

pension agreement to which the Plan is a party, such pension plan or plans hereinafter referred to as the 

"Related Plan" or "Related Plans," as the case may be. 

(c) Recognition of Service Credits. Service credits accumulated and maintained by a Participant 

under a Related Plan shall be recognized under the Plan as Related Plan Service Credits. The Board of Trustees 

shall compute Related Plan Service Credits on the basis on which that credit has been earned and credited under 

the Related Plan and certified by the Related Plan to the Plan. 

(d) Combined Service Credit. The total of a Participant's service credits under the Plan and 

Related Plan Service Credit together comprise the Participant's Combined Service Credit. No more than one 

year of Combined Service Credit shall be counted for any 12-consecutive calendar months. 

If during a calendar year an Employee has worked under at least two Plans that are parties to the Carpenters 

Reciprocal Agreement or any other partial pension agreement to which the Plan is a party and accumulated fractional 

SLK_TOL: #2505331 v3 30 

SWORCCPP2018-000274
years of service credit that together add up to more than one year of service credit for that calendar year, the Combined 

Service Credit shall be limited to one year. The Combined Service Credit will first be counted under the plan that 

provides the highest benefit accrual rate. The other plan(s) shall count as Combined Service Credit the necessary 

fractional year(s), in a declining benefit accrual rate order, that will bring the total to one year of Combined Service 

Credit. 

(e) Eligibility for Benefits. A Participant shall be eligible for a Partial Pension from the Plan if 

he or she satisfies all ofthe following requirements: 

(1) He or she would be eligible for any type of pension under the Plan (other than a 

Partial Pension) ifhis or her Combined Service Credit were treated as service credit under the Plan. 

(2) In addition to any other requirements necessary to be eligible under 

subparagraph (1 ), he or she has, under each Related Plan, at least one year of service credit based on 

employment since January 1, 1955, for which employer contributions have been made. 

(3) In the case of a Participant applying for a pension based on disability, he or she 

meets the definition of disability under each Related Plan that will be paying a Partial Pension. 

(4) In the case of a Participant applying for a pension based on age, he or she meets the 

minimum age requirement in each Related Plan that will be paying a Partial Pension. 

(5) At least two Related Plans will actually be paying a Pro Rata Pension to the 

Participant. 

(f) Breaks in Service. In applying the rules of the Plan with respect to cancellation of service 

credit, any period in which the Participant has earned Related Service Credit shall not be counted in 

determining whether there has been a Break in Service. 

(g) Election of Pensions. If a Participant is eligible for more than one type of pension or 

optional form of benefit under the Plan and the Related Plans, he or she shall be entitled to elect the type and 

form ofpension from each plan. 

(h) Partial Pension Amount. The amount ofthe Partial Pension payable by the Plan shall be the 

Accrued Benefit he or she earned under the Plan. 

(i) Payment of Partial Pension. The payment of a Partial Pension shall be subject to all of the 

conditions contained in the Plan applicable to other types of pensions including, but not limited to, retirement, 

suspension ofbenefits and timely application. 

Section 3.15 - Benefit Adjustments 

The Accrued Benefit that an individual who (1) had not retired by December 31, 1999, with an Early, Normal 

or Disability Retirement Benefit, and (2) worked in Covered Employment in 1999 had earned as of December 31, 1999, 

shall be increased by 3 percent, effective as of such date. 

Each individual who retired with an Early, Normal or Disability Retirement Benefit by December 31, 1999 

(and each Beneficiary of such deceased person who is otherwise entitled to a monthly survivorship benefit), shall receive 

one extra benefit payment equal to $700. 

The Accrued Benefit that an individual who (1) had not retired by December 31, 2000, with an Early, 

Normal or Disability Retirement Benefit and (2) worked at least 100 hours in Covered Employment in 2000, had 

earned as of December 31, 2000, shall be increased by 3 percent, effective as of such date. 

SLK_TOL: #250533lv3 31 

SWORCCPP2018-000275
Each individual who retired with an Early, Normal or Disability Retirement Benefit by December 31, 2000 

(and each Beneficiary of such deceased person who is otherwise entitled to a monthly survivorship benefit), shall 

receive one extra benefit payment equal to $750. 

Section 3.16 - In-Service Distribution for Accruals after Normal Retirement Age 

In the event that a Participant has reached Normal Retirement Age and continues to accrue benefits under the 

Plan and such accruals caused the Participant to exceed the Maximum Permissible Benefit under Section 415 of the 

Internal Revenue Code and Section 3.12 of the Plan, the Participant shall be entitled to receive an in-service distribution 

ofthe benefits in excess ofthe applicable limits in accordance with the Plan's distribution provisions. 

Section 3.17 - Modification to Restrictions on Maximum Amount of Benefit 

For Purposes of Section 3.12 of the Plan, effective for any calculations for Limitation Years beginning on or 

after January 1, 2008, any reference to Revenue Ruling 2001-62 shall be replaced by Internal Revenue Code 417(e)(3). 

ARTICLE4 

APP LI CA TIO NS, BENEFIT PAYMENTS, RETIREMENT AND BENEFIT SUSPENSIONS 

Section 4.1 - Applications 

Application for a benefit must be filed in writing with the Board of Trustees on a form approved by the 

Board of Trustees. 

A pension shall not be payable for any month before the month an application has been filed, except as 

otherwise provided herein. 

Section 4.2 - Information and Proof 

Each applicant shall furnish all information or proof reasonably required by the Board of Trustees to 

determine benefit rights. If the applicant knowingly makes a false statement that is material to the application or 

furnishes fraudulent information that is material to the claim, benefits may be denied, suspended or discontinued. 

The Board of Trustees shall have the right to recover any benefits paid in reliance on any false statement, 

information or proof submitted by an applicant (including withholding of material facts) plus interest and costs, 

without limitation ofrecovery through offset ofbenefit payments as permitted by this article. 

Section 4.3 - Action of Board of Trustees 

The Board of Trustees has discretionary authority to determine eligibility for benefits and to use its 

discretionary authority to interpret the Plan. Benefits under the Plan will be paid only if the Board of Trustees 

decides, in its discretion, that the applicant for the benefits is entitled to them. If any decision of the Board of 

Trustees ( or of those acting on behalf of the Board of Trustees) is appealed or questioned in any judicial proceeding, 

it is the intention of the Board of Trustees that such decision is to be upheld unless it is judicially determined to be 

arbitrary and capricious. 

The Board of Trustees shall process a claim for benefits as quickly as is administratively feasible, subject to 

the receipt of adequate information and proof necessary to establish the applicant's benefit rights. 

Section 4.4 - Right of Appeal 

An applicant whose application for benefits has been denied in whole or in part shall be provided with 

adequate notice in writing setting forth the specific reasons for such denial and shall have the right to appeal the 

decision in accordance with the claims and review procedure in the summary plan description. 

SLK_TOL: #2505331v3 32 

SWORCCPP2018-000276
Section 4.5 - Benefit Payments Generally 

(a) A Participant who is eligible to receive benefits and who makes application in accordance 

with the rules of the Plan shall be entitled to receive monthly benefits for life, except as otherwise provided 

herein. 

(b) Benefits shall be payable commencing with the month following the month in which the 

applicant has fulfilled all of the conditions for entitlement to benefits, including the requirement for the 

filing of an application with the Board of Trustees. The first day of such first month shall be the Annuity 

Starting Date and the effective date of the benefit. A Participant may, however, elect in writing filed with 

the Board of Trustees to receive benefits first payable for a later month, provided that no such election may 

postpone the commencement ofbenefits beyond the required beginning date, as defined in section 4.6(o). 

(c) Subject to the foregoing, payment of benefits to a Participant shall begin no later than 60 

days after the close of the Plan Year in which occurs the latest of: 

(i) the date such person attains the Normal Retirement Age, 

(ii) the fifth anniversary of the first day ofthe Plan Year in which such person began 

participation in the Plan (with participation prior to a Forfeiture of Service disregarded for 

purposes of determining the participation commencement date), or 

(iii) the date such person terminates service with all Employers. 

Notwithstanding the foregoing, the failure of a Participant (and, if applicable, the spouse) to consent to a 

distribution while a benefit is immediately distributable, within the meaning of section 5 .6, shall be deemed 

to be an election to defer commencement of benefit payments sufficient to satisfy the foregoing, although 

any such deemed election shall be subject to section 4.6. 

(d) If the amount of the payment required to commence on the date determined under this 

section 4.5 cannot be determined by such date, or if it is not possible to make such payment on such date 

because the Board of Trustees has been unable to locate the Participant after making reasonable efforts to 

do so, a payment retroactive to such date may be made no later than 60 days after the earliest date on which 

the amount of such payment can be ascertained or on the date on which such person is located, as the case 

maybe. 

(e) Payment ofbenefits shall include retroactive payment for any months for which the benefit is 

due and payable in accordance with paragraph (d) of this section, or in other cases where the Board of Trustees 

determines that retroactive payment is justified by extenuating circumstances (such as a delay in reviewing or 

approving the Participant's application for benefits). However, any such retroactive payment shall satisfy the 

following requirements: 

(i) The Participant shall receive a lump-sum make-up payment reflecting all months 

for which the Board of Trustees determine benefit payments were due but not made (with, for makeup payments to be made after December 31, 2001, an appropriate adjustment for interest from the date 

the missed payment would have been made, taking into account reasonable time for processing the 

payment, to the date the retroactive lump-sum payment is made). 

(ii) The Board of Trustees has provided the Participant with the written explanation of 

the Joint and Survivor Annuity described in section 5.6 no more than 180 days (90 days for 

explanations given prior to January 1, 2007) prior to the date the retroactive payment is made to the 

Participant. 

(iii) The retroactive payment is made either (a) at least 30 days after this written 

explanation is provided, or (b) at least seven days after the notice is provided if the Participant has 

affirmatively consented in writing to an immediate distribution. 

SLK_TOL: #2505331v3 33 

SWORCCPP2018-000277
(iv) The Participant's spouse (if any) on the date the retroactive payment is made has 

consented to the distribution to the extent required by section 5.6. 

Section 4.6 - Distribution Requirements 

Subject to the provisions of the Plan relating to the payment of the Joint and Survivor Annuity, the 

requirements of this section shall apply to any distribution of a Participant's or Former Participant's interest and will 

take precedence over any inconsistent provisions ofthe Plan. 

Time and Manner of Distribution 

(a) Required Beginning Date. The Participant's entire interest will be distributed, or begin to 

be distributed, to the Participant no later than the Participant's required beginning date. 

(b) Death of Participant Before Distributions Begin. If the Participant dies before 

distributions begin, the Participant's entire interest will be distributed, or begin to be distributed, no later 

than as follows: 

(1) If the Participant's surv1vmg spouse is the Participant's sole designated 

Beneficiary, distributions to the surviving spouse will begin by December 31 of the calendar year 

immediately following the calendar year in which the Participant died, or by December 31 of the 

calendar year in which the Participant would have attained age 701⁄2, iflater. 

(2) If the Participant's surviving spouse is not the Participant's sole designated 

Beneficiary, distributions to the designated Beneficiary will begin by December 31 of the calendar 

year immediately following the calendar year in which the Participant died. 

(3) Ifthere is no designated Beneficiary as of September 30 of the year following 

the year of the Participant's death, the Participant's entire interest will be distributed by 

December 31 ofthe calendar year containing the fifth anniversary ofthe Participant's death. 

(4) If the Participant's surviving spouse is the Participant's sole designated 

Beneficiary and the surviving spouse dies after the Participant but before distributions to the 

surviving spouse begin, this section 4.6(b), other than section 4.6(b )(1 ), will apply as if the 

surviving spouse were the Participant. For purposes of this section 4.6(b) and section 4.6(i)G) and 

(k), distributions are considered to begin on the Participant's required beginning date [(or, if 

section 4.6(b )( 4) applies, the date distributions are required to begin to the surviving spouse under 

section 4.6(b)(l)]. If annuity payments irrevocably commence to the Participant before the 

Participant's required beginning date [(or to the Participant's surviving spouse before the date 

distributions are required to begin to the surviving spouse under section 4.6(b)(l)], the date 

distributions are considered to begin is the date distributions actually commence. 

(c) Form of Distribution. Unless the Participant's interest is distributed in the form of an 

annuity purchased from an insurance company or in a single sum on or before the required beginning date, 

as of the first distribution calendar year distributions will be made in accordance with sections 4.6(d) 

through (k) of this article. Ifthe Participant's interest is distributed in the form of an annuity purchased from 

an insurance company, distributions thereunder will be made in accordance with the requirements of 

section 40l(a)(9) of the Code and the Treasury regulations. Any part of the Participant's interest that is in 

the form of an individual account described in section 4 l 4(k) of the Code will be distributed in a manner 

satisfying the requirements of section 40l(a)(9) of the Code and the Treasury regulations that apply to 

individual accounts. 

SLK_TOL: #250533lv3 34 

SWORCCPP2018-000278
Determination of Amount to be Distributed Each Year 

(d) General Annuity Requirements. If the Participant's interest is paid in the form of annuity 

distributions under the plan, payments under the annuity will satisfy the following requirements: 

(1) the annuity distributions will be paid in periodic payments made at intervals not 

longer than one year; 

(2) the distribution period will be over a life ( or lives) or over a period certain not 

longer than the period described in sections 4.6(g) through (k); 

(3) once payments have begun over a period certain, the period certain will not be 

changed even if the period certain is shorter than the maximum permitted; 

(4) payments will either be nonincreasing or increase only as follows: 

(i) by an annual percentage increase that does not exceed the annual 

percentage increase in a cost-of-living index that is based on prices of all items and 

issued by the Bureau ofLabor Statistics; 

(ii) to the extent of the reduction in the amount of the Participant's 

payments to provide for a survivor benefit upon death, but only if the Beneficiary whose 

life was being used to determine the distribution period described in section 4.6(g), (h) 

dies or is no longer the Participant's beneficiary pursuant to a Qualified Domestic 

Relations Order within the meaning of section 4 l 4(p ); 

(iii) to provide cash refunds of employee contributions upon the 

Participant's death; or 

(iv) to pay increased benefits that result from a plan amendment. 

(e) Amount Required to be Distributed by Required Beginning Date. The amount that must 

be distributed on or before the Participant's required beginning date [( or, if the Participant dies before 

distributions begin, the date distributions are required to begin under section 4.6(b )(1) or (2)] is the 

payment that is required for one payment interval. The second payment need not be made until the end of 

the next payment interval even if that payment interval ends in the next calendar year. Payment intervals 

are the periods for which payments are received, e.g., bi-monthly, monthly, semi-annually, or annually. All 

of the Participant's benefit accruals as of the last day of the first distribution calendar year will be included 

in the calculation of the amount of the annuity payments for payment intervals ending on or after the 

Participant's required beginning date. 

(t) Additional Accruals After First Distribution Calendar Year. Any additional benefits 

accruing to the Participant in a calendar year after the first distribution calendar year will be distributed 

beginning with the first payment interval ending in the calendar year immediately following the calendar 

year in which such amount accrues. 

Requirements For Annuity Distributions That Commence During Participant's Lifetime 

(g) Joint Life Annuities Where the Beneficiary Is Not the Participant's Spouse. If the 

Participant's interest is being distributed in the form of a joint and survivor annuity for the joint lives of the 

Participant and a nonspouse Beneficiary, annuity payments to be made on or after the Participant's required 

beginning date to the designated Beneficiary after the Participant's death must not at any time exceed the 

applicable percentage of the annuity payment for such period that would have been payable to the 

Participant using the table set forth in Q&A-2 of section 1.401 ( a)(9)-6T of the Treasury regulations. If the 

form of distribution combines a joint and survivor annuity for the joint lives of the Participant and a 

SLK_TOL: #2505331v3 35 

SWORCCPP2018-000279
nonspouse Beneficiary and a period certain annuity, the requirement in the preceding sentence will apply to 

annuity payments to be made to the designated Beneficiary after the expiration ofthe period certain. 

(h) Period Certain Annuities. Unless the Participant's spouse is the sole designated 

Beneficiary and the form of distribution is a period certain and no life annuity, the period certain for an 

annuity distribution commencing during the Participant's lifetime may not exceed the applicable 

distribution period for the Participant under the Uniform Lifetime Table set forth in section 1.401 ( a)(9)-9 of 

the Treasury regulations for the calendar year that contains the annuity starting date. Ifthe annuity starting 

date precedes the year in which the Participant reaches age 70, the applicable distribution period for the 

Participant is the distribution period for age 70 under the Uniform Lifetime Table set forth in 

section l.401(a)(9)-9 of the Treasury regulations plus the excess of70 over the age of the Participant as of 

the Participant's birthday in the year that contains the annuity starting date. Ifthe Participant's spouse is the 

Participant's sole designated Beneficiary and the form of distribution is a period certain and no life annuity, 

the period certain may not exceed the longer of the Participant's applicable distribution period, as 

determined under this section 4.6(h), or the joint life and last survivor expectancy of the Participant and the 

Participant's spouse as determined under the Joint and Last Survivor Table set forth in section l.40l(a)(9)-

9 of the Treasury regulations, using the Participant's and spouse's attained ages as of the Participant's and 

spouse's birthdays in the calendar year that contains the annuity starting date. 

Requirements For Minimum Distributions Where Participant Dies Before Date Distributions Begin 

(i) Participant Survived by Designated Beneficiary. If the Participant dies before the date 

distribution of his or her interest begins and there is a designated Beneficiary, the Participant's entire 

interest will be distributed, beginning no later than the time described in section 4.6(b )(1) or (2), over the 

life ofthe designated Beneficiary or over a period certain not exceeding: 

(1) unless the annuity starting date is before the first distribution calendar year, the 

life expectancy of the designated beneficiary determined using the beneficiary's age as of the 

beneficiary's birthday in the calendar year immediately following the calendar year of the 

Participant's death; or 

(2) if the annuity starting date is before the first distribution calendar year, the life 

expectancy of the designated beneficiary determined using the beneficiary's age as of the 

beneficiary's birthday in the calendar year that contains the annuity starting date. 

G) No Designated Beneficiary. Ifthe Participant dies before the date distributions begin and 

there is no designated Beneficiary as of September 30 of the year following the year of the Participant's 

death, distribution of the Participant's entire interest will be completed by December 31 of the calendar year 

containing the fifth anniversary of the Participant's death. 

(k) Death of Surviving Spouse Before Distributions to Surviving Spouse Begin. If the 

Participant dies before the date distribution of his or her interest begins, the Participant's surviving spouse is 

the Participant's sole designated Beneficiary, and the surviving spouse dies before distributions to the 

surviving spouse begin, sections 4.6(i), G) and (k) will apply as if the surviving spouse were the Participant, 

except that the time by which distributions must begin will be determined without regard to 

section 4.6(b )(1 ). 

Definitions 

(I) Designated Beneficiary. The individual who is designated as the Beneficiary under 

section 1.5 of the plan and is the designated Beneficiary under section 401 ( a)(9) of the Internal Revenue 

Code and section l.40l(a)(9)-1, Q&A-4, ofthe Treasury regulations. 

(m) Distribution Calendar Year. A calendar year for which a mm1mum distribution is 

required. For distributions beginning before the Participant's death, the first distribution calendar year is the 

calendar year immediately preceding the calendar year that contains the Participant's required beginning 

SLK_TOL: #250533lv3 36 

SWORCCPP2018-000280
date. For distributions beginning after the Participant's death, the first distribution calendar year is the 

calendar year in which distributions are required to begin pursuant to section 4.6(b ). 

(n) Life Expectancy. Life expectancy as computed by use of the Single Life Table in 

section l.401(a)(9)-9 of the Treasury regulations. 

(o) Required Beginning Date. 

(1) General Rule. Except as specified otherwise in subparagraphs (2), (3) or (4) 

below, the required beginning date of a Participant or Former Participant is the first day of April of 

the calendar year following the later of the calendar year in which the Participant or Former 

Participant attains age 701⁄2 or the calendar year in which the Former Participant retires. 

(2) Prior to January 1, 2000. The required beginning date of any Participant or 

Former Participant who attained age 701⁄2 before January 1, 2000, shall be the first day of April ofthe 

calendar year following the calendar year in which the attainment of age 701⁄2 occurred. 

(3) Transitional Rule. Any Participant or Former Participant who attains age 70-1/2 

between January 1, 2000 and December 31, 2000 may elect to have his or her required beginning 

date determined under either the General Rule in subparagraph (1) or the old rule in 

subparagraph (2). 

(4) Treatment of 5 Percent Owner. The required beginning date of a Participant or 

Former Participant who is a 5 percent owner during any year beginning after December 31, 1979, is 

the first day ofApril following the later of: 

(A) the calendar year in which the Participant or Former Participant attains 

age 701⁄2, or 

(B) the earlier of the calendar year with or within which ends the Plan Year 

in which the Participant or Former Participant becomes a 5 percent owner, or the calendar 

year in which the Participant or Former Participant retires. 

(5) 5 Percent Owner. A Participant or Former Participant is treated as a 5 percent 

owner for purposes of this section if such Participant or Former Participant is a 5 percent owner as 

defined in section 4 l 6(i) of the Code ( determined in accordance with section 416 but without regard 

to whether the Plan is top-heavy) at any time during the Plan Year ending with or within the calendar 

year in which such owner attains age 661⁄2 or any subsequent Plan Year. 

(6) Continuation of Payments. Once distributions have begun to a 5 percent owner 

under this section, they must continue to be distributed, even if the Participant ceases to be a 

5 percent owner in a subsequent year. 

Section 4. 7 - Suspension of Benefits 

(a) Definition of Suspension. "Suspension of Benefits" means nonentitlement to benefits for 

the month, regardless of whether payment of such benefits has commenced. If benefits were paid for a 

month for which they should have been suspended, the overpayment shall be recoverable through 

deductions from future pension payments, pursuant to subparagraph (h). 

For purposes of this section 4.7, 

(i) The term "industry covered by the Plan" means the building and construction 

industry and any other industry in which employees covered by the Plan were employed when the 

individual's monthly benefits began or, but for suspension under this section, would have begun. 

SLK_TOL: #250533lv3 37 

SWORCCPP2018-000281
(ii) The geographic area covered by the Plan is that defined in the current Collective 

Bargaining Agreement as well as any other area covered by the Plan when the individual's 

monthly benefits began or, but for suspension under this section, would have begun. 

(iii) If an individual reenters Covered Employment to an extent sufficient to cause a 

suspension of benefits and pension payments are subsequently resumed, the industry and area 

covered by the Plan "when the individual's monthly benefits began" shall be the industry and area 

covered by the Plan when the monthly benefit resumed. 

(b) Suspension of Benefits After Normal Retirement Age. If an individual completes 

480 Hours of Service in Disqualifying Employment during a Plan Year, his or her Normal Retirement 

Benefit shall be suspended for each remaining month in that Plan Year during which he or she completes at 

least 40 Hours of Service in Disqualifying Employment on or after his or her Normal Retirement Date. 

(c) Suspension of Benefits (Other than Disability Retirement Benefits) Before Normal 

Retirement Age. Subject to the remaining provisions of this subparagraph (c), if an individual who is 

receiving a monthly benefit ( other than a Disability Retirement Benefit) from the Plan completes 480 Hours 

of Service in Disqualifying Employment during a Plan Year, such benefit shall be suspended for each 

remaining month in that Plan Year during which he or she completes at least one Hour of Service in 

Disqualifying Employment prior to his or her Normal Retirement Date. 

Notwithstanding the provisions of the prior paragraph of this subparagraph, effective for benefits 

accrued after June 30, 2005, if an individual who is receiving a monthly benefit (other than a Disability 

Retirement Benefit) from the Plan works in the industry covered by the Plan (regardless of where such 

work occurs or the number of hours worked in such industry), such benefits shall be suspended until such 

person's Normal Retirement Date. 

Notwithstanding the previous paragraphs of this subparagraph, if an individual who is receiving a 

monthly benefit (other than a Disability Retirement Benefit) that commenced on or after April 30, 2010 

from the Plan works in the industry covered by the Plan (regardless of where such work occurs or the 

number of hours worked in such industry), such benefits shall be suspended until such person's Normal 

Retirement Date. 

(d) Suspension of Disability Retirement Benefit. If an individual who is receiving a monthly 

Total and Permanent Disability Retirement Benefit pursuant to section 3.4 completes more than 40 hours of 

work during a month in gainful employment or self-employment, such Benefit shall be suspended for that 

month and for each subsequent month until the individual proves to the satisfaction of the Board of 

Trustees that he or she did not complete more than 40 hours of work in gainful employment or 

self-employment during a particular month. In addition, if the individual receiving the monthly Total and 

Permanent Disability Retirement Benefit does not comply with the notice requirement of 

subparagraph (t)(ii) hereof, such Benefit shall be suspended for each month in which such individual 

completes more than 40 hours of work in gainful employment or self-employment and for 12 additional 

payments and shall be subject to recoupment pursuant to subparagraph (h) hereof. 

If an individual who is receiving a monthly Trade Disability Benefit pursuant to section 3 .4 

completes at least one Hour of Service in Disqualifying Employment during a month, such Benefit shall be 

suspended for that month and for each subsequent month until the individual proves to the satisfaction of 

the Board of Trustees that he did not complete more than one Hour of Service in Disqualifying 

Employment during a particular month. In addition, if the individual receiving a monthly Trade Disability 

Benefit does not comply with the notice requirement of subparagraph (t)(ii) hereof, such Benefit shall be 

suspended for each month in which such individual completed at least one Hour of Service in Disqualifying 

Employment and for 12 additional payments and shall be subject to recoupment pursuant to 

subparagraph (h) hereof. 

For purposes of this subparagraph ( d), "Disqualifying Employment" shall have the same meaning 

as in subparagraph ( e ). 

SLK_TOL: #2505331 v3 38 

SWORCCPP2018-000282
(e) Disqualifying Employment. For purposes of this section, "Disqualifying Employment" 

means employment or self-employment in an industry covered by the Plan when such monthly benefits 

began, in the geographic area covered individual by the Plan when such monthly benefits began, and in 

any occupation in which the individual worked under the Plan at any time or any occupation covered by the 

Plan at the time such monthly benefits began. However, if an individual worked in Covered Employment 

only in a skilled trade or craft, employment or self-employment shall be disqualifying only if it is in work 

that involves the skill or skills ofthat trade or craft directly. 

(i) The term "industry covered by the Plan" means the building and construction 

industry and any other industry in which employees covered by the Plan were employed when the 

individual's monthly benefits began or, but for suspension under this section, would have begun. 

(ii) The geographic area covered by the Plan is that defined in the current Collective 

Bargaining Agreement as well as any other area covered by the Plan when the individual's 

monthly benefits began or, but for suspension under this section, would have begun. 

(iii) If an individual reenters Covered Employment to an extent sufficient to cause a 

suspension of benefits and pension payments are subsequently resumed, the industry and area 

covered by the Plan "when the individual's monthly benefits began" shall be the industry and area 

covered by the Plan when the monthly benefit resumed. 

(f) Notices. 

(i) Upon commencement of monthly benefit payments, the Board of Trustees shall 

notify the individual of the Plan rules governing suspension of benefits. If benefits have been 

suspended and payment resumed, new notification shall, upon resumption, be given if there has 

been any material change in the suspension rules or the identity of the industries or area covered 

by the Plan. 

(ii) An individual ( other than an individual receiving the Total and Permanent 

Disability Retirement Benefit or the Trade Disability Benefit) must notify the Board of Trustees 

in writing within 15 days after the month in which he or she started any work of a type that is or 

may be disqualifying under the provisions of the Plan, regardless of the number of hours of such 

work during that month. If such individual has worked in Disqualifying Employment in any 

month and has failed to give timely notice to the Board of Trustees of such employment, the 

Board of Trustees shall presume that he or she completed the number of Hours of Service 

necessary to effect a suspension of benefits during such month and any subsequent month before 

such individual gives notice that he or she has ceased such Disqualifying Employment. Such 

individual shall have the right to rebut such presumption by establishing that the work was not in 

fact an appropriate basis for suspension of benefits. In addition, if such individual has worked in 

Disqualifying Employment for any number of hours at a building or construction site and has 

failed to give timely notice to the Board of Trustees of such employment or self-employment, the 

Board of Trustees shall presume that he or she has engaged in such work for as long as the 

contractor has been and remains actively engaged at that site. Such person shall have the right to 

rebut such presumption by establishing that the work was not in fact an appropriate basis for 

suspension ofbenefits. 

(iii) An individual receiving the Total and Permanent Disability Retirement Benefit 

shall notify the Board of Trustees in writing within 15 days of engaging in any gainful 

employment or self-employment, and an individual receiving the Trade Disability Benefit must 

notify the Board of Trustees within 15 days of completing at least one Hour of Service in 

Disqualifying Employment. 

(iv) An individual whose monthly benefit has been suspended must notify the Board 

of Trustees in writing when Disqualifying Employment has ended and, as a condition for receiving 

SLK_TOL: #250533lv3 39 

SWORCCPP2018-000283
benefits, must file the appropriate application or resumption form. The Board of Trustees shall 

have the right to withhold benefit payments until such form has been filed. 

(v) An individual may ask the Board of Trustees whether a particular type of 

employment is Disqualifying Employment. The Board of Trustees shall provide the Participant 

with its determination. 

(vi) The Board of Trustees shall inform an individual of any suspension of benefits 

by notice given by personal delivery or first class mail during the first calendar month in which 

benefits are withheld. Such notice shall include a description of the specific reasons for the 

suspension, a general description of the Plan's suspension provisions, a copy of such provisions, 

reference to the applicable regulations of the Department of Labor and a statement of the 

procedure for securing a review of the suspension. In addition, the notice shall describe the 

procedure for the individual to notify the Plan when Disqualifying Employment ends, a 

description of the procedure for filing a request for the commencement ( or recommencement) of 

benefits and a copy of the appropriate form. Finally, the suspension notice shall explain the offset 

procedure and identify the amount expected to be recovered as well as the periods of employment 

to which they relate. Notwithstanding the foregoing provisions of this subparagraph, however, if 

the Plan's summary plan description contains information that is substantially the same as 

information described in this subparagraph, the suspension notification may refer to the relevant 

pages of the summary plan description as to a particular item, as long as the individual is informed 

how to obtain a copy of the summary p Ian description ( or relevant pages thereof) and provided 

requests for referenced information are honored within a reasonable period oftime, not to exceed 

30 days. 

The Board of Trustees shall inform all retirees at least once every 12 months of the reemployment 

notification requirements and the presumptions in this subparagraph. 

(g) Review. An individual shall be entitled to a review of a determination suspending 

benefits in accordance with the claims and review procedure in the summary plan description. The same 

right shall apply to a determination that contemplated employment will be Disqualifying Employment. 

(h) Resumption of Benefit Payments. 

(i) Benefits suspended pursuant to subparagraph (b) shall resume for months after 

the most recent month for which benefits were suspended, with payments beginning no later than 

the first day of the third month after the last calendar month for which the benefit was suspended, 

provided the Participant has complied with the applicable notification and filing requirements of 

subparagraph (f). 

(ii) Benefits suspended pursuant to the first paragraph of subparagraph (c) shall 

resume with the payment due for the month following the month in which the Participant last 

worked in Disqualifying Employment or with the payment due for the month following the 

Normal Retirement Age [unless benefits are suspended pursuant to subparagraph (b)], whichever 

is sooner. Benefits suspended pursuant to the second paragraph of subparagraph (c) shall resume 

with the payment due for the month following the Normal Retirement Age [unless benefits are 

suspended pursuant to subparagraph(b )]. 

(iii) Total and Permanent Disability Retirement Benefits suspended pursuant to 

subparagraph (d) shall resume with the month in which the individual did not complete more than 

forty hours of work in gainful employment or self-employment, provided such person has 

complied with the applicable notification and filing requirements of subparagraph (f). However, 

to the extent 12 additional payments are to be withheld pursuant to subparagraph (d) and/or to the 

extent payments were made for any month during which the individual completed more than forty 

hours of work in gainful employment or self-employment, the period of re-commencement shall 

be delayed until such payments have been recouped, provided, however, that after such person's 

SLK_TOL: #2505331v3 40 

SWORCCPP2018-000284
Normal Retirement Date, his or her Normal Retirement Benefit shall not be reduced by more than 

25 percent after the first three payments following such Normal Retirement Date. 

Trade Disability Benefits suspended pursuant to subparagraph (d) shall resume with the 

month in which the individual did not complete more than one Hour of Service in Disqualifying 

Employment, provided such person has complied with the applicable notification and filing 

requirements of subparagraph (f). To the extent 12 additional payments are to be withheld 

pursuant to subparagraph (d) and/or the extent payments were made for any month during which 

the individual completed at least one Hour of Service in Disqualifying Employment, the period of 

re-commencement shall be delayed until such payments have been recouped, provided, however, 

that after such person's Normal Retirement Date, his or her Normal Retirement Benefit shall not 

be reduced by more than 25 percent after the first three payments following such Normal 

Retirement Date. 

If a Participant dies before recoupment of overpayments has been completed, deductions 

shall be made from the benefits payable to the Beneficiary, subject to the 25 percent limitation on 

the rate of deduction. 

(iv) Overpayments attributable to payments made for any month or months for 

which an individual engaged in Disqualifying Employment after the Normal Retirement Age shall 

be deducted from benefit payments otherwise paid or payable subsequent to the period of 

suspension. Such deduction shall not exceed 25 percent of the benefit amount (before deduction), 

except for the first benefit payment made upon resumption after a suspension. If such individual 

dies before recoupment of overpayments has been completed, deductions shall be made from the 

benefits payable to the Beneficiary, subject to the 25 percent limitation on the rate of deduction. 

(v) Overpayments attributable to payments made for any month or months for 

which an individual engaged in Disqualifying Employment before the Normal Retirement Age 

shall be deducted from benefit payments otherwise paid or payable subsequent to the period of 

suspension, provided, however, any such deduction after the Normal Retirement Age shall not 

exceed 25 percent of the benefit amount (before deduction), except for the first benefit payment 

made upon resumption after suspension, pursuant to subparagraph (i) of this subparagraph. If such 

individual dies before recoupment of overpayments has been completed, deductions shall be made 

from the benefits payable to the Beneficiary, subject to the 25 percent limitation on the rate of 

deduction. 

(i) Trustee Action Regarding Suspension of Benefits. The Board of Trustees, by action duly 

taken and notice duly given, may suspend and reinstate the operation of all or any portion of this section. 

Section 4.8 - Benefit Payments Following Suspension 

(a) Determination of Amount of Benefit Payment. The monthly amount of benefits 

following a suspension shall be determined under subparagraph (b) of this section and shall be adjusted for 

any optional form ofbenefit as well as for any additional accruals earned during the period of suspension in 

accordance with subparagraph (c) and subparagraph (e) hereof. Nothing in this section shall be deemed to 

extend any benefit increase or adjustment effective after the initial retirement to any benefit upon 

resumption of payment, except to the extent that it may be expressly provided by other provisions of the 

Plan. 

(b) Amount of Resumed Benefit. When a Participant whose monthly benefit has been 

suspended pursuant to section 4.7 has filed the appropriate application or resumption form pursuant to section 4.7(e)(iii), and if the Board of Trustees determines that such person's benefits are no longer 

suspendible, the amount of the monthly benefit upon its resumption shall be equal to the sum of the 

following: 

(i) the Participant's Accrued Benefit at the time his or her benefit was suspended. 

SLK_TOL: #250533lv3 41 

SWORCCPP2018-000285
(ii) Any additional benefit accruals the Participant earned while benefits were 

suspended. 

Such person shall be entitled to a new election as to the form of benefit, but only with respect to 

such benefit accruals earned during the period of suspension. 

(c) Adjustments. The amount determined under subparagraph (b)(ii) shall be adjusted (using 

the factors in Appendix I) for the Joint and Survivor Annuity or for any other form of benefit that is 

payable. 

(d) Effect Upon Form of Benefit. A Joint and Survivor Annuity in effect immediately prior 

to a suspension of benefits or any other form of benefit that provides payment to a survivor following the 

death of the Participant in effect immediately prior to a suspension of benefits shall remain effective if 

death occurs while benefits are suspended. 

Section 4.9 - Direct Rollovers 

(a) This section applies to distributions made on or after January 1, 1993. Notwithstanding 

any provision of the Plan to the contrary that would otherwise limit a distributee's election under this 

section, a distributee may elect, at the time and in the manner prescribed by the Board of Trustees, to have 

any portion of an eligible rollover distribution paid directly to an eligible retirement plan specified by the 

distributee in a direct rollover. 

(b) Definitions. 

(i) Eligible Rollover Distribution: An eligible rollover distribution is any 

distribution of all or any portion of the balance to the credit of the distributee, except that an 

eligible rollover distribution does not include: any distribution that is one of a series of 

substantially equal periodic payments (not less frequently than annually) made for the life ( or life 

expectancy) of the distributee or the joint lives ( or joint life expectancies) of the distributee and the 

distributee's designated Beneficiary, or for a specified period often years or more; any distribution 

to the extent such distribution is required under section 401 ( a)(9) of the Code; the portion of any 

distribution that is not includible in gross income (determined without regard to the exclusion for 

net unrealized appreciation with respect to employer securities); and any hardship withdrawal of 

elective deferrals [within the meaning of section 40l(k)(2)(B)(i)(IV) ofthe Code]. 

(ii) Eligible Retirement Plan: An eligible retirement plan is an individual retirement 

account described in section 408(a) of the Code, an individual retirement annuity described in 

section 408(b) of the Code, an annuity plan described in section 403(a) of the Code, an annuity 

contract described in section 403(b) ofthe Code, an eligible plan under section 457(b) of the Code 

which is maintained by a state or political subdivision of a state and which agrees to separately 

account for amounts transferred in such plan from this Plan, or a qualified trust described in section 401(a) of the Code, that accepts the distributee's eligible rollover distribution. However, in the 

case of an eligible rollover distribution to the surviving spouse, an eligible retirement plan is an 

individual retirement account or individual retirement annuity. 

(iii) Distributee: A distributee includes an employee or former employee. In 

addition, the employee's or former employee's surviving spouse and the employee's or former 

employee's spouse or former spouse who is the alternate payee under a Qualified Domestic 

Relations Order, as defined in section 414(p) of the Code, are distributees with regard to the 

interest of the spouse or former spouse. 

(iv) Direct Rollover: A direct rollover is a payment by the Plan to the eligible 

retirement plan specified by the distributee. 

SLK_TOL: #250533lv3 42 

SWORCCPP2018-000286
(c) If a distribution is one to which section 401 ( a )(11) and section 417 of the Code do not 

apply, such distribution may commence less than 30 days after the notice required under 

section l.4 l l(a)-11( c) of the regulations is given, provided that: 

(i) the Board of Trustees informs the distributee that he or she has a right to a 

period of at least 30 days after receiving the notice to consider the decision of whether or not to 

elect a distribution (and, if applicable, a particular distribution option), and 

(ii) the distributee, after receiving the notice, affirmatively elects a distribution. 

(d) Effective January 1, 2010, ifa Participant or Former Participant dies, and the Beneficiary 

(determined pursuant to section 1.6) is not the surviving spouse of the Participant or Former Participant and 

is entitled to receive an eligible rollover distribution, the Beneficiary may elect to receive the distribution of 

the full amount of the Participant or Former Participant's Accrued Benefit to which the Beneficiary is 

entitled in the form of a direct rollover pursuant to a direct trustee to trustee transfer to either (i) an 

individual retirement account as defined in section 408(a) of the Code, or (ii) an individual retirement 

annuity, as defined in section 408(b) of the Code, established for the purpose of receiving the distribution 

on behalf ofthe Beneficiary. 

A direct rollover of a distribution by a non-spouse Beneficiary is a rollover of an eligible rollover 

distribution for purposes of section 402( c) of the Code only. Accordingly, the distribution is not subject to 

the direct rollover requirements of section 401 ( a )(31) of the Code, the notice requirements of section 402( f) 

of the Code, or the mandatory withholding requirements of section 3405(c) of the Code. If an amount is 

distributed from a Plan and is received by a non-spouse Beneficiary, the distribution is not eligible for 

rollover treatment. 

If, with respect to any portion of a distribution from the Plan of a deceased Participant's vested 

Accrued Benefit, a direct trustee-to-trustee transfer is made to an individual retirement plan as described in 

section 40l(c)(8)(B)(i) or (ii) of the Code, established for the purpose of receiving the distribution on 

behalf of an individual who is a Beneficiary of the deceased Participant and who is not his or her surviving 

Spouse or a Spouse or former Spouse who is an Alternate Payee under a Qualified Domestic Relations 

Order (1) the transfer shall be treated as an Eligible Rollover Distribution; (2) the individual retirement plan 

shall be treated as an inherited individual retirement account or individual retirement annuity [ within the 

meaning of section 408( d)(3)(C)] of the Code; and (3) section 401(a)(9)(B) of the Code [other than section 

401(a)(9)(B)(iv) of the Code] shall apply to such individual retirement plan. For purposes of this 

paragraph, to the extent provided in rules prescribed by the Secretary, a trust maintained for the benefit of 

one or more designed beneficiaries shall be treated in the same manner as a Beneficiary. 

(e) For distributions made after December 31, 2007, a Participant entitled to receive an 

eligible rollover distribution may also elect to have such eligible rollover distribution paid directly, as a 

direct rollover, to the custodian or trustee of a Roth Individual Retirement Account described in Section 

408A of the Code; however, for taxable years beginning prior to January 1, 2010, the income restrictions 

that apply to a rollover from a traditional IRA with a Roth IRA shall continue to apply such payments. 

ARTICLE 5 

MISCELLANEOUS 

Section 5.1 - Non-Reversion 

In no event shall any of the corpus or assets of the Plan revert to any Employer or the Association or be subject 

to any claims of any kind or nature by the Association or any Employer, provided that any contribution made by an 

Employer because of a mistake of fact or law may be returned to the Employer within the period of six months after a 

determination is made that the contribution was made by reason of such a mistake, if such return is authorized by the 

Board of Trustees. 

SLK_TOL: #2505331 v3 43 

SWORCCPP2018-000287
Section 5.2 - Limitation of Liability 

The Plan has been established on the basis of an actuarial calculation that has established, to the extent 

possible, that the contributions will, if continued, be sufficient to maintain the Plan on a permanent basis, fulfilling 

the funding requirements of ERISA. Except as otherwise provided by law, nothing in the Plan shall be construed to 

impose any obligation to contribute beyond the obligation of the Employer to make contributions as stipulated in the 

Collective Bargaining Agreement. 

There shall be no liability upon the Trustees individually or collectively to provide the benefits established 

by the Plan, ifthe Plan does not have sufficient assets to make such payments. 

Section 5.3 - No Specific Interest 

Nothing in this document shall be construed to give any Participant, Inactive Participant or Beneficiary any 

interest in the Plan, other than the right to receive payment in accordance with the provisions hereof. 

Section 5.4 - Participants' Rights 

Each Participant, Inactive Participant and Beneficiary shall have only the rights, privileges and benefits that 

are provided hereunder. The Plan does not create any contract of employment with any person nor grant any person 

the right to continue employment. 

Section 5.5 - Forfeitures 

If a Participant incurs a Forfeiture of Service, or dies under such circumstances that no death benefits are 

payable, his or her Accrued Benefit shall be forfeited. Such forfeiture shall not be applied to increase the benefits 

any other person would otherwise receive under the provisions ofthe Plan. 

Section 5.6 - Duties of Board of Trustees with Respect to Certain Payments 

Ifthe Actuarial Value of a Participant's vested Accrued Benefit exceeds $5,000, and the Accrued Benefit is 

immediately distributable, the Participant and the Participant's spouse ( or where either the Participant or the spouse 

has died, the survivor) must consent to any distribution of such Accrued Benefit. The consent of the Participant and 

the Participant's spouse shall be obtained in writing within the period of at least 30 days and no more than 180 days 

( or 90 days prior to January 1, 2007) ending on the Annuity Starting Date. The Board of Trustees shall notify the 

Participant and the Participant's spouse of the right to defer any distribution until the Participant's Accrued Benefit is 

no longer immediately distributable. Such notification shall include a general description of the material features, 

and an explanation of the relative values of, the optional forms of benefit available under the Plan in a manner that 

would satisfy the notice requirements of section 417(a)(3) of the Code and section l.417(a)(3)-l of the Treasury 

Regulations, and shall be provided no less than 30 days and no more than 180 days (or 90 days prior to January 1, 

2007) prior to the Annuity Starting Date. Further, for notices given in Plan Years beginning after December 31, 

2006, the written explanation provided to Participant shall include a description of how much larger benefits will be 

ifthe commencement of distributions is deferred. 

Notwithstanding the foregoing, only the Participant need consent to the commencement of a distribution in the 

form of a Joint and Survivor Annuity while the Accrued Benefit is immediately distributable. Neither the consent of 

the Participant nor the Participant's spouse shall be required to the extent that a distribution is required to satisfy section 40l(a)(9) or section 415 ofthe Code. 

Such distribution may commence less than 30 days after the notice required under section 1.41 l(a)-1 l(c) of 

the regulations is given to the Participant, provided that: 

(i) the Board of Trustees informs the Participant that he or she has a right to a period of at least 

30 days after receiving the notice to consider the decision of whether or not to elect a distribution (and, if 

applicable, a particular distribution option), 

SLK_TOL: #2505331v3 44 

SWORCCPP2018-000288
(ii) the Participant, after receiving the notice, affirmatively elects a distribution, and 

(iii) the distribution commences at least seven days after the Participant receives the notice. 

For purposes hereof, an Accrued Benefit is immediately distributable if any part of the Accrued Benefit could 

be distributed to the Participant ( or surviving spouse) before the Participant attains ( or would have attained if not 

deceased) the later ofthe Normal Retirement Date or age 62. 

The foregoing shall not apply if the Actuarial Value of such person's vested Accrued Benefit does not exceed 

$5,000. 

Section 5.7 - Valuation of Plan Assets 

The Board of Trustees shall cause the assets of the Plan to be revalued at least annually ( as of the last day 

of the Plan Year) at their fair market values. 

Section 5.8 - Merger, Consolidation or Transfer of Assets 

In the case of any merger or consolidation with, or transfer of assets or liabilities to or from, any other plan, 

each Participant's or Beneficiary's accrued benefit immediately after the merger, consolidation or transfer shall be 

equal to or greater than the Paiticipant's or Beneficiary's benefit immediately before the merger, consolidation or 

transfer. 

Section 5.9 - Inalienability of Benefits 

No benefit or interest available from the Plan will be subject to assignment or alienation, either voluntary or 

involuntary. However, this provision does not apply to the creation, assignment or recognition of a right to any 

benefit payable with respect to a Participant pursuant to a Qualified Domestic Relations Order, as defined in section 414(p) ofthe Code. 

Section 5.10 - Top-Heavy Provisions 

Ifthe Plan is or becomes top-heavy in any Plan Year beginning after December 31, 1983, the provisions of 

this section will supersede any conflicting provisions in the Plan. 

(a) Definitions. 

(1) Key Employee. Key employee means any employee or former employee 

(including any deceased employee) who at any time during the Plan Year that includes the 

determination date is an officer of the Employer having an annual compensation greater than 

$130,000 [as adjusted under section 416(i)(l) of the Code for Plan Years beginning after 

December 31, 2002], a 5 percent owner of the Employer, or a 1 percent owner of the Employer 

having an annual compensation of more than $150,000. For purposes of this subparagraph, annual 

compensation means Compensation within the meaning of section 1.11. The determination date is 

the last day of the preceding Plan Year. The determination of who is a Key Employee will be 

made in accordance with section 416(i)(l) of the Code and the regulations thereunder. 

(2) Top-Heavy Plan. The Plan is top-heavy for any Plan Year after December 31, 

1983, if any ofthe following conditions exists: 

(i) If the top-heavy ratio for the Plan exceeds 60 percent and the Plan is 

not part of any required aggregation group or permissive aggregation group of plans. 

(ii) Ifthe Plan is a part of a required aggregation group of plans but not part 

of a permissive aggregation group and the top-heavy ratio for the group of plans exceeds 

60 percent. 

SLK_TOL: #250533 lv3 45 

SWORCCPP2018-000289
(iii) If the Plan is a part of a required aggregation group and part of a 

permissive aggregation group of plans and the top-heavy ratio for the permissive 

aggregation group exceeds 60 percent. 

(3) Top-Heavy Ratio. 

(i) If the Employer maintains one or more defined benefit plans and the 

Employer has not maintained any defined contribution plan [including any simplified 

employee pension, as defined in section 408(k) of the Code] that during the five-year 

period ending on the determination date(s) has or has had account balances, the top-heavy 

ratio for the Plan alone or for the required or permissive aggregation group (as 

appropriate) is a fraction, the numerator of which is the sum of the present values of 

accrued benefits of all Key Employees as of the determination date(s) [including any part 

of any accrued benefit distributed in the five-year period ending on the determination 

date(s)], and the denominator of which is the sum of the present value of all accrued 

benefits [including any part of any accrued benefit distributed in the five-year period 

ending on the determination date(s)], determined in accordance with section 416 of the 

Code and the regulations thereunder. 

(ii) If the Employer maintains one or more defined benefit plans and the 

Employer maintains or has maintained one or more defined contribution plans (including 

any simplified employee pension) that during the five-year period ending on the 

determination date(s) has or has had any account balances, the top-heavy ratio for any 

required or permissive aggregation group (as appropriate) is a fraction, the numerator of 

which is the sum of the present value of the accrued benefits under the aggregated 

defined benefit plan or plans for all Key Employees, determined in accordance with (1) 

above, and the sum of the account balances under the aggregated defined contribution 

plan or plans for all Key Employees as of the determination date(s), and the denominator 

of which is the sum of the present value of the accrued benefits under the aggregated 

defined benefit plan or plans for all participants, determined in accordance with (1) 

above, and the sum of the account balances under the aggregated defined contribution 

plan or plans for all participants as of the determination date(s), all determined in 

accordance with section 416 of the Code and the regulations thereunder. The account 

balances under a defined contribution plan in both the numerator and denominator of the 

top-heavy ratio are increased for any distribution of an account balance made in the 

five-year period ending on the determination date. 

(iii) For purposes of subparagraph (i) and subparagraph (ii), the value of 

account balances and the present value of accrued benefits will be determined as of the 

most recent valuation date that falls within or ends with the 12-month period ending on 

the determination date, except as provided in section 416 of the Code and the regulations 

thereunder for the first and second plan years of a defined benefit plan. The account 

balances and accrued benefits of a Participant (i) who is not a Key Employee but who 

was a Key Employee in a prior year, or (ii) who has not been credited with at least one 

Hour of Service with any Employer maintaining the Plan at any time during the five-year 

period ending on the determination date will be disregarded. The calculation of the 

top-heavy ratio, and the extent to which distributions, rollovers, and transfers are taken 

into account will be made in accordance with section 416 of the Code and the regulations 

thereunder. Deductible employee contributions will not be taken into account for 

purposes of computing the top-heavy ratio. When aggregating plans the value of account 

balances and accrued benefits will be calculated with reference to the determination dates 

that fall within the same calendar year. 

The accrued benefit of a Participant other than a Key Employee shall be 

determined under the method, if any, that uniformly applies for accrual purposes under 

SLK_TOL: #250533 lv3 46 

SWORCCPP2018-000290
all defined benefit plans maintained by the Employer, or if there is no such method, as if 

such benefit accrued not more rapidly than the slowest accrual rate permitted under the 

fractional rule of section 411 (b)( 1 )( C) of the Code. 

(iv) For purposes of determining the present values of accrued benefits and 

the amounts of account balances of employees as of the determination date: 

(A) Distributions During Year Ending on the Determination Date. 

The present values of accrued benefits and the amounts of account balances of 

an employee as of the determination date shall be increased by the distributions 

made with respect to the employee under the plan and any plan aggregated with 

the plan under section 416(g)(2) of the Code during the I-year period ending on 

the determination date. The preceding sentence shall also apply to distributions 

under a terminated plan which, had it not been terminated, would have been 

aggregated with the plan under section 416(g)(2)(A)(i) of the Code. In the case 

of a distribution made for a reason other than severance from employment, 

death, or disability, this provision shall be applied by substituting "5-year 

period" for "1-year period." 

(B) Employees Not Performing Services During Year Ending on 

the Determination Date. The accrued benefits and accounts of any individual 

who has not performed services for the employer during the I-year period 

ending on the determination date shall not be taken into account. 

(4) Permissive Aggregation Group. The required aggregation group of plans plus 

any other plan or plans of the Employer that, when considered as a group with the required 

aggregation group, would continue to satisfy the requirements of section 401 (a)( 4) and section 410 

ofthe Code. 

(5) Required Aggregation Group. (1) The qualified plan of the Employer in which 

at least one Key Employee participates or participated at any time during the determination period 

(regardless of whether the plan has terminated), and (2) any other qualified plan of the Employer 

that enables a plan described in (1) to meet the requirements of sections 401(a)(4) or 410 of the 

Code. 

(6) Determination Date. For any Plan Year subsequent to the first Plan Year, the 

last day ofthe preceding Plan Year. For the first Plan Year of the Plan, the last day of that year. 

(7) Valuation Date. The last day of the Plan Year, the date as of which account 

balances or accrued benefits are valued for purposes of calculating the top-heavy ratio. 

(8) Present Value. Present value shall be based only on the interest and mortality 

rates specified in Appendix I. 

(b) Minimum Accrued Benefit. 

(1) Notwithstanding any other prov1s10n in this Plan except 

subparagraphs (b )(3 )-(b )( 5) of this section, for any Plan Year in which the Plan is top-heavy, each 

Participant who is not a Key Employee and who has completed at least 1,000 Hours of Service 

with the Employer will accrue a benefit (to be provided solely by Employer contributions and 

expressed as a Straight Life Annuity commencing at the Normal Retirement Date) of not less than 

2 percent of his or her highest average compensation for the five consecutive years for which the 

Participant had the highest compensation. The aggregate compensation for the years during such 

five-year period in which the Participant was credited with a year of service will be divided by the 

number of such years in order to determine average annual compensation. The minimum accrual is 

determined without regard to any Social Security contribution. The minimum accrual applies even 

SLK_TOL: #2505331v3 47 

SWORCCPP2018-000291
though under other provisions of the Plan the Participant would not otherwise be entitled to 

receive an accrual, or would have received a lesser accrual for the year because the non-Key 

Employee fails to make mandatory contributions to . the plan, the non-Key Employee's 

compensation is less than a stated amount, the non-Key Employee is not employed on the last day 

of the accrual computation period, or the Plan is integrated with Social Security. 

(2) For purposes of computing the minimum accrued benefit, compensation shall 

mean compensation as defined in section 415( c)(3) of the Code, as limited by section 40l(a)(l 7) 

of the Code. 

(3) No additional benefit accruals shall be provided pursuant to subparagraph (b )(1) 

to the extent that the total accruals on behalf of the Participant attributable to Employer 

contributions will provide a benefit expressed as a Straight Life Annuity commencing at the 

Normal Retirement Date that equals or exceeds 20 percent of the Participant's highest average 

compensation for the five consecutive years for which the Participant had the highest 

compensation. 

(4) Notwithstanding subparagraph(b)(l), if a Participant is covered under any 

defined contribution plan of the Employer that is also top-heavy, the minimum accrual 

requirements of section 416 of the Code shall be satisfied during the Plan Year the plans are topheavy if the Participant is provided with the minimum accrual described in section 5.l0(b)(l), 

offset by benefits provided under the defined contribution plan. 

(5) All accruals of Employer-derived benefits, whether or not attributable to years 

for which the plan is top-heavy, may be used in computing whether the minimum accrual 

requirements of subparagraph (b)(3) have been satisfied. 

If the form of benefit is other than a Straight Life Annuity, the Participant must receive 

an amount that is the actuarial equivalent of the minimum Straight Life Annuity benefit. If the 

benefit commences at a date other than at Normal Retirement Date, the Participant must receive at 

least an amount that is the actuarial equivalent of the minimum Straight Life Annuity benefit 

commencing at the Normal Retirement Date. 

(c) Vesting Provisions. The minimum accrued benefit required [to the extent required to be 

nonforfeitable under section 4 l 6(b) of the Code] may not be forfeited under section 411 ( a )(3 )(B) or 

41 l(a)(3)(D) ofthe Code. 

For any Plan Year in which the Plan is top-heavy, the following vesting schedule will apply: 

Years of Vesting Service Vested Percentage 

Less than 3 0 

3 or more 100 percent 

The minimum vesting schedule applies to all benefits within the meaning of section 41 l(a)(7) of 

the Code except those attributable to Employee contributions, including benefits accrued before the 

effective date of section 416 of the Code and benefits accrued before the Plan became top-heavy. Further, 

no decrease in a Participant's nonforfeitable percentage may occur in the event the Plan's status as topheavy changes for any Plan Year. However, this subparagraph does not apply to the Accrued Benefit of any 

Employee who does not have an Hour of Service after the Plan has initially become top-heavy and such 

person's account balance attributable to Employer contributions and forfeitures will be determined without 

regard to this subparagraph. 

SLK_TOL: #250533lv3 48 

SWORCCPP2018-000292
Section 5.11 - Governing Law 

This document shall be administered, construed and enforced in accordance with ERlSA and, to the extent 

that ERlSA has not preempted the laws ofthe State of Ohio, in accordance with the laws of the State of Ohio. 

Section 5.12 - Marriage Equality Requirement 

Notwithstanding any provision in the Plan to the contrary, for purposes thereof, 

1. The terms "spouse," "husband and wife," "husband," and "wife" include an individual married to a person 

of the opposite or same sex if the individuals are lawfully married under state law, and the term "marriage" 

includes such a marriage between individuals ofthe opposite or same sex. 

2. Any marriage that was validly entered into in any state is recognized by the Plan as a marriage, and the 

individuals in that marriage as spouses. 

Section 5.13 - Recovery and Offset for Overpayment or Erroneous Payment 

Notwithstanding any provision of this Plan to the contrary and to supplement any other right to recovery or 

reimbursement contained in the Plan, the Plan Administrator shall have the right to recover any erroneous or 

overpayment of any benefits or funds to any participant, retired participant, beneficiary, alternate payee, or other 

individual, regardless of whether any such payment remains separately identifiable. The Plan Administrator shall 

have all rights in law and equity to recover such erroneous payments or overpayments, including, but not limited to, 

offset or reduction of any benefits owed to or due to be paid to such participant, retired participant, beneficiary, 

alternate payee, or other individual. 

Section 5.14 - Dispute Resolution Forum for Withdrawal Liability 

Effective September 8, 2011, the sole forum for arbitration of disputes with the Plan related to withdrawal 

liability shall be the American Arbitration Association subject to its Multiemployer Pension Plan Arbitration 

(MEPPA) Rules for Withdrawal Liability Disputes, as amended. 

ARTICLE6 

Amendment and Termination 

Section 6.1 - Amendment 

No part of the corpus or income of the Plan shall be used for purposes other than for the exclusive benefit 

of Participants and Beneficiaries, and for defraying reasonable expenses of administering the Plan. Otherwise, the 

Plan may be amended at any time by the Board of Trustees. Any amendment may be given retroactive effect. 

However, no amendment (including a change in the actuarial basis for determining optional or early retirement 

benefits) shall be effective to the extent it has the effect of decreasing an Accrued Benefit. However, the preceding 

provision shall not apply to the extent the reduction in the Accrued Benefit is permitted by section 412(c)(8) of the 

Code. For purposes of this section, an amendment that has the effect of ( 1) eliminating or reducing a retirement-type 

subsidy or (2) eliminating an optional form of benefit (with respect to benefits attributable to service before the 

amendment) shall be treated as reducing an Accrued Benefit, except as otherwise permitted by law or regulation. In 

the case of a retirement-type subsidy, the preceding sentence shall apply only with respect to a Participant who 

satisfies ( either before or after the amendment) the pre-amendment conditions for the subsidy. In general, a 

retirement-type subsidy is a subsidy that continues after retirement, but does not include a qualified disability 

benefit, a medical benefit, a Social Security supplement or a death benefit (including life insurance). In addition, no 

amendment shall have the effect of decreasing a Participant's vested interest determined without regard to such 

amendment as of the later of the date of such amendment is adopted or becomes effective. Notwithstanding this 

section 6.1, a Participant's Accrued Benefit, early retirement benefit, retirement-type subsidy, or optional form of 

benefit may be reduced by an amendment to the Plan adopted by the Board of Trustee to the extent permitted under 

section 412( c)(8) of the Code (for Plan Years beginning on or before December 31, 2007), or Section 412(d)(2) (for 

SLK_TOL: #2505331v3 49 

SWORCCPP2018-000293
Plan Years beginning after December 31, 2007), or to the extent permitted under sections 1.411 ( d)-3 and 1.411 ( d)-4 

of the Treasury Regulations. 

If the Plan's vesting schedule is amended, or if the Plan is amended in any way that directly or indirectly 

affects the computation of the nonforfeitable percentage, each affected person with at least three Years of Vesting 

Service may elect, within a reasonable period after the adoption of the amendment or change, to have the 

nonforfeitable percentage computed under the Plan without regard to such amendment or change if his or her 

nonforfeitable percentage under the Plan, as amended, is at any time less than the percentage determined without 

regard to such amendment. 

The period during which the election may be made shall commence with the date the amendment is 

adopted or deemed to be made, and shall end on the latest of the following: 

(1) 60 days after the amendment is adopted; 

(2) 60 days after the amendment becomes effective; or 

(3) 

Trustees. 

60 days after written notice of the amendment is issued by the Board of 

An amendment to the Plan shall be evidenced by an instrument in writing signed by a majority of the 

number ofthe Board of Trustees or by the duly-authorized officers thereof. 

Section 6.2 - Termination 

The Plan may be terminated at any time upon the written agreement of the Council and the Association. 

The Board of Trustees shall continue to act until the fund has been distributed according to the provisions of this 

document. 

When a termination or partial termination ofthe Plan occurs, each Participant's Accrued Benefit shall be, to 

the extent funded as ofthe date oftermination or partial termination, totally nonforfeitable. 

In the event of termination (including partial termination) of the Plan, the Board of Trustees shall allocate 

the assets of the Plan (available to provide benefits) among Participants, Inactive Participants and Beneficiaries in 

the manner provided by ERISA. 

Section 6.3 - Restrictions in Event of Plan Termination 

In the event of the termination of the Plan, the benefit of any highly compensated active or highly 

compensated former Employee shall be limited to a benefit that is nondiscriminatory under section 401(a)(4) of the 

Code. 

Benefits distributed to any of the 25 most highly compensated active and highly compensated former 

Employees with the greatest compensation in the current or any prior year shall be restricted such that the annual 

payments are no greater than an amount equal to the payment that would be made on behalf ofthe Employee under a 

Straight Life Annuity that has the same Actuarial Value of the sum of the Employee's Accrued Benefit, the 

Employee's other benefits under the Plan [other than a Social Security supplement, within the meaning of section 1.41 l(a)-7(c)(4)(ii) of the regulations], and any amount the Employee is entitled to receive under a Social 

Security supplement. 

SLK_TOL: #2505331 v3 50 

SWORCCPP2018-000294
The preceding paragraph shall not apply if: (1) after payment of the benefit to an Employee described in the 

preceding paragraph, the value of Plan assets equals or exceeds 110 percent of the value of current liabilities, as 

defined in section 412(1)(7) of the Code, (2) the value of the benefits for an Employee described above is less than 

1 percent of the value of current liabilities before distribution, or (3) the value of the benefits payable under the Plan 

to an Employee described above does not exceed $5,000. 

This section is solely for the purpose of complying with the requirements of the Internal Revenue Service 

and shall not be applied except to the extent necessary to comply with such requirements. 

SLK_TOL: #250533lv3 51 

SWORCCPP2018-000295
IN WITNESS WHEREOF, the Board of Trustees of the Southwest Ohio Regional Council of Carpenters 

Pension Plan has caused this document to be executed by duly authorized officers on this 4th day of December, 2014, 

but effective as of January I, 2014, except as otherwise noted. 

SOUTHWEST OHIO REGIONAL 

COUNCIL OF CARPENTERS 

PENSION PLAN 

SWORCCPP2018-000296 
APPENDIX I 

(1) Interest at 7 percent per annum, except as otherwise provided below hereof. 

(2) Mortality based on UP-1984 Mortality Table, except as otherwise provided below. 

(3) Lump sum payment for purposes of calculating the present value of the benefit payable on or after 

January 1, 1999 and prior to January 1, 2008: 

(a) Interest at the average annual interest rate on 30-year U.S. Treasury bonds for the second 

month preceding the beginning ofthe Plan Year in which the distribution occurs. 

(b) Mortality based on the 1983 Group Annuity Mortality Table in the form prescribed by 

Rev. Rul. 95-6, or such other mortality table prescribed by the Commissioner of the Internal 

Revenue Service for purposes of section 417( e )(3) and section 4 l 5(b )(2)(E) of the Code. 

Effective for distributions with Annuity Starting Dates on or after January 1, 2003, and 

notwithstanding any other Plan provision to the contrary, any reference in the Plan to the 

applicable mortality table or the mortality table prescribed in Rev. Rul. 95-6 shall be 

construed as a reference to the mortality table prescribed in Rev. Rul. 2001-62 for all 

purposes under the Plan. 

(4) Lump sum payment for purposes of calculating the actuarial value of the benefit payable on or 

after January 1, 2008 shall be based on the Applicable Mortality Table and the Applicable Interest 

Rate as defined below: 

(a) Applicable Interest Rate: the adjusted first, second and third segment rates applied under 

rules similar to the rules under section 430(h)(2)(C) of the Code for the second month 

preceding the Plan Year containing the date of distribution, or such other time as the 

Secretary of the Treasury may by regulations prescribe. For this purpose, the adjusted 

first, second, and third segment rates are the first, second, and third segment rates which 

would be determined under section 430(h)(2)(C) of the Code if: 

1. Section 430(h)(2)(D) of the Code were applied by substituting the average 

yields for the month described in section 430(h)(2)(D)(ii) of the Code for the 

average yields for the 24-month period described in such section; and 

2. Section 430(h)(2)(G)(i)(II) of the Code were applied by substituting 

"section 417(e)(3)(A)(ii)(II)" for "section 412(b )(5)(B)(ii)(II)"; and 

3. the applicable percentage under section 430(h)(2)(G) of the Code is treated as 

being 20% in 2008, 40% in 2009, 60% in 2010, and 80% in 2011. 

(b) Applicable Mortality Table: the mortality table modified as appropriate by the Secretary 

of the Treasury, based on the mortality table for the Plan Year as specified under 

subparagraph (A) of section 430(h)(3) of the Code, without regard to subparagraph (C) or 

(D) of section 430(h)(3) ofthe Code. 

SLK_TOL: #2505331v3 

SWORCCPP2018-000297
APPENDIX II 

SLK_TOL: #2505331v3 

SWORCCPP2018-000298
• • 

• • 

AP.PENDIXrr

(DAYTON) 

I• •

UNIT.ED lH\OTHERHOOD OF CAilPENTEns AND JOlliERS OF AMlSlUt;A . 

JNTERNATIONAL RECIPROCAL AGllEEMENT FOR 

CARPENTERS PENSION FUNDS 

fo by Boards ofTrustees of Pension Funds (signatory Fund or Funds) which provide retirement and pension 

This International :Reciprocal Agreer.ne.nt for Carpenters .Pension Funds (Reciprocal Agreement) is ~ntered. 

eneilts for employees (Employees) represented for the purpose of collective bargaining by one or more Local 

:nions or CounoUs affiliated with the United Brotherhood of, ,Carpent7rs and

·· Jqiners of America {Unlled 

,rotherhood). 

'Ihe Effective Date of this Beciprocal Agreement sbru.1 be, for each •signatory I'ension Fund, the date set 

o.rth. as the "Effective Date" on the slgnal:ure page used· by tbe Fund to become a party to this, Reciprocal 

lgreement and such Effective Date shall have the signIBoance set forth herlnafter. 

This Reciprocal Agreement shall be signed on beh11lf of a Fund becopling signatory to this Agreement: by 

a.t lea.st one Ji;mployer and at Ienst one Union Trustee of such Fund who are duly a.ul:horized to execute this 

;.. .. 

The persons wl10 are from time to Hme acting as Trustees ofsignatofy Pension Funds are sorneti~es referred 

Agreement for that Pension Fund: 

· · • · · lrl ,t ;. •

· ·•. · • ' 

to in this Agreement as 'Trustees". ,; : 

·t' 

WHEREAS, the Trustees of each signatory Fund acting under separate Trust Agreements are authorized : WITNESSETH: 

and empowered to e11tl!r into this Reciprocal Agreement and to' provide'retirement nnd pension bane.fits to, em­

• .'· • • ' 1 : "· 1,, ,. · · • · :· '.! .; ·I :•

ployees who are or.have been represented. in collective hnrgafoing by Local Unions cir District Councils affiliated 

,:.. • · .. · with the United l3rotberhooc1; n.od 

· WHEREAS, many ~mployees have cont,ributions'made·i? more tha11 one signatory Pension F,unlnnd as a 

'' ... reduced pension benefits been.use years of service credit were divided nmong sjgnatory Funds; n:nd 

consequence inay not be eligible for any pension benefits from nny signatory J?ension Fund or may qualify for 

1 • • , ··,: 1 

·WHEREAS, the Trustees ofsignatozy Funds desire to·.make _provision for" conlinttity of pension coverage for 

'• •I· ,1··· • ·;

..

,. ' 

;eciprocal agreements b~seq.~n parlinl pensuch Employees; and 

WHEREAS, it is recognized that some sigllatory Fl.Ulds hawi1

. ,. 

sions or the transfer tlf co:otribuHons (money~follows-the-mah) and it'is further recognized that it fa not the :infent 

of this Agreement to modify, cancel or a.1fect such Agreementsr and.,.. . " 

VVHEREAS, the Trustees of each signatory Fund acknowledge that they have llIIl_emled tnelr Plan ln substantial!y the form ofExhibit Aor Exhibit A and Exhibit Battached hereto. (All signatory Pension Funds must adopt 

, ,1 • 

E:chibit A providing for partial pensions ru1d1 if !:hey plect to d~ so, Exhibit 13 which providet ~at the .E)md will 

WHEREAS, each signatory Pension Fund fa qualilled as a tax exempt trust under the ap,eroprfat~ provisions 

transfer mone,r. to other signatory: FuDd.s which hav~ .al~o a1_op~1tl Exhi?!t B; 

, ...: • · · · : ' •·

of the Internal Revenue Service and is currentl( operating in such a manner ns to continue to be entitled to sucb 

i. • • •• •• • • · 

WHEREAS, the Trustees of ench' 

signato.ty Pension Fund desire to implement" the amendments adopted 

exemption·t and 

pursuant to this Reciprocal Agreement and establish unifqnn prooeuures to cnrry out the terms of this Reciprocal 

, , 

WHEREAS, the Trustees of each signatory l'ension Fund executing this Agreement on behalf of the!r 

Agreementi and 

• 

respective :Pension Funds represent and warrant that tbey ._have been duly authorized to make, execute and 

1,, • deliver this Agreement; 

I 

. ,, NOW, TI·lEDEFOUE1 In consideration of the mutual prom!ses, it is mutually understood and agreed as 

f011ows: 

Scotton 1. Form of Agreements. The Trustees of ench signato.ry Pension Fund must amend lh.elr Penslon 

Plan to incorporate the nrticle attached hereto as Exhibit A. Exhibit Aprov!d.es for partial pensions based on 

service credit with two or more signa~ory Pension Funds. I 

SWORCCPP2018-000299
The Trustees of any signatory Pension Fund mny, in addition to adopting Exhibit A, elect to amend theh

Pension Plan to incorporate the article attached hereto as Exhibit B; such election to be indicated on the signature page of this I\eciprocnl Agreement. As between two signatory Pension Funds whioh have both adopted

Exhibit B as well ns Exhibit A, Exhibit B shall govern, As between two signn.l:ory Pension Funds only one 0£

which has ll<lopted Emlbit B as well ns Exhibit A, Exhibit A s~all govern.

ment, 

• S~ction 2, necognition, Each signatory Pension Fund, for the period it is bound by this Reciprocal Agreerecoguizes each other signnto1y :Penslop Fund as a "Related" an_d/or "Coopers.ting" Fund to the extent that

such Fuud lias adopted one 01· both of \:he Articles attnched hereto as Ex~bit A and Exhibit B.

. Sect!~n 3, Effect 011 Other Reciprocnl Agreements. This Reciprocal Xgreement shall in no way be construed as interfering with or affecting any Reciprocal Agreement between a signatory Pension Fund and 11 nonsignntory Pe11slon Ftmd or any Reclp1·ocal Agreement between signatory Pension Funds, unless the Belated or

Cooperating Plans covered nuder thefr own B.ecip1·ocal Agreement mutually agree to clisconthme 

Agreement and agree to be covered under 

their Reciprocal

this Reciprocal Agreement,

~ Section 4. Cootierntion. The effective administration of this ReciproC3;l Agreement by the Trustees of tl1e

signatory Pension Funds requires that each Fund exchnnge information with respect ta tl1e credited service of

persons covered by such Fund, the status pf pensions paid from time to time by such Fund and the details of the

pl.an.of. beneflts ·provided by such Fund. The Trustees of each signatory Pension Fund agree to cooperate in tbe

exchange or relevant information and documents to permit implementation of the pension provisions in the attached Exhibit Aor Exhibits A and B. Each signatory Pension Fund shall comply within thirty (80) days w:ith auy

reasonable written request by another signatory Pellsion Fund for information or data ~ecessary to carry out the

pui:poses of this Reciprocal Agreement 

Secl'ion 5.. Z:[o Change in Exhibit A or Exhibit B. The Trustees of each signatory Pension Fund agree that;

except .as hereinafter provided in Sectio1112 hereof, no substantive cl1ange snall be made in tl1e provisions a.f the

Articles attached hereto as Exhibit A or Exhibit B, either by change of language or by any modilkatlon of the

Pension Plan which would have the effect of changing the provisions of Exhibit A or Exhibit B, It is further

agreed tbat the only way a signatory Pension Fund can terminate the operation of.the provisions of Exhibit Aor

Exhibit B is to follow the tenntnation provisions of this Reclprocal Agreement setforth in Section 9 hereof.

Section 6, Effective Date. ,The date this Reciprocal Agreement becomes operative as to any signatory :Pension Fund shall be the date shown as tbe "E!Fecttve Date'; on the signature page, The elate this Agreement: becomes operative.as between two signatory Pension Funds shall be the Effective Date of each sitch Fund if they

are the samu Effec~ive Date or the later of the two Effective Dates if they are not the same•

Applications 

.This Reciprocal 

previously 

Agreement 

denied 

shnl1 

by any 

be enforced 

of 

£or pension applications made on and after the Elfeclive Date.

the signatory Plans may be reconstdered upon the approval of a11

affected :Plans. ·

Section 7. Duration of lleciprocal Agreement. This Reciprocal Agreement shall .first be operative when at

lenst two Pension Funds become signatories antl shnll coutfone' so long as two or more :Pension Funds continue

as signatories, 

•.

Section B. Central Filing of Eeciprocnl Agreements 11ncl :Related Documents. Wlthin ten (10) days .from the

date of execution of tl1is Reciprocal Agreement, each Pension Fund which becomes a signatory fund shall file a

signed copy with the following: 

General President

United Brotherhood of Carpenters nnd Joiners of America

101 Constitution Avenue, N.W.

Washington, D. C. 2.0001 

but at least.annually, in the official publication of the United Brotherhood a list of all Pension Funds and their 

It is understood tl1at tl1e Genei-al President of the United Brotherhood will cause to be publis~ed· periodically,

addresses whicb have become and remaiin pnrties to this neclpl'ocal Agreement. The ·listing will be based 011

the filing of a copy of such Agreements ns provided in this section and based on the llling of notices of termination of participation in this Recip!'ocal Agreement ns 11eretofore provided. 

SWORCCPP2018-000300
' -•••"•"••• ,.....••---•••-••••-•-•-••••••-r..,i...,.,._•,,;---'-~~~l~ ;....~~\it'Wtt~~sf~~....._____ 

;ivlllg written uotice by certified mail to the General President of the United Brotherhood at least nine!J (SO) 

Section 9, l'erroinntiou, Any 0£ the signatory Pension Funds may te•te t:h!s Reciprocal Agreement by 

~nys in advance of the date such termination is d~sired. 

Section 10, ArbitrnUon, Any dispute, controversy or claim nris!ng out of or relating to the'applicatl.on of this 

Agreement between signnto1y Plans shall be settled by arbitration, Any signatory :Plan which disagrees with the 

action ta.ken by another Plnn under this Agreement may request arbitration by filing awritten notice witli suoh 

Plan by cert!fied mail with a copy to the United Drotli.erhood. If the Trustees of !:he Plans involved cannot agree 

upon nn arbitrator within thirty days, nppHcation sl1all be made to the Amerfoau Arbltration Associa:tton 'for the 

· 

selecUon of an nrbH:rator. The general expenses of the arbitration, if any, shall be borne equally

· 

by,

· 

the

· · 

parties

· to the arbitration, 

Judgment on ariy award rendered shall be binding on the pnrl:ies and may be enteretl in any court having 

jurisdiction. 

Section 11, Separnte Liability. 

(a) It is expressly understood and agreed that none of the signatoi:y' Funds assumes any of ~e liabilities or 

obligations of l:he other signatory Funds:· Each signatory Fund shall be liable solely n.nd exclusively for pension 

benefits due u11der its own pension fun<l, and no Fund shall be liable for the acts or omissions -of another Fund. 

(b) The Trustees of each signatory Fund shall be fully protected in acting upon any instrument;' certiflcn.te, · 

report or paper beUeved by them to be genuine, and t}le Trustees of each signatory Fund shall be under no duty 

to make any illvestigation or inquiry as to any statement in any such writing, ,or as to the authority. of the.pen~ 

sion -making siich statement, but may accept tbe same as conclusive evic1ence of the accuracy of the statement 

. . . • ! .. J ••,. contained therein and the au~ority to make it. 

Section 12. Amendment.· Proposals for amenclment of this Agreement may be submitted to the General 

Presideut of the United Brotherhood. Proposed amendments may be submitted by the. Unite~ ;Brother~ood to 

the affiliated Funds for a vote. Aproposed amendment will be deemed adopted if approved. by a two-1:'hitds (1⁄2) 

vote of all signatory Funds voting within the time prescribed by the General President of the United :Brotherhood.

. " 

Section 13, Jurisdic:1:ion. This Agreement shall be construed and enforced according to the laws of the Dis:· 

Met of·columbia and the Trustees of the signafory funds shall be Ha.bie to account with respect to' this Agreement, and any rights and duties thereunder, only- in the courts oE the Dlsbfot of Columbia. However, a dispute 

ment Income Security Act of 1974 (ERISA). ·

between a Participant and a specific signatory Fund

· 

shall be snbJect to the provisions of the Employee RetireSection 14, Amendment of Pinn lJocurpef.!~. Each signatqry Fund agrees to make the necessary amendments .

to its Pension l'lan documents, and other legal documents which may be required, in order to implement the pro• 

visions of this Agreement, · 

SWORCCPP2018-000301
~:!~~~~~~ ., ·.;,·•.: SIGNATURE :PAGE 

;r-,•. ·."=-:r:+":.., -:. _ -< ,:"·· lN WITNESS WHEREOF the Pension Fund named below by the signatures of its duly authorized Trustees 

hereby becomes a party to this Reciprocal Agreement and agrees to be bowid by its terms and provisions. It is 

tJD~erstood that eacb Fμnd which becomes or is signatory to this Reciprocal Agreement is entering this Agree• 

,l;l;l.ent wi~ each other signatory FQDd. ..,....,. ~. . . .. 

·f<i•:• The Effective Date for ~e following Pen~on Fund shall be the _1_ day of_.--=M=a=-y'------, 19~ 

Please check one: 

~ FUDd has adopted Exhibit A only------------------------------------------------------·. ( )/ 

This FUDd has adopted both Exhibit A and Exhibit B -------:----------------------------.------ ( V) 

(Note: Exhibit .A must be adopted by all Funds and provides for partial pensions. Exhibit ff should only be 

adopted by Funds that want to transfer contributions to other Funds that have adopted E~bit B.) 

. F •a N Miami Valley Carpenters D.C. Pension Fund 

Pension uu ame: ----.--------------------------

Dayton OH 45405 Pension Fund Address, 201 Riverside Dr. 

. .

,.'§;;~.. ~ ...;;.:s ..:s;~;i:,,;;!:it~-i;:;-;:A~#-::;.;-.==· ==-;:::: .. ~-:=-•::'.!"~·--:':'.:.;··.2.- _:.::.·•,·:......,;.~~- ••. ·~---·- ----~ · ... ·- ···· •·..... . ·· - - · • • - • ,.\I·-

~~- .-:.....:.. ··'- :· . . 

SWORCCPP2018-000302 
... .................. 

SIGNATURE PAGE (continued) 

COMPLETE l3ELOW IF MPLICABLE 

It is understood and agl:'eed. that this Reciprocal Agreement shall not make void, clnmge or replace a Reclp• 

' ·

rocnl Agreeme11t entered into by thls signatory Pension Fund with the following Pension Fun<l(s) whose names and 

nddresses are listed below; 

It Is further understood that the signatory .Pension Fund named below shall notify the Unitecl Brotherhood in 

writing of nny ndditiona~ Reciprocal Agreements to whi~h such sigup.tory Fund becomes party nnd which shall 

tnke precedence over thls Beciprocal Agreement. It ls also forther understood that such signatory .Pension Fund 

shall notify tbe United Brotherhooc1 of the cancellation of a11y Recipro7al Agreements to wl:tlch·

· 

fuch ·signatory 

·

, 

· Fund was n party, 

'.. 

~ !• • 

Sl1ni.turo ol Autbarlud Upfan Tru•ID• 

•. I 'i 

••\ t I 

SWORCCPP2018-000303
,•. ,1,:•·.. Extn:BIT A'' 

•' iAB.TIGLE'-:PARTIAL PENSIONS; 1 

Section l. .l't1rpose, · Partial Pensions shall be provided under this Agreement for Employees who otherwise 

lack suffictent pensio11 credit to be eligible for any pension because. their years. of employment were divided between different part!cipat.ing pension plnris or, if eligible, whose J?ensions would be less than the full amount 

beco.use of such dlvision of employment. 

Section 2. Related Pension Credits. For purposes of this Agreement the term "Pension Credits' shall mean 

those periods of service during wlucl1 credit is gi·anted for benefit accrual purposes. Pension Credit shall 11ot necessarily cover periods for which a Pinn grants credit for ve~ting purposes under ERISA. Pension Credits accumulated ancl maintained by nn Employee under one of the Plans signatory to this Agreement shall be recognized 

under this Agreement by the other signatory Plnns as Related fensio11 Credits. Penslon Credits under each Plan 

shall be based on the rules in effect in that Plan at tiie time the employment occurred. 

Section 3, Combined :Pension Credit. The Pension Credit gi·anted under each of the Plans slgnntory to this 

Agreement together comprise the Employee's Combined J?enslon Credit. In no cuse will more than one year of 

Pension Credit be counted for any twelve consecutive calendar months. 

I£ the Employee has, in a calendar year, worke<l under two or more Plans and nccwnulated fractional years 

of Pension Credit which together add up to more than one year of credit for: that calendar yeari then the :Pension 

Credit recognized under this Agreement shall be limited to one yea.r. :Pension Credit will .first be counted under 

the Plan which pl'ovides the highest benefit accrual rate, The other Plo.n(s) shall count as Pension Credit the nee• 

essru.y fractional year(s), in a decliuing benefit accrual rate order, whlch will bring the total to exactly one year 

of Pension Credit for the Employee. 

Section 4. 'Irnnsfer of Contributions. Notwithstanding any other provisions of thls nrtic!e to the contrary 

an Employee whose f!ome Pension Fund is a signatory to Exhibit Bof this Reciprocal AgreemeDt and who works 

under the jurisdiction of and· bas contributions·made' td a Pe7:1sloh Fund signatory only to Exhibit A of this 

Reciprocal Agreement shall have ·such contributions fonvarded to his Home Pension Fund: • t f ., •~ • •,. 1 I "l • 1t If I • I I I 1 • • • "" " 

(a). if during any" calemlar year such Employee. docs not earn $Orne Pension Credit under the Pension Fund 

signatory only to Exhibit A of this Reciprocal Agreement, ond , , 

(b) if ut the end of any three calendar yea. perfod such Employee has not earned a total of at least one year 

of Peusion Cretlit in e. Peuslon Fund signatory only to Exhibit.A of th.is Reciprocal Agreement such contributions will be sent to his Home Fund. 

Section 5. Eligibility for Benefits, An Employee shall be eligible for a Partial Pen~ion if he satisfies all of 

the following requirements; 

(n) He would be eligible for any type of pension under the Plan if his Combined Pension Credit were 

treated as credit under that Plan; and 

(b) He has, under several of the signatory plans,' at.leas't one yi;ar of Pension Crndit since January 1, 1955; 

and · .. . 

(c) In the case of an Employee applying for a pension based on disability, he is able to meet the definition 

of disabil~ty in each 0£ the signatory Plans, or in the case of a.n Employee applying for a pension based 

on age, he meets the minimum age requirement in each of the signatory Plan11 which will be paying 

Partial Pensions; and 

(d) At leo.st two Plans will actually be paying a Partial .Pension under th~ terms ~f this Reciprocal 

Agreement, 

Section 6, Election of Pension. If an Employee is. eligible fo1· more than one type of pension or optional 

form of benellt under t1ie signatory Plnns, he shall be entitled to elect the type and form, of pension he is to 

receive from each Plan. 

Section 1. Partial Pension Amount. The amount of the Partial Pension _payable by each signatory Plan 

under which nn Employee qualifies for a pension shall be the.benefit amount he accrued under that Plan durlng 

tbe period he earned :Pension Credit under that Plan. 

SWORCCPP2018-000304
Section 8, 'Payment of J?artinl l'ensio.ns, The payment of a. Partial Pension shall be subject to nll of the conditions contained in the signatory Plans applicable to other types of pensions, ll a. Partial :Pension b suspended 

by one Plan, it may be suspended by oilier Plan(s), Any '.Plnn suspending a pensioner's benefit shall. notify all 

other afi'ected Plans._ 

Section 9 Other :Benefits. The obligation of each of the Plans signatory to this Agreement is limited to·pensio11 benefits, including survivor's pensions after retirement payable as a result 0£ election 0£ a Husband and Wife 

Penslon or guaranteed period payments. This Agreement shall not apply to any :pre-ret:!.tement death .or sur• 

vivers' benefits. Ot}ler benefits provided by any of the Plans after retire~ent such as lump sutn d~ath benefl.ts, 

)evol income or lump smn options, health benefits, etc., are not" covered by this Agreement. However/ notltlng tn 

this Agreement shall prohJbit nny :Plan from providlng such benefits in aocorda:uce with its own IUles and 

• · · · regulations. 

Section 1.0, Benefit Inorcnses, After an Employee leaves the j\lrisdiction of one of the signatory Plans the 

bene.llt level 111 that Plan may be later i11orea.sed. ·Benefits from that Plan may be computed at the benefit level 

ln effect nt the time the Participant last ea.med Pe·nsion Credit under that Plan, or the level nh.,the time the 

pension is effective, at the option of each Plan. · • · i 1 l 1 •••,., 

Section 11. Application l'roceclure. The Plan under whtch an Employee .lhst makes application for b;neflls 

shall initiate the processing of a .Partial Pension with the other signatory l?lans-based upon the in.formation supplied by the .Employee as to where he worked, Each Plan agrees to provide the other Plans with complete data, 

certlSed by an authorized Administrator or l'lan employee, ill order ~o process :Parl:ial Pensions promptly under 

: ,. th.is Agreement. 

In ap{?lylng the riile~ of each l'lan 'with respect to cn.nceHation of :Pension 

Section 12. Brenks in Service. 

Credit, ruiy Pension Crec1it earned. during a period in which the.Employee worked. in the jurisdiction of another 

signatory Plan sbllll be constd~recl when cletennining wbether there has.been a permanent break in service, 

1' I 

,, ~ .

• ! 

• I 

• 1.. ,.... .. .. ' .1 '\ '"' 

.. 1. ' .

"i''•

.. ,,! 

,: : ...'f. 

I •• ,! ;, • "tt,f!11' 

'• t I ••• ! .. .,.,. .,.. ··r 

,, " •I" • • •' 

.!, l r I ,,,. • , !: 

:It : • I 

,,.. I: 

SWORCCPP2018-000305
EXRIBIT B 

·.ARTICLE-TRANSFER OF CONTRIBUTIONS 

Section I. Purpose. A Pension is provided unde~ this Plan for Employees who would ~therwise lack suffi. cient service credit to be eligible for any pension because their' yenr:; of employment were dMded between different pension plans or, if eligible, whose pensio11 woulcl be less than the full amount because of such division

of employment. The provisions of t11is Article are operative only if both the Pro-Rata and Transfer of Contributions Exh[bits of the ,International Reciprocal Pension Agreement for Carpentei-s Pensioll Funds have been

adopted _by the signatory Fu11ds in. whose jurisdiction the Employee works, · . 

Section 2, Cooperating Pension Fund, By resolution duly adopted, the Board of Trustees recognizes nll other Pension Funds which hnve executed the United Brotherhood's neciprocal Pension Agreeme11t and whicl1

have adopted _Exhibits A ancl n tl1ereto, as ~ooperath1g :Pension Funds. 

-Section' 3. Home Pension Fund, Each Employee wllo h11s employer conbibutlons ma<le on his behalf to one

or more of the Cooperatin~ l'ension Funds shall have n "Home l'ension Fund", The following rules s11aII be used in determining an Employee's "Home l'ension Fund"'. 

(a)· II the Employee· is a member of a local unlo111 hls Home Pension Fund shall be that Cooperating :eension

Fund in which such local union pnrlicipates by virl:ue of a collective bargaintng agreement requiring

contributions thereto, 

(b) If the Employee is not a member of a local tmion, his Home Pension Fund shall be that Co.operating

Pension Fund to wl1ich the bulk of contributions have been made on his behalf in the last three (3) years.

(c) 'A co·operatlng Pension Fund other than one detenniued under subsection (a) or (b) shall be an Employee's Home Pension Fund if the Employee cim estnblish such Home Fund status to the satisfaction of

the Trustees of the two Cooperating Pension Funds. 

Section 4. Employee Authorization. If contributions n.re or wilf be made on an Employee's behalf to a

Coopernt!ng Fund signntory to Exhibit A and n of the United Brotherhood's Ileciprocal Pension Agreement

he mn.y, provided his Home Fund is also signatory to Ex:hibits A and D of said Agreement, £lie a request with the

Cooperating Fund that such contributions be transferi·e<l to his Home Fun<l on his behalf. Such request sl1all be made in writing on a form approved by the respective Funds which is signed and dated by the Employee. Said

request form sliall release the Boards of Tmstees of the 1 respective Funds from any liability or claim by an

Employee, or anyone claiming through him, that the tra1~sfer of contributions may not work to his best interest.

Said completed request form shall be Bled by the Employee with the Coopern!:ing Ft111d w1thln sixty (60) days

following the beginning of his emriloyment within tl1e Cooperating Fu11d's jurisdiction provided however that the

Board of Trustees of the Cooperating Fund may, at 11:s discretion, grant an extension of that sixty (60) clay pedocl

for special circumstances. 

lf the Employee does 11ot Rle a timely reques~ form with the Cooperating Fund, he will be treated as elect•

ing not to authorlze a transfer of contributions and the Pro•R:tta Pension provisions of the Cooperating Fund's

Plan sho.11 apply to the Employee, By filing a 1·equest fol' transfer of contributions, the Employee agrees that his

eligibility for benefits nnd all other participant rights are governed by _the terms ,?f the lJome FullC1's Pension

Plan and not by the terms of the Cooperating Fttnd'.s Pension Plan. 

Section 5, Transfer of Contributions, Upo11 receipt of a timely and properly compl!:lted request for a transfer of conl:ribt1t!o11s to the Employee's Home Fund, the Cooperating Fund shall collect and transfer to the

Employee's Home Fttnd the contributions required to be made to the Cooperating Fund on the Employee's

behalf. Said contributions shnll be forwarded to the Employee's Home Fu11d within ninety (90) calendar days

following the calendar mouth in which the contributions were receh'eu, Any undue delay in transferring contrilmtions shall be considered a violation of the United Brotherhood's Reoiprocnl Pension Agreement and subject

to its provisions for arbitration, The contributions so transferred sllll.Jl be accompanied by such records or re-

. ports ,vhlclt nre necessary or appropriate. The Cooperating Fnnd sha1! transfer_ the actual dollar amount of contributions received regardless of o.ny difference in the contribution rntes between the Funds. 

For purposes of this Section, in the event the local union in which an Employee holds or has applied for

memb1mh!p or which first represented such Employee participates in both a Local or District Council Pensior1

l)lan and the Carpenters Lnbor-Management Pension Plan, bol:h Plans shall be considered to be Home Pension 

SWORCCPP2018-000306
?lnns if they have adopted Exhibit A nncl Exhibit B of this Agreement and contributions shall be tr1msferred to 

mch Plans under a proportionate allocn!:ion determined according to the contribution rntes then in effect under 

mch Plans. However, in a situation iu which only one of such Home Plans has signed both Exhibit Aanc! Exhi~ 

btt B of this Agreement, tl1e amount forwarded to the !ooal Home Plan which has slgned Exhibit B shall be the 

proportionate share aliocated to such Funn taking into consideration foe total of the contributions to. that Fund 

1111d the Fm1d which is participating only in Exhibit A. The balance of the conti:ibut!ons not forwarded will be 

covered by the provisions of .Exhibit A of this Agreement, 

diction of a Cooperating Pension Func1 shall be counted a:s If they were worked in the jurisdiction of the Home

Section O. llrenks in Senrice. For the purpose of any break in service rule, any hours worked In the jmis­

.Section 7, Pnyment of l'ension. The pnyment of the pension shall be subject to the provisions of the Home

Pension Fund. . 

Pe11sion Fund's Plan, 

Section 8, Collection of Contributions. The Home Fund shall have 110 responsibility to take any action to 

enforce the terms of any collective bargaining agreement, or of any other agreement, requiring cont:rlbttt!ons 

,el'lforcing the terms of cDllective bnrgainh1g agreements and of other agreements requiring contributions thereto, 

to nt1y Cooperating Fund other than the Home Fund. Each Cooperating Fund shall be solely mponsib1e f(?r 

Section 9. Change in Home Pension Fund, It is recognized that situations will arise where nn Employee 

wlll change his Home Pension Fund becimse of a change ill residence, availability of work, or for other rensons. 

1n order. ~o .protect such an Employee to the fullest extent possible, while still providing safeguards against pos­

. sible ahuse, the following rules shall apply when an Employee wishes to change his Home Pension J!und: 

(a) An Employee must submit a request fol' a permanent change of Home Pension Fund to both his former 

Home Pension Fund and to the Pension Fund wltich he claims to be his new Home Pension Fund. 

(b) Such request must be on a form approved by the Trustees of the respective.Pension Funds and signed 

· by the Employee. 

(c) Such request must state the facts which the Employee claims support his request to change his Home 

Pension Fund. 

(d) No change in Ho:rne Pension Fund shall occur unless both Funds agree to the change, · 

on the £rst ctay of the month followtng the agreement by both Penslol} Funds. No assets shnll be transferred

If tbe Employee's request for a change in Home Fund is granted by both Funds, the change shall be eJfeeted 

t from the old Home Fund to the new Home Fund, Ratlier, the J?ro-nata Pension provisions of this Plan shall 

govern the Employee's rights under the old Home Fund. 

This Article, and the payment of pensions hereunder, shall be effective on 

Section 10. Effective Date, 

., 

SWORCCPP2018-000307
APPENDrxn

(CINCINNATI) 

I· •

UNIT.ED BROTHERHOOD OF CAUPENTEns AND JOINERS OF AME!UUl\ • 

INTERNATIONAL .BECl?ROCAL AG.l'\EEMENT FOR 

CARPENTERS PENSION FUNDS 

.to by Boards ofTrustees of Penslon Funds {slgnatory Fund or Funds) which provide retirement and pension 

Th.fa International Reclpi:ocal Agreement £or Carpenters Pension Funds (Reciprocal Agreernen!:) 1s entered 

enefits for employees (Employees) represented for the purpose of c:oUecl:iva bargaining by one or more Local 

:nions or Councils affiliated with the United Brotherhood o~ .Ca.rpent~rs and rqio.ers of America (Unlted 

· ' 

,roi:herhood), 

The Effective Date of this Reciprocal Agreement shall he, for ea.ch ·signatory Pension Fund, the do.te set 

l..greement and·such Effective Date shall have the signi.£lcanco set forth herlnafter,

orlh as the ''Effective Date" on the signature page

.

used by

. 

the 

. 

Fund to become a party to this, Rec!procalat least one .Employer and at lenst one Union Trustee of such Fund who a.re duly authorized to execute tbis 

This Reciprocal Agreement sliall be signed. on behalf of a Fund becofI}ing signatory to this Agreement by 

., 1•• •• 

Tho persons who.are from time to time acting·as Trustees of signatofy Pension Funds are sorneti1;11es referred 

Agreement for that Pension Fund; 

; 

·; 

I 

: ,·. · : If 4

· -~. . •t ! 

to in this Agreement as "Trustees". 

' .. ~ 

" ' •I ' 

WHEBEAS, the Trustees of each signatory Fund acting under separate Trust Agreements axe authorized

WITNESSETH: l 

and empowered to enter into this Reciprocal Agreement and to·i>rovide 'retirement nnd pension benefits to, em­

' 1 : ·• ' 1

•· .. • •· • • · · ' · 

p!oyees who !lre o:r have been represen~ed in collective bnrgninlng by Local Unions cir District Councils affilt~ted 

,!.. • · •·· :· ·.: .: ·i :• 

with the United Brotherhood; and · 

· WHEilEAS, many Ji:mployees have conl.:ributions·made'ip more than one signatory Pension F.unland as a 

'' ·" 

reduced pension benefits because yea.rs of service credit w'ere divided nmong signatmy Funds; arid 

consequence may not be eligible .for any pension beneRts from nny signatory fension Fund or may quatff,y for 

·WHEREAS, the Trustees ofsignatory Funds desire to·make provision for' continuity of pension coverage for 

• 1 1 • ··,, I 1 • •I· ,1··· ' . • ' ·., :· . such Employeest and 

WHEREAS, it is recognized .that some signatory Funds ha~e·,;eciprocal agreements b~eq,~n partial pen­

,. . 

sions or the transfer of contributions (money-follows-the~mah) and i.t'is further recognized that it is not the intent 

of this Agreement to modify, cnocet or nlfect such Agreements;- a.nd.,.. 

WHEREAS, the Trustees of each signatory Fund acknowledge that they httve amended thelr Plan 1n substan-• 

tinily the form of Exhibit A or Exhibit Aand Exhibit B attached hereto. (All signatory Pension Funds must adopt 

. ,1 • .

Exhibit Aproviding for partial pensions ru1d1 ii they pled to d? so, Exhibit B which provid~_ ~nt tbe J!'.u:nd will 

WHEREAS, each signatory Pension Fund is qualified as a tlU' exempt trust under the a.peroptiat~ provisions 

tr~nsfer moner, to other signatory Funds which hav~ .al~o a?.°P~tid Exhi?it B; 

' ••• : • 

of the Internal Revenue Service and is current17 operating in such a manner as to continue to be entitled to such 

· · • : • " 1

• • • " ·' • • 

WHETIEAS, the Trustees of 

· 

ench signatory Pension Fund deslre to implement' the amendments adopted 

exemption; S+ld 

pursuant to this Reciprocal Agreement and establish unifonn procedures to co.rry out the terms of this Reciprocal 

. . 

WHEREAS, the Trustees of eacl1 signatory Pension Fund executing this Agreement on behalf of their 

Agreement; and 

respective Pension Funds represent and warrant that they .have been duly authorized to make, execute and 

• ,. •· 

delivet this Agreement; · 

1 • 

NOW, Ti-IEREFOnE, Jn consideratio~ of the mutual promises, if: is mutually understood and ngreed 85 

·· follows: 

Section 1, Form of Agreements. The Trustees of euch signatory Pension Fuod must amend their Pension 

Plan to incorporate the article• attaclied hereto as Eiliibit A. Exhibit A provides for partial pensions based on 

service credit with two or more signatory l'ension Funds. I 

SWORCCPP2018-000308
Pension 

The 

Plan 

Trustees 

to incorporate 

or any signatory 

the a1ticie 

Pension Fund may, in ai:.ldiHon. to adopting Exhibit A, elect to am~nd their

attached hereto as Exhibit B; such election to be indicated on the signaExbibit 

ture page 

B as 

of 

well 

this Reciprocal 

as Exhibit 

Agreement. 

A, Exhibit 

As between two signatory Pension Funds which have both adopted

which has ndopted Exhibit l3 ns well 

B shall govern, As between two signatory Pension Funds only one of

es Exhibit A, Exhibit A shall govern.

· Section .2, necognitron. Each signatory Pension Fund1 

me11t, recognizes each other 

for the period it is bound by this Reciprocal Agreesignnto1y Pensiop Fund as a ."Related" an~l/or "Cooperating" Fund to the extent t11at

sucl1 Fund has adopted one or both of the A1:ticles attached hereto as E~bit A and Exhibit B.

strued 

Secti~n 

as interfering 

3, Effect 

with 

on Other 

or affecting 

Reciprocal Agreements. This Reciprocal A'.greement shall in no way be consignntory Pension Ftm<l or any Reolprocal 

any 

Agreement 

Reciprocal Agreement between a slgnntory :Pension Fund and 11 nonCooperating :Plans covered under 

between signatory Pension Funds, unless the Related or

Agreement and agree. 

their own Reciprocal Agreement mutually agree to cllscontinue their Reciprocal

to be covered under this Reciprocal Agreement. • .

signatory 

:Siiction 

Pension 

4. Cooperation, 

Funds requires 

The 

that 

effective administration of this Reciprocal Agreement by the Trustees of the

persons covered by such Fund, the 

each Fund exchange information with respect to the credited servh:e of

p~an.of. benefits provided by such Fund. 

status 

The 

of pensions paid from time to time by such Fund and the· details of the

exchange of relevant infonnation and 

Trustees of each signatory Pension Fund agree to cooperate in the

documents to permit implementation of tb,e pension provisions in the atreasonable 

tached Exhibit 

written 

A or 

request 

Exbibits 

by 

A 

another 

and E. Each signatory l?ension Fund shall comply witliln thirty (30) qays with any

purposes of this Rectprocal Agreement. 

sigtrntory Pension Fund for information or data necessill}' to carry out the

·

except 

. Sec!ion 5.. ~o Change in Exhibit A or Exhibit B. The Trustees of each signatory Pension Fund agree that,

Articles 

,as 

attached 

he1·eillafter 

hereto 

provided 

as Exhibit 

in Section 

A 

12 hereof, no substantive change shall be made in the provisions of the

Pension Plan which w01.1ld have the 

or Exhibit B, either by change of language or by any modi.Boation of the

agreed that the only way a signatory 

effect of changing the provisions of Exliibit A or Exhibit B. It is further

Exhibit Dis to follow the termination 

Pension Fund can terminate the operation of .the prov:lsions of Exhibit Aor

provJsions of this Redprocal Agreement set forth in Section 9 hereof.

Section ?· Effective Date. •The date this Reciprocal Agreement becomes operative as to any slgno.tory Pen­

. sion 

comes 

Fund 

operntive.as 

shall be 

between 

the date 

two 

shown 

signatory 

as the "EITective Date'; on the signature page. The date this Agreement beare the samo E.!fect:lve Date or the later 

Pensio? Funds shall be the Effective Date of ·each such Fund if they

of the two Effective Dates if they are not the some,

Applications 

This Reciprocal 

previously 

Agreement 

denied 

sha11 

by 

be enforced for pension applications made on-and after the Effective Date,

affected l'lans.

nny of the signatory Plans may be reconsidered upon the approval of all

. 

Secticm 7. Duration of Tieciprocnl

. 

Agreement. This Reciprocal Agreement shall first be operative wben at

iea:st 

as signatories, 

two Pension Funds become signatories and shnll· conthme' so long as two or more Pension'·Funds con!:inU\l

•.

date 

Section 

of execution 

8. Central 

of this 

Filing 

Reciprocal 

of Reoiprocul 

Agreement, 

Agreements and Relntecl Documents. Within ten (10) days from the

signed copy with the following: 

each '.Pension Fund which becomes a signatory fund shall file a

General :President

United :Brotherhood of Carpenters and Joiners of America

101 Constitution Avenue} N.W.

Washington, l). C. 20001

. .

but 

. 

at 

It 

least

is undorstood 

_annually, 

that the General President of the United Brotl1erhood will cause to be publis~ed periodically,

addresses which nave 

in 

become 

the official publication of the United Brotherhood a list of all Pension Funds and !:heir

the filing of a copy of such Agreements 

and remaiin parties to this .neclprocal Agreement. The iisting will be basml on

tion of participation in this Reciprocal Agreement 

as provided in tbis section and based on the £ling of notices of tenninans 1metofore provided. 

SWORCCPP2018-000309
Section 9. Terminnfiou, Any' of the sig11atory Pension Funds may terminate this- Reciprocal Agreement by 

giving written. 11otlce by certiiled.mail to the Genernl Presit1ent of the United Brotherhood at least llinety (90) 

days in advance of the date such tenninatio~ is dl:sl.red. , . 

Section 10, Arbitration, Any dispute, contr.oversy or olnim arising out of or relating to tbe'appUcation 0£ this 

Agree.tnent between signatory Plans shnll be settled by arbltration. Any signatory Plllll whkh disagrees with the 

notion taken by another :Plan under this Agreement may request iu-bitraf:ion by filing a written notice wiffi such 

Plan by certlflecl mail with a copy to the United Brotherhood, If the Trustees of !:he Plans involved cannot agree 

upon an arbitrator within thirty days, application shall be made to the American Arbitration Association·tor the 

selection of an. arbitrator. The general expenses of the arbitration, if nnyt shall be home eq_ua1ly by, l:h~

' · 

parties 

· · to the arbitration, 

Judgment on any award rendered sl1all be binding ·on the parties and may he enterecl in any courl:· havfng 

• I I,

jurisdiction, 

Section 11, Separnt:e Liability, 

(a) It 1s expressly understood and agreed that none of the signatory' Funds assumes iiny of t:be llabflities or 

obligatlom of tbe other signatory Fund.s. ·Each sign!ltory Fund shall be liable solely and exclusively for pension 

benefits due under its own pension fund, n.nd 110 Fund shall be liable for the acts or omissions of another Fund. 

(b) The Trustees of each signatory Fund shall be fully protected in acting upon· any instrument,' certillcnte, · 

report or paper believed by them to- be genuine, and p;ie Trustees or each signatory Fund she.II be under no duty · 

to make any investigation or inquiry as to any statement in any such writing, .f?r as to the authority. 0£ the.pension making such statement, but may accept the same as conclusive evidence of the acotiracy of the statement 

I I .... • • • • ,. f •• contained therein a.ud the authority to mnke it. • 

:President of the United Erotberhood. Proposed amendments may be submitted by tbe, Uniteq }Jrother~ood., to

Section 12. Amendment. Proposals for mnendment of this Agreement may be submitted to the General 

the affiliated Funds for a vote. Aproposed amendment will be deemed adopted if approved by a two-thirds (%) 

vote of all signatory Funds voting withip the time prescribed by the General President of the United Brotherhood.• . •I 

·S~ctfon rn. Jurisdiction. This Agreement shall be construed and enforced according to the laws of !:he Dis:· 

trict of Columbia and the Trustees of the signatory funds shall be liable to account with respect to' this Agreement, and any rights and duties thereunder, only in the courts of the District of Columbia. However, a dlspute 

between a Parttcipant and a specific signatory Fu11d shnll be subject to the provision~ of the Employee Retirement Income Security Act of 1974 (ERISA). 

Section 14. Amendment of :Pinn Docurpen.~. Each signatqxy Fund agrees to make the necessary amendments 

to

• 

its Pension Plan doournents1 and other legal documents which may be required, in orcler to implement the pro-

·· visions of this Agreement. 

., 

SWORCCPP2018-000310
· SIGNATUllE PAGE . 

• l •• 

IN WITNESS WHEREOF tl1e Pension Fund named Qelow by the signatures'of ils duly authorlzed Trustees 

hereby becomes a party to this Reciprocal Agreement and agrees to be bound by its terms and provisions, It is 

understood thnt each Fund which.becomes or Is signatory fo this Reciprocal Agreement Is entering this Agreement with ench other signatory. Fund. 

The Effective Dnte for the foliowlng Pension Fund shall be' the __ day of ________ 19_·_ 

.Please check one: ·. 

This Fund hns ndoptecl Exlubjt A only-·-----------!.~-----.!--------------------------------------- ( ) 

This Fund has ndopted botl1 Exhibit A and Exhibit B ----·--------------..:--~.----~--..: ________________ ( 0 

(Note: Exhibit A must be ·adopted by nil Funds and provides for partlal pensions. Exhibit B should ·only be 

. . , adopted by.Funds that want to, transfer contributiotis to other Funds that hove adopted Exhibit B.) It •••>' 

Pension Fund Name:------~-------------.--,---------

Penslon·Fund Address: ______________________________,_ 

· Pension F11nd Telephone Number: _________________________ 

Name of Person to Contact: ___________________________ 

' I 

SWORCCPP2018-000311 
.. • •' •••, ........ • ,t 

SIGNATURE PAGE (continued) 

COMPLETE DELOW IF AP.PUCABLE 

·It is understood and agreed thnt this Reciprocal Agreement shn.ll not make void, chnng~ or replace a Reciprocal Agreement entered into by this signatory Pension Fund with the following Pension Fund(s) whose nru;nes and 

· ' 

nddresses are listed. below: 

.. ' 

. . lt is further understood that the signatory Pension Fund n~ed below shall notify the United Brotl1erhood in 

writing of nny additiona} 11.eclprooa~ Agreements to whi~1 such signp.tory Fund becomes party antl which shall 

take precedence over this Reclproco.l Agreeme11t, It is also further understood that such signatory Pension Fund 

shall notify the United :Brotherhood 0£ tl1e canc:ellaUon of n11y Reclpro7al Agreements to which· ~uoh·signatory 

" 

· · · · Fund was a party. 

,.. • i 

.. '~-

NJUne of 511.no.lory l'en•lon Fund 

..

', 

Slgn•l1>re ol Aud,orlz•d Union Tru•I•• 

I 'I 

.. 

'i .I 

.. ,t fl 

SWORCCPP2018-000312
....i,:••.• Emrnrr A,, 

: IARTIG:LE'-:PARTIAL PENSIONS: 

. Section 1•. Purpose. : Partial Pensions shall be provided under this Agreement for Employees who otherwise 

laok sufficient pension credit to be eligible for any pension because theh' years. of employment were divided be~ 

tween different participating pension plan's or, if eligible, whose pensions would be less than the full amount 

because of such division of employment. · 

Seotion 2, Related Pension Credtts. For purposes of this Agreement the term "Pension Credits' shall mean 

those periods of sorvice during which credit is granted for be11e.flt accrual purposes. Pension Credit shall not necessarlly cover pedods for which a Plan grants credit for vesting purposes under ERISA. Pension Credits accumulnted and maintained by ru1 Employee under one of the Pla11S signatory to this Agreement shall be recognized 

under this Agreement by the other signatory Plans as Related Pension Credits. Pension Credits under each .Plan 

· shall be based on the ru1es in effect in that Plan at the time the employment occurred, · 

Se<ition 3. Combined Pension Crecllt, The Pension .Credit granted under each of the Plans signatory to tl1Is 

Agreement together comprise the Employee's Combined Pension Credit. In no case will more than one year of 

Pension Credit be counted for any twelve consecutive calendar months, 

· If the Employee hns, in a calendar year, workecl under two or more Plans and accumulated fractional years 

of Pension Credit which together add up to more than .one·year of credit for that calendar year; then the Pension 

Credit recognized undel' thls Agreement shall be limited to one year. Pension Credit will fust be counted under 

the l'lan whlch provides the highest benefit accrual rate, The other Plan(s) shall count as Pension C:redit the necessa1y fractional year(s), in a declining benefit accl1lal rate order, which will bring the total to exactly Olle year 

of Pension Credit for the Emp!oyee, 

Section 4. Trnnsfer of Contributions. Notwithstanding any other provisions of this mticle to the contrary 

an Employee whose ffome Pension Fund is a signatory to Exhibit B of this _Reciprocal Agreement and who works 

under the:jurisdiotion' of and·ba.s contributions·made' td a Pe~sioh Fund signatory only to E;xhibit A of this 

Reciprocal Agreement shall have·such contributions· forwarded to his Home Pension Fund: • ,, ; I••• • •,. • 1 l ., :,,n,,. ,,,,... • ,, • ' 

(a). if during any' calendar year such Employee, does not earn some Pension Credit under the Pension Fund 

signatory only to Exhibit A of this Reciprocal Agreement, and · , 1 

(b) if nt the end of any three ca!endnx year period such Employee has not earned a total of at least one year 

of Pension Credit in a Pension Fund signatory only to Exhibit A of this Reciprocal Agreement such contributlons· wm be sent to his Hol!le Fund. .. 

Section 5. Eligibility for Bene.Hts, An Employee shall be eligible for a Partial Pen~ion if he satisfies a.11 of 

the .following reg_uireroents: · 

(a) He would be eligible for any type of pension unde:r the Plan if his Combined Pension Credit were 

· treated as credit under that Plan; and 

(b) He has, under several of the signatory plans,· at least one yco.r of Pension Credit since January !, 195S; 

and · . ., , · . . (c) In the case of an Employee applying for a pension based on disabllity, he is able to meet the definition 

of disability in each of the signatory Plans, or in the case of an Employee a1Jp1ying for a pension based 

on age, he meets the minimum age requirement in each of the signatory I'lan11 which will be paying 

l'artial .Pensions1 and 

(d) At least two l'lans will actually be paying a Partial Pension under the terms of tWs Reciprocal 

Agreement, 

Section 6, Election of Pension. If an Employee is eligible for more than one type of pension or optional 

. form of beneflt under the signntozy Plnns, he shall be entitled to elect the type and form, of pension he ls to 

receive from each Plan. 

Section 7. Pnrlinl Pension Amount, The amount of the Partial Pension payable by each signatory Plan 

under which an Employee qnalifles for a pension shall be the benefit amount he accrued under that Plan during 

the period he earned Pension Credit under that Plan. 

SWORCCPP2018-000313
' ..

Section 8. :Payment of Pnrtinl Pensions, The ·payment of a Partial Pension shall be rnbject to all of the conditions contained in the signatory Plans applicable to other types of pensions. I£ a Partial Pension is suspended 

by one :Plan, it may be suspended by other Plan(s). Any Plan suspendlng a pensioner's benefit shall notify all 

other affected Plans. 

Section 9 Other :Benelits. The obligatlo11 of each of the Plans signatory to this Agr.eement is limited to·pension benefits, including survivor's peosions after retirement payable as a result of elecl:fon of a Husband and WHe 

Pension 01· guatsnteed period payments, This Agreement shall not apply to nny pre-retirement death .or survivors' bene.Sts. Other beneflts provlcled by any of the Plans after retire~ent such as lump sum d~ath benefits, 

level income or lump sum optloos, health benefits, etc., are not covered by this Agreement, However, nothing in 

this Agreement sball prohibit any Pla11 from provid!ng such beneflts ln accordance with its own rules and 

, · · .regulations. 

Section l,O, l3ene11t Increnses. ·After· an Employee leaves the jurisdiction of one of the signatory Plans the 

benefit level in that Plan may be later increased. 'BeneBts from that Plan may be.computed nt the beneflt level 

in e.Efect at the time the Participant last earned Pe'nsiou Credit under that Plan, or the level ab.,the tlme the 

.. · 11 \.i ....,.. . pension is effective, at the. option of each Plan. ' 

Section 11. .Appl!cntion :Proced1,u:e. The Plan u11der which an Employee fust makes application for b~nefits 

shall initiate the processing of a Partial Pension with the other signatory Plans,bnsed. upon the information supplied by the Employee as to where he worked. Each Plan agrees to provide the other Plans with complete data, 

certified· by an authorized Administrator or Plan employee, in order ~o process l'a.rt!al Pensions promptly under 

,. 1 this -Agreement. 

In applying tbe titles of each Plan 'with respect to cancellation of Pension 

Section 1~ Brenks hi Service. 

Credit, any Pension Credit earned. during a period in whtch the.Employee worked in the ·jurisdiction of another 

signatory Plan shall be consid~red when detennining whether there has, been a permanent break in service. 

I I •: 

' ,, .\ ' ... ,. .... 

• I : ~ ,,.. 

... .. 

·.,.,:. 

.

.·,. 1, ·:' 

;, ~ I • ' 

.'" a•• . :•,. ,. ,. I 

. ,. 

I t• ••' :• ,: 1• IIO:i1,' .

• I • I I ti : .;• •• I • t,, ., •• 

l' •• •t• 1 • ,!

...... t, .! .. 

:r, i •, 

. ~ ; t. 11'' 

I:. I• 

SWORCCPP2018-000314
EXHlBlT J3 

·.ARTICLE-TRANSFER OF CONTRIBUTIONS 

Seoti~n 1. Purpose. A Pension is provided under this Plan for Employees who W;ttld otherwise laok suffi.

cient service credit to .be eligible for any pension because their'yenr$ of emp1oy,li1ent were divided between dif­ ferent pension plans or, if eligible, whose pensio11 wonlc1 be less than the full amount because of such division

of employment, The provisions of this Article are opernHve only if both the Pro-Rata and Transfer of Contributions .Exhibits of the ,International Reciprocal Pension Agreement for Carpenters Pension Funds have been

adopted by the signatory Funds in. who~e jurisdiction the Employee works. · 

Section .2, Coopernting Pension Fund, By resolution duly adopted, the Board of Trustees recognizes all

other :Pension Funds which have executed the Unite<l Brotherhood's Reo!proonl Pensi011 Agreement nnd whicli

have adopted .

Exhibits A and D tl1ereto, a.s .

Cooperath,g Pension Funds, · 

· Seotion'8, Home l'ension Fund, Ea.ch Employee who has employer conb.ibutfons mac.le 011 his behalf to one

or more of the Cooperating Pension Funds shall have n "Home Pension Fund", The following rules shall be used

in determining an Em_ployee's "Home Pension Fund", 

(a)· If the Employee is a member of a. local union1 hls Home Pension Fund shall be that Cooperating Pe11slon

·· Fund m which such local union participates by virtue of a collective bargaining agreement requiring

· contributions therel:o, 

(b) If the Employee is not a member of a local union, his Home Pension Fund shall be that Cooperating

· 1 Pension Fund to which the bulk of contributions have been made on his behalf in the last three (8) years.

(c) 'A Cooperating .Pension Fund other than one determined under subsection {a) or (b) shall be an Employee's Horne Pension Fund if the Employee can establish srich Home Fund status to the satisfaction of

the Trustees of the two Cooperating Pension Funds. · 

Section 4. Employee Authorizntion. If contributions are or will be made on nn Employee's behalf to 11 Cooperating Fund signntory to Exhibit A and J3 of the United Brotherhood's Ileciprocnl Pension Agrecmenl:

he may, provided his Home Fund is also signntory to Exhibits Aand B of said Agreement, flle a request with the

Cooperating Fund that such contributions be transferred to his Home Funcl on his behalf, Such request shall be

·made in writing on a form approved by the respective Funds which is signed and dated b)' the Employee. Sahl

request foim shall release \he Boards of Tmstees of the 1respective Funds from any liability or claim by an

Employee, or anyo11e claiming through him, that tlie transfer of contributions may not work to hls best interest.

Said completed request form shall be .filed by tl1e Employee with the Cooperating Fund within sixty (60) days

following the beginning of his employment within tl1e Cooperating Fund's jurisdiction provitled however that the

Board of Tmstees of the Cooperatillg Fund may, at its discretion, grnnt an extension of that sixty {60) day period for S,IJBcial ciroumsta11ces. 

If the Employee does 11ot file a timely request form with the Cooperating Fund, he will be treated as elect­ ing not to authorize a transfer of contributions and the Prc-R~ta Pension provisions of the Cooperating Fund's

Plan shall apply to the Employee,. By flllng a request for transfer of co11tributlons1 the Employee agrees that his

eligibility for benefits and all other participant rights are governed by .the tenns .~f the t-Iome Fund's Pe11siot1 l'lan and not by the terms of the Cooperating Fund's Pension Plan. .. 

Section S, Transfer of Contributions, Upon receipt of a timely and properiy completed request for a transfer of contri!mtions to the Employee's Home Fund, the Cooperating Fund· slinll collect and transfer to the Employee's Home Fund the contributions required to be made to the Cooperating Fund on the Employee's

behalf, Sa!cl contributions sha.11 be forwarded to the Employee's Home Fund within nh1ety (90) calendar days

following the calendar month in which the contributions were rec.-ejyed. Any undue delay in transferring oon~

hihutlons shall be considered a violation of the United Brotherhood's Reciprocal Pension Agreement and subject

to its I?rovisions for arbitration. The oontributions so transferred shall be accompanied by such records or re~

ports which are necessary or oppropriate, The Cooperating Fnncl shall transfer, the actual dollar amount of c.ontributions received regardless of any difference hl the c011tribution rntes between the Funds. 

For purposes of this Section, in the event the local union in which an Employee holds or has •applied for

membership or whlch first represented such Employee participates Jn both a Local or District Council Pension

Plan nnd the Carpenters Labor-Management l'ension Plan, both Plans shall be considered to be Home Pension 

SWORCCPP2018-000315
.)}ans If they have ado]?ted Exhibit A and Exhibit B of this Agreement and contributions shllll be b:'nn~ferrecl to 

:uch Plans under a proportionate allocation detennined according to the contribution rates then in el!ect under 

ruch Plans, However, In.a situation in which only one of such Home Plans has signed both Exhibit Aancl Exhi1,it B of this Agreement, the amo\lnt forwarded to the local Home Plan which has signed Exhibit B shall be the 

proJ?ortionnte share allocated to such Ftrnd t11king into consideration the total of-the contributions to that Fun'd 

n.nd the Fund which is participating only in Exhibit A. The balance of tbe contributions not forwarded will be 

covered by the provisions of Exhibit A of this Agreement, 

Section 6. Breaks in Service, For the purpose of any break in service rule, any hours worked in the jurisdiction of o. Cooperating Pension Fuml shall be co\\nted as if they were worked in the jurisdiction of the Home 

Pension Fund. 

Section 7. Pnyment of Pension, The payment of the pension sball be subject to the provisions of the Home 

Pension Fund's Plan. 

Section 8, Collection of Contributions, The Home Fund shall have no resrionslbility to take any action to 

enforce the terms of any collective bargaining agreement, or of any other agreement. requiring contributions 

to a11y Cooperating Fund other thnn the Home Fund, Each Cooperating Fund shall be solely respdnsible for 

enforcing tbe terms of collective bo.rgo.ini!lg agreements and of other agreements requiring contributions thereto. 

Seclion· 9. Cbonge in Home :Pension Fund. ' . It is recognized tbat situations will arise where an Employee 

will obange his Horne l'tmslon Fund because of a change in residence, avaHability of work, or for other reasons. 

1n order to protect such nn Employee to the fo1lest extent possible, while sti11 providing safeguards against possible nhuse, the following rules shall apply when an Employee wishes to change his Home Pension Fund: 

(a) An Employee must submit a request fo1· a pe1manent change of Home Pension Fund to both- his former 

Home Fension Fund and to foe Pension Fund which he claims to be his new Home Pension Fund. 

(b) Such request must be on a form appl'oveu by the Trustees of the respective Pension Funds and signed 

by the Employee. 

(c) Sucb request m11st state the facts wbicl1 the Employee claims support his request to cbo.nge his :Home 

· "Pension Fund. 

(d) No change in Home 'Pension Fund shall occur unless both Funds agree to the change. · 

If the Employee's request for n change in Home Fund is granted by both Funds, the change shall be effected 

on the first day of the month following the agreement by both l'ensioq Funds. No assets shall be transferred 

from the old Home Fund to the new Home Fund, Ratlm·, the Pro-Ra.ta Pension provisions of this Plan shaU 

i 

govern the Employee's r.igbts under the old Home Fund. 

This Article, and the payment of pensions hereunder, shall be elfeclive on

Section 10, Effective Dnte, 

', 

SWORCCPP2018-000316
SECOND AMENDMENT TO THE 

SOUTHWEST omo REGIONAL COUNCIL OF CARPENTERS 

PENSION PLAN 

Re: Clarification of Earliest Retirement Age and Elimination ofTrade Disability 

THIS AMENDMENT TO THE SOUTHWEST OHIO REGIONAL COUNCIL OF 

CARPENTERS PENSION PLAN ("Amendment") is adopted on this 7ttJ day ofJune, 2018 by the Board 

ofTrnstees of the Southwest Ohio Regional Council ofCarpenters Penston Plan ("Board ofTrustees"). 

WHEREAS, the Board of Trustees sponsor and maintain the Southwest Ohio Regional 

Council of Carpenters Pension Plan, as amended to date (the "Plan"), for the benefit of those 

employees who are eligible thereunder; and 

WHEREAS, the Plan provides that, subject to the provisions thereof, the Board of 

Trustees may amend the tem1s ofthe Plan in any manner; 

NOW THEREFORE, effective as of the date set forth above, the Board of Trustees 

hereby amends the Plan as follows: 

1. Effective August 1, 2018, Section 1.15 is hereby restated in its. entirety as follows: 

Section 1.15-Early Retirement Date 

"Early Retirement Date" means the first day of any month prior to 

the Normal Retirement date as of which the Participant attains the 

age of at least 55 years and has completed at least five Years of 

Vesting Service. 

2. Effective August 1, 2018, Section I .37 is hereby restated in its entirety as follows: 

Section 1.37 -Total and Permanent Disability 

"Total and Permanent Disability" means that the person has been 

determined by the Social Security Administration to be totally and 

permanently disabled and entitled to a disability benefit under the 

Old Age and Survivors Disability Insurance (OASDJ) program. 

3. Effective August I, 2018, Section 1.38 is hereby restated in its entirety as follows: 

Section 1.38 - Trade Disability 

"Trade Disability" means that based on medical evidence 

satisfactory to the Board of Trustees a person is m1able, as a result 

ofbodily injury or disease, to perform any ofthe work described in 

the Collective Bargaining Agreement for the remainder of his or 

her life. Effective August 1~ 2018, the Plan no longer provides for 

a benefit for Trade Disability. 

SWORCCPP2018-000317 
4. Effective August 1, 2018, Section 3.4 is hereby restated in its 

entirety as follows: 

Section 3.4 - Disability Retirement Benefit 

A Participant who has at least five Years of Vesting Service, who 

is not eligible for a Normal Retirement Benefit, who incurs a Total 

and Permanent Disability p1for to Ju]y 1, 2010 and on whose 

behalf Employer contributions were made during the 12-month 

period immediately preceding the date of his or her Total and 

Permanent Disability is entitled to a Total and Permanent 

Disability Retirement Benefit equal to the sum ofthe following: 

(a) the benefit such person had accrued in the Southwest Ohio 

District Council of Carpenters Pension Plan-Cincinnati, in 

the Southwest Ohio District Council of Carpenters -

Dayton Pension Plan, or both, at December 31, l 998, and 

(b) $99 per Year of Credited Service through December 31, 

2001, $80 per Year of Credited Service through May 31, 

2003, and $50 per Year ofCredited Service thereafter. 

A Participant who has at least five Years of Vesting Service, who 

is not eligible for an Early Retirement Benefit, who incurs a Total 

and Permanent Disability on or after July 1, 2010 and on whose 

behalf Employer contributions were made during the 12-month 

period immediately preceding the date of his or her Total and 

Permanent Disability is entitled to a Total and Permanent 

Disability Retirement Benefit equal to the sum ofthe following: 

(a) the benefit such person had accrued in the Southwest Ohio 

District Council of Carpenters Pension Plan-Cincinnati, in 

the Southwest Ohio District Council of Carpenters -

Dayton Pension Plan, or both, at December 31, 1998, and 

(b) $99 per Year of Credited Service through December 31, 

2001, $80 per Year of Credited Service through May 31, 

2003, and $50 per Year ofCredited Service thereafter. 

Such sum shall be reduced based on actuarial equivalent reductions 

from the Participant's Normal Retirement Date. 

A Participant who has at least five Years of Vesting Service, who 

is not eligible for an Early Retirement Benefit, who incurs a Total 

and Permanent Disability on or after July 1, 2010 and on whose 

SWORCCPP2018-000318 
behalf Employer contributions were made during the 12-month 

period immediately preceding the date of his or her Total and 

Permanent Disability is entitled to a Total and Permanent 

Disability Retirement Benefit equal to the Participant's Early 

Retirement Benefit determined under Section 3.2. 

The Total and Pe1manent Disability Retirement Benefit shall 

commence as of the first day of the month coincident with or next 

following the date the disability occurred, as determined by the 

Social Security Administration. 

However, if a Participant applying for the Total and Permanent 

Disability Retirement Benefit is also eligible for an Early 

Retirement B~nefit, such person may elect to have the Early 

Retirement Benefit commence as provided .in section 3.3. In such 

event, if the Participant is subsequently dete1mined to be eligible 

for the Total and Permanent Disability Retirement Benefit, his or 

her future monthly retirement benefit shall be adjusted tp reflect 

the amount of the Total and Permanent Disability Retirement 

Benefit, and a lump sum payment equal to the product of (a) the 

difference. between the monthly amount of the Total and 

Permanent Disability Retirement Benefit and the Early Retirement 

Benefit and (b) the number of months for which the Early 

Retirement Benefit was paid, shall be paid to such person. 

5. Effective August 1, 2018, Section 3.5 is hereby restated in its entirety as follows: 

Section 3,5 - Determination of Eligibility for Disability 

Retirement Benefit 

A determination by the Social Security Administration that the 

applicant is totally and permanently disabled and entitled to a 

disability benefit under the Old Age and Survivors Disability 

Insurance (OASDI) program shall constitute Total and Pe1manent 

Disability under the Plan. The Board of Trustees may periodically 

require that the applicant submit to a certification that the 

applicant1s award under the OASDI program continues as the 

Board ofTrustees may direct. Failure to so submit or provide shall 

be a basis for suspension or termination ofsuch benefit. 

Upon the attainment of age 62, a Participant receiving the 

Disability Retirement Benefit shall not be required to submit 

continuing proofofdisability. 

SWORCCPP2018-000319 
6. Effective August 1, 2018, Section 3.6 is hereby restated in its entirety as follows: 

Section 3.6 - Cessation of Disability Retirement Benefit 

Any Participant receiving the Disability Retirement Benefit who 

subsequently ceases to be totally and permanently disabled may 

apply for an Early Retirement Benefit (provided such person is 

eligible therefore), in which case the Early Retirement Benefit 

shall become payable for the month immediately following the 

month in which the Disability Retirement Benefit terminates. 

Furthermore, the Disability Retirement Benefit shall cease with the 

payment due for the month immediately preceding the Participant's 

Normal Retirement Date, as of which he or she shall be deemed 

eligible for the Normal Retirement Benefit. 

In all other respects, the provisions ofthe Plan shall remain in full force and effect. 

[the remaining portion ofpage is intentionally blank] 

SWORCCPP2018-000320 
IN WITNESS WHEREOF, this Amendment has been executed by the undersigned 

authorized representative as ofthis ?1hday ofJune, 2018. 

BOARD OF TRUSTEES OF THE 

SOUTHWEST omo REGIONAL COUNCIL 

OF CARPENTERS PE ION PLAN 

SWORCCPP2018-000321 
 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 37.3 

The most recent Summary Plan Description, dated January 1, 2017, and a copy of the Notice of 

Adjustable Benefits Reduction/Summary of Material Modifications dated June 29, 2018. 

Document #37.3 

SWORCCPP2018-000322
SUMMARY PLAN DESCRfPTION 

SOUTHWEST OHIO REGIONAL COUNCIL OF CARPENTERS 

PENSION PLAN 

As of January 11 2017 

SWORCCPP2018-000323
TABLE OF CONTENTS 

Page 

QUESTIONS AND ANSWERS ABOUT THE SOUTHWEST OHIO 4 

REGIONAL COUNCIL OF CARPENTERS PENSION PLAN 4 

EUGlBILITY FOR PARTICIPATION: 4 

1. Who is eltgib!e to participate in the Plan? 4 

2. When wilt I become a partidpant in the P!an? 4 

3. Do l have to sign anything to 1oln the Plan? 4 

4. What Is Covered Employment? 4 

5. What is an Hour of Service? 5 

CREDITED SERVICE: 5 

1. What is Credited Service? 5 

VESTING: 6 

1. What does it mean to be vested in my pension benefit? 6 

2. How do I become vested? 6 

3, What is a Year of Vesting Service? 6 

RECIPROCITY; 7 

i. Whal If i work for a contributing employer outside the jutisdicfion of this Plan? 7 

2. How do I know if a reciprocity agreement ls in effect between the Southwest Ohio Regional 

Council of Carpenters Penslo11 Plan and the plan of the Local Union in the area where 1am 

working? 7 

LOSS OF PENSION BENEFITS: 7 

1, Is it possible for me to ever lose my Credited Service and my Vesting Service? 7 

RETIREMENT BENEFITS: 8 

i. When can I retlre under the Plan? 8 

2. If I retlre on my Normal Retirement Age, how much will my benefit be? g 

3. Do l have to retire at my Normal Retirement Age? iO 

4. What will my benefit be If t continue to work past my Normal Retirement Age? 10 

5, Wnat will my benefit be if l retire before my Normal Retirement Age? 1 0 

6.. Is there a maximum benefit under the Plan? 11 

7. What about Social Security benefits? 11 

8, Do ! pay taxes on my pension? 11 

SUSPENSION OF Bf:NEFITS RULES: 11 

1. What happens if l retire and then go back to work? 1i 

2. What should l do if l declde to return lo work after l retire? 13 

3, What must l do to star! my monthly pension .again after I stop working? 14 

4. What will happen if I receive pension benefits for a month In Which they should have been 

suspended? 14 

5. How can I find out more about the suspension of benefits rules? 14 

FORM OF PENSION PAYMENTS: 15 

1. In what form will my retirement pension be paid? 15 

2. What other forms of payment are offered under the Plan? 15 

3. If I elect to receive my benefit in the form of a Joint and Survivor Annulty, how wm my monthly 

pension be calculated? 15 

4. How is fhe Slr1gle Life Annuity with a 10 Year Certain Payment calculated? 18 

5. Can l receive my pension beneffls In a lump sum distribution? 19 

SWORCCPP2018-000324
TOTAL AND PERMANENT DISABILITY RETIREMENT: 19 

i. Are there any benefits payable if I become totally and permanently disabled? 19 

2. What is meant by "Tota! and Permanent Dl$-abillty?" 19 

3. If I am eligible for Tota! and Permanent Disability, what will be the amount of my benefit? 19 

4, How do I apply for a Total and Permanent Disability Retirement benefit? 20 

5. When wm my Total and Permanent Disability pension slart? 20 

6, Can l start receiVlng Early Retirement Benefits while waifing for a disability award? 20 

7, What happens If I recover from my Total and Permanent Disability? 20 

DISABLED FROM THE TRADE BENEFITS: 21 

1. Does tho Plan provide benefits if i can no longer work as a carpenter? 2·1 

2. What type of medical evidence will be requlred for a determination of Disabled From The Trade 

Benefits? 2·1 

3. What ls the amount of the Disabled From The Trade Benefit? 22 

4. When wlU my Disabled From The Trade Benefits start? 22 

5. What happens If I start receiving a Olsablcd From Tho Trade Benefit and later receive a Total and 

Permanen! Disabllfty award from the Social Security Administration? 22 

6. Oan my Disabled From The Trade Benefits be suspended? 22 

7. If my Disabled From The Trade Benefits are suspended, how can J again apply for benefits? 23 

8. What happens if I recover from my d!sabl!ity? 23 

DEATH BENEFITS; 23 

1. What if l die before I retire? 23 

2. Are ihere any benefits payable upon my death when I die after I retire? 24 

3. How do I designate my beneficiary? 24 

4. May I designate someone other than my spouse to receive the death benefits payable under the 

~~ ~ 

5. What if I die before my Normal Retirement Age while I am receiving a monthly disability benefit?24 

TERMINATION OF BENEFITS: 25 

1. Will ! be entitled to any benefits if I stop working in Covered Employment before my early 

retirement /ilge? 25 

PROVISIONS RELATING TO VETERANS' REEMPLOYMENT: 26 

1. What happens to my benefits under the Plan If I enter military service? 25 

APPLICATION FOR 13ENEFITS, CLAIMS PROCEDURES AND APPEALS PROCESS: 26 

1. How do l apply for Pension Benefits? 26 

2. When will I be notified aboltt the status of my appHcaUon for benefits and whal Information will ! 

receive? 26 

3. What rights do l have following my appeal? 28 

M1SCELLANEOUS: 28 

·1. Wt10 administers the plan? 28 

2. Who contrlbutes to the Plan? 28 

3. How are the funds to provide penslon benefits accumulated? 29 

4. \/\Jill I receive a statement of my status under the Plan? 29 

5, Can I assign my benefits under the Plan? 29 

6. Can the Plan be changed {amended) or terminated? 29 

7, Are my benetlts under the Plan insured? 29 

8. Are there legal documents covering the Plan? 30 

STATEMENT OF YOUR ERISA RIGHTS 

li 

SWORCCPP2018-000325

31 
SUMMARY PLAN DESCRIPTfON 

FOR THE 

SOUTHWEST OHIO REGIONAL COUNCIL OF CARPENTERS 

PENSION PLAN 

January, 20 i7 

To Partlcipanls and Beneficiaries of the Southwest Ohio Reglonal Council of Carpenters Pension Plan: 

We are pleased to present this summary of the main provisions of the Southwest Ohio Regional Council of 

Carpenters Pension Plan. This Plan is the st1ccessor to the Southwest Ohio District Council of Carpenters -

Cincinnati Pension Plan and the Southwest Ohio Distrlct Councfl of Carpenters - Dayton Pension Plan, Which 

were merged effectwe January 1, 1999. 

The booklet summarizes the eligibili~1 rules for participation in the Plan, the benefits provided to those Who 

are eligible, and the procedures that must be followod when applying for a benefit. Also included Is important 

lnforrnaUon concerning your rights as a participant or beneficiary. 

The Board of Trustees has discretionary au!horily to determine etigibiltty for benefits and to interpret the 

provisions of the Plan. Benefits under the Plan wl!I bo paid only if the Board of Trustees decides, in its 

discretion, that the applicant is entitled to them, Any interpretation or determination made by the Goard of 

Trustees pursuant to this discretionary authority wm be final and btnding on all parties unless it is determined 

by a court that the i11ierpretafion or determination was arbitrary and capricious. 

The Board of Trustees also has the authority to amend the Plan, You will be notified of any important 

Ghanges, 

This Is your booklet describing your Plan, Make sure you read lt from cover to cover, Then put it in a safe 

place for future reference. rf at any time you have questions about your Plan, you should call or write the 

Plan Administrator for assistance. 

Note - This booklet ls a summary of the Plan. If there is any discrepancy between the provisions of the 

summary and the Plan itself, the Plan wm control. 

BOARD OF TRUSTEES 

SOUTHWEST OHIO REGfONAL COUNCIL OF CARPENTERS 

PENSION PLAN 

SWORCCPP2018-000326
PLAN INFORMATION 

Name of Plan: 

Southwest Ohio Regional Council of Carpenters Pens!on Plan 

Type of Plan: 

Defined Benefit Plan 

Identification Number ot Plan Sponsor: 

31-6127287 

Plan Number: 

001 

Plan Yaar: 

January 1 - December 31 

Plan Sponsor and Administrator: 

Board ofTmstees 

Southwest Ohio Regional Council of Carpenters Pension Plan 

c/o BeneSys, Inc. 

P.O. Box 3i580 

Independence, OH 44131 

Phone: (330)779-8862 

(800} 435-2388 

Type of Administration: 

The Plan ls administered pursuant to a contract belween the Board of Trustees and BeneSys, inc. 

BeneSys, fnc. 

700 Tower Drive, Suite 300 

Troy, Ml 48090 

Phone: (330) 779-8862 

{800) 435-2388 

Trustees: 

Management Trustees: Union Trustees: 

Randall Fox Mark McGriff 

Associated General Contractors Indiana/Kentucky/Ohio Rcglona! Council of Carpenters 

1i5 Llnwood Street 771 Greenwood Springs Drive 

Dayton, OH 45405 Greenwood, IN 46143 

2 

SWORCCPP2018-000327
Management Trustces'. Union Trustees: 

Steve Schramm Donald Crane 

OK Interiors Corp. lndfana/l<entucky/Ohto Re~lonal Council of carpenters 

537 Ashburn Road 755 Boardman Canfield Road, Suite H1 

Cincinnati, OH 45240 Youngstown, OH 44512 

Ken Schroeder David Meier 

Leo B. Schroeder, inc. lnd1ana!Kentucky/Ohio Regional Council of Carpenters 

1229 East Third Street 204 Norlh Garver Road 

Dayton, OH 45402 Monroe, OH 45050 

Mark Trimbach Richard Fletcher 

Universal Contracting Corporation Indiana/Kentucky/Ohio Regional Councif of Carpenters 

5151 Ffshwick Drive 204 North Garv01· Road 

Cincinnati, OH 4521B Monroe, OH 45050 

Kenneth Lyons (Alternate} 

Indiana/Kentucky/Ohio Reglonal Council of Carpenters 

204 North Garver Road 

Monroe, OH 45050 

Agent for Service of Legal Process: 

Service of legal process may be made upon any Plan Trustee or upon the Plan Administrator, at (he 

addresses shown above. 

Collective Bargaining Agreement: 

The Plan is maintained as a result of collective bargaining between local unions affiliated with the 

Indiana/Kentucky/Ohio Regional Council of Carpenters and various contributing employers. You may 

obtain a copy of the collec!ive bargaining agreement by wtit!11g the Plan Administrator. (A reasonable 

charge may be made for copying.) You may also examine a copy of the collective bargalning 

agreement at the Plan Administrator and at your Union Hall. A copy of the collective bargaining 

agreement will also be made available at any work site where 50 partk:ipants are viorking, rf you give 

the Pian Administrator at least 10 days' advance written notice, 

Contributing Employers: 

Upon written request to the Pian Administrator, you will receive information ab.out whether a particular 

employer or union is contributing to !he Plan and, if so, its address. 

3 

SWORCCPP2018-000328
QUESTIONS AND ANSWERS ABOUT THE SOUTHWEST OHIO 

REGIONAL COUNCIL OF CARPENTERS PENSION PLAN 

ELIGIBILITY FOR PARTICIPATION: 

1. Who Is eligible to participate in the Plan? 

Any person for whom wnirlbullons to the Plan are required by the collective bargaining agreement or 

particlpation agreement is eHgtble to participate. Self-employed persons, such as sole proprietors or 

partners in unincorporated businesses, cannot have contributions made for them. This is prohibited 

by the Taft-Hartley Act, one of several federal laws that govern the Pion, 

2. When will I become a participant In the Plan? 

You 1Nill become a Participant on the first day of the month following the completlon of 500 Hours of 

Service during your Eligib!lity Computation Period. 

The Eligibllfty Computation Period is !he 12-month period that begins on the dale you first earn an 

Hour of Service (An Hour of Service ls generany an hour for which you are paid or entitled to 

payment by your Empk,yer). lf you rlo not become a Participant as a result of your first 12 months 

after earning a Hou1 of Setvice, then your Eligibility Computation Period snail thereafter be the Plan 

Year {January 1 through December 31) and you will be measured each year on December 3i to see 

if you satisfied the 500 Hours of SaNlce to become a Participant. 

However, no person wlll become a Partlcipanl n., before the fime a contribution to the Plan for such 

person is required, contributions are to be reciprocated. 

3. Do I have to sign anything to Join the Plan? 

No. 

However, since there aro death benefits under the Plan, a beneficiary designation form should be 

completed. You should receive such a fonn from the Plan Administrator after you become a 

Participanl However, if you do not receive this form within six weeks of becorntng a Participant, 

please contact the Plan's Fund Office. 

4, What Is Covered Employmont? 

Covered Employment is employment for which your Employer is required to contribute to the Plan, 

Covered Employment Is determined by the collective bargaining agreement or partidpatlon 

agreement. 

4 

SWORCCPP2018-000329
5. What Is art Hour of Service? 

An Hour of Service is generaUy an hour for which you are paid or entmed to payment by your 

Employer. 

CREDITED SERVICE: 

1. What is Credited Service? 

Credited Service is used to determine the amount of the benefit yoll will receive llnder the Plan. 

Years of Credited Service are detem1ined as foffows: 

·j. The nl!mber of years earned as of December 3i, 1998; under the Southwest Ohio District 

Council of Carpenters ~ Clnclnnail Pension Plan or lhe Southwest Ohio Dlstrict Council of 

Carpenters-Dayton Pension Plan (as the case may be) for benefJt accrual purposes, and 

2. After December 3i, 1998, you will be credited with one (1) Year of Credited Service for 

each Plan Year during which Employer contributions are required for 1,500 hours of work 

in Covered Employment at the base journeyman's contrlbutlon rate, with partial credit 

being granted as toHows: 

If Employer contributions are required for more or fess than 1,500 hours of work during a 

Plan Year at the base Journeyman's rate, the Grectlted Service for that Plari Year 1s a 

fraction. The numerator is the number of hours for which Employer contributions at the base 

journeyman's rate are required and the denominator is i, 500, Note that if more than 1500 

hours are credited, Credited Service for the year wil! be morn than one ( 1 ). 

A\so, if Employer contributions are reql!ired during a Plan Year at a contribution rate other 

than the base joumeyman's rate, the Credited Servic·.e for that Plan Year wll! be earned on a 

pro--rata basis, based on the rallo of the required hourly conlrlbution mte to the base 

journeyman's rate. 

In an cases, however, no periods of self-employment wm be taken lnlo account when 

determining Years of Credited SeNice, and Years of Credited Servloo before a Forfeiture of 

Service {as desc1ibed on Page 7) are disregarded. 

Finally, no Years of Credited Service wm be granted for periods of work that are not 

constdered Covered Employment 

5 

SWORCCPP2018-000330
VESTING: 

1. What does it mean to be vested in my pension benofit? 

To be vested means that. you have a non-forfeitable right to a future benefit That !s, even if you 

leave Covered Employment. you would still be eligible for a penslon beneflt when yoll reach 

retirement age. 

2. How do I become vested? 

You wHl be vested when you have earned five (5) Years of Vesting Service, or when you have 

reached Normal Retirement Age whife an active participant in the Plan. GeneraHy speaking, to be 

an active participant, you must have eamed an Hour of SelVice and had contributions made on 

your behalf during the preceding 12 months. However, service before a forfeiture of Service (as 

described on Page 7} is disregarded. 

3. What is a Year of Vesting Service? 

A Year of Vesting Service means: 

1. Before January 1, ·1999, a Year of Vesttng Service as defined under the Southwest Ohio 

District Council of Carpenters - Clnclnnati Pension Plan or the Southwest Ohio rnstriot 

Covncil of Carpenters- Dayton Pension Plan {as the case may be). 

2. After December 3·1, 1998, each Plan Year during which you complete at least 1,000 Hours 

of Service in Covered Employment or in Conliguous Non-Covered Empfoyment {as 

described on Page S), with partial credit granted at the rate of one-tenth of a Year of Vesting 

Service for each 100 Hours of Service as set forth below: 

Hours of Service in 

Covered Employment and/or 

in Contiguous Non-Covered Years of 

F.moloyrnent During a Plan Year Vesting SeNice 

S00-999 .9 

800-899 .8 

700-799 .7 

G00-699 .6 

500-599 .5 

400-499 .4 

300-399 3 

200-299 ·'-

'1 

100-199 , 1 

Less than i00 -0-

6 

SWORCCPP2018-000331
No Vesting Setvlce will be earned if fewer than 100 Hours of Service are earned in a Plan Year, 

Also, no more than one (1) Year of Vesting Service can be earned during a Plan Year. 

RECIPROCITY: 

1. What if I work for a contributing employer outside the Jur!sdictlon of this P hm? 

If you work outside the jurisdiction of your Local Union, it may be posslble lo have that service count 

toward your pension. This wlll be posslble if a reciprocJty agreement exlsts between this Plan and 

the plan of the other Local Union where you work. However, even if there is a reciprocity agreement, 

you must make a proper application to initiate the transfer. You should make this request as soon as 

possible because often contributions are transferred prospectively only from the date the application 

form ls received. Contributions made to the other pian for you before your appllcation fs recelved 

may not be transferred back to this Pfan. 

2. How do J know if a reciprocity agreement ls in effect between the Southwest Ohio 

Regional Council of Carpenters Ponsion Plan anct the plan of the Local Union in the 

area where I am working? 

As soon as you know that you wm be working in another jorlsdiction, please check wlth the Ptan 

Administrator to determine rt a reciprocity agreement exists; and, if it does, whether the other 

jurisdiction will provide you with the proper forms to complete. Do not wait until the job in the other 

area is finished before you apply. As noled, many reciprocity agreements have deadlines for 

transfening contlihuticms, and ff you wwt too long to npplv, oonltibutioris may not be transferred. 

LOSS OF PENSION B~NEFITS: 

1. Is it possible for me to ever lose my Creditod Service and my Vesting Service? 

Yes, If you leave Covered Employment before becoming fully vested, at1d ifyou do nol return to work 

under the Plan within !he time speclf!ed below, you will lose your Vesting Setvice, your Credited 

Service and all pension benefits earned. tf you work no hours in a Pian Year, you have a One-Year 

Break in Service. When you have a One-Year 8reak in ServJce, you will no longer be a Participant 

(If you have earned at leas.I five (5) Years of Vesting Se!Vlce; you will be consk!ered a Deterred 

Vested Participant) 

!f you leave the Plan and are not vested, you can regain your· prior Years of Vesting Service by 

returning to work under the Plan during any of the next five consecutive Plan Years. if you do not, 

you will have a Forfeiture of Service. This means that all of your Years of Vesting Servlce, Years of 

Credited Service and pension benefits earned are permanently lost. However, you will not lose your 

Years of Vesting Service, Years of Credited Service and pension benefits you have earned If: 

1. You are !n the military servlco. A grace perlod will be granted for the fength of such 

service, provided that you make yourself available for Covered Employment within the time 

period required by law following your separation from mllilary servlce. Upon re-entering 

Covered Employment you wifl afso be credited with contributions, service and benefits for 

7 

SWORCCPP2018-000332
the period of time you were in the mmtary according to lRS regulations, tf you feel you 

should be credited for time spent in the military, please contact the Plan Administrator. See 

Page 25 for more information about absence due to mHltary service, 

2. You remain employod by your Employer, but in a category of work not considered 

Covered Employment. For example, suppose you are moved by your Employer (who has 

been contributing io the Plan on your beha10 to a posillon not covered by the collective 

bargaining agreement. The law requires that all service ln this new position be counted tor 

purposes of determining whether or not you are vested, This service must be uninterrupted 

and must be with the same Employer. (This is known as ''Contrguol!s Non-Covered 

Employment.") If you have such a switch In employment before you become vested, please 

notify !he Plan Administrator so that your records can be updated to ensure that you wm not 

lose any benefits to which you might be entmed. 

Exampfa 1: You have three Years of Vesting Service, !eave the Plan, and come back after having 

four consecullve One-Year Breaks in Servtce. Since you rcturneq before having five consecutive 

One-•Year Breaks in Service, you will regain your service credits and earned pension. 

Example 2: You teave the Plan after having completed four Years of Vesting Service. You then 

have flve consec-.ulive Plan Years within ,mich to return and rega\n your past credits. Suppose, 

however, that you do not return until six years later. That is, you have six One-Year Breaks fn 

Service. This means you have a Forfeiture of Service, and an of your prior service and benefits are 

permanently lost You would start out again as a new employee with zero benefits, zero Years of 

Credited Service and zero Years of Vesting SeN!ce. You would also be required to satisfy the 500-

hour initial eliglbllity rule described on Page 4 before you would be a participant. 

RETIREMENT BENEf=ITS: 

1. When can I retire under the Plan? 

The Plan provides for both Nom,al and Early Retirement. In each case your e!!gibHi!y to retire ts 

based upon your age and service under the Plan. 

Your Normal Retirement Age is the later of age 62 or the age on which you reach the fifth 

anniversary of the day on which you flt'st became a Plan participant (Sorvlce before a Forteiture of 

SefVice, as described on Page 7 is disregarded when determining your fifth anniversary.} 

You are eligible for Early Retirement If you are at leas! age 55 and have el least five (5) Years of 

Vesting Service. (Service before a Forfeiture of Service Is disregarded.) 

When you retire and want your benefits to begin, you must make a wrttten applicat!on to the Truslees 

through the Plan Admlnls!rator. Benefit payments wm not start until the first day of tho month 

folJowlng the dato on which tho full and complete application Is filed with thfJ Plan 

Administrator. However, whetber or not an application has been fited, Federal law requires that 

retirement benefits begin noi later than the Aprll 1st foUowlng the year in which you reach age 701⁄2 or 

retire, whichever is later. 

8 

SWORCCPP2018-000333
Z. if I retire on my Normal Retirement Age1 how much will my benefit be? 

Your pension will be equal to the benefit earned under the Clnchmatl or Dayton Plans as of 

Dncember 3'I, 1998, plus the benefit earned under this Plan from January 1, 1999 until you retire. 

Since the formulas under the Cincinnati and Dayton Plans were improved over the years, it is 

impossfble to use a single factor to determine your monthly pension. However, in the past you have 

received an annual statement showing your accumulated benefit at the end of each Plan Year. You 

will also continue to receive a benefit statement each year under the current Plan. 

To obtain an estimate of your retirement benefit, you can add to the benefit shown 011 ymir most 

recent statement your anticipated benefit for Mure years until you retire. To assist you ln estimating 

the benem you wm cam for Mure years, we have included the following table. The table shows the 

amount of monthly pension credit that wiH be earned during one Plan Year, based upon tlie current 

formula of $50.00 (effeclive June i, 2003) per Year of Credlted Service. Hours worked above or 

below 1500 in a Plan Yearresult in more or less of a Credit eamed during the Plan Year. 

Hours Worked in Plan Year al 

Base Journeyman's Contr!bu!lon Credit Earned for the Plan 

tate Year 

2,000 $ 66.67 

'1,750 58.33 

1,500 50.00 

1,250 41,67 

1,000 33.33 

750 25.00 

500 16.67 

250 8.33 

ln addition, benefits for all active participants were increased on December 3i, 1999 and again on 

Dec:ember 31, 2000 by 3% as of those dates. These increases also apply to benefits earned under 

the former CinoinnaH and Dayton Plans, as well as any benefit earned during 1999 amt 2000, 

respectively Ul)der the Plan. 

Note, the previous accrual amounts included $99.00 per Year of Credited Service effective through 

December 31, 2001, and $80.00 per year of Credited Service effecUve through May 31, 2003, 

The fo!lowing ls an example of how to estimate your normal retirement pension under the Plan: 

EXAMPLE: You are 55 years old and have 20 years of Credited Service. As of the last 

December 31, you have an earned pension of $2,000.00 per month. If you i.vork 1,500 hours 

each Plan Year from age 55 to age 62 at the base journeyman's contribuflon rate, you wm then 

be entitled to a normal retirement benefit of $2,350.00 per month, determined as follows: 

g 

SWORCCPP2018-000334
Earned Benefit to age 55 

plus 

Earned Benefit for service from age 55 

to age 62 [7 years @$50.00 per Plan Year] 

Total 

3. Do I have to retire at my Norma! Retirement Age? 

No. 

S2,000.00 

$2,350.00 

4. What wHI my benefit be If I continue to work pa$t my Normal Retirttm1mt Age? 

Your pension will conflnue to increase as contributions are rnade to the Plan on your behalf. 

However, your monthly pension may be suspended under the Plan's suspension rufes until you 

actually ret\re, This suspension will be determined in the same tmmner as for a member who retires 

and then returns to work. {See Page i 1, Question Number 1.) 

6. What wm my benefit be If I retire before my Normal Retirement Age? 

For retirements with a benefii commencement date on or after January 1, 2Gi 3, your benefit will be 

subject to an actuarial reduction if you commence receipt of benefits prior to your Normal Retirement 

Age. This means trial your monthly benefit will be reduced to accotml for the extra time you wm 

receive payments. The amount of the reduction will depend on the number of months that your 

actual retirement date precedes your Normal Retirement Date (at age 62). A sample chart 

iflustrating actuarial reduction factors is attached as Appendix A at the end of this Summary Pian 

Description. 

EXAMPLE: You are now age 57 and have 15 Years of Credited Service. Your ~om1al Retirement 

Age ls 62 but you wish to retire early at age 57, Assume that your earned monthly pension rs 

$1,800.00. Your monthly early retirement pension at age 57 will be $1,084.36, oompuled as f:o!fows: 

Earned Pension at Age 57, 0 months 

Muftlpfled by: 

Actuarial reduclion of 0.602424 (60.24%) for 

Early Retirement Date at 57 years and Omonths: 

Totai Monthly Early Retirement Pension 

$1,800.00 

0,60~:'.424 

$1,084.36 

iO 

SWORCCPP2018-000335
6. fs there a maximum benefit under the Plan? 

Federal tax laws require the Plan to limit the annual benefit paid to participants and surviving 

spouses. If your benefit or that of your surviving spouse would exceed the amount that federal tax 

laws aHow to be paid, the benefit vAll be reduced to comply with the law. 

The Plan Administrator w!ll inform you if your benefit wl!I be affected by this restriction. 

7. What about Social Security benefits? 

Your Social Security benefits are separate and apart from your benefits under this Plan. The amount 

of your Social Security benefits do not have any impact on the amount of your Plan benefits. 

8, Do l pay taxes on my pension? 

Your pension payments are taxable Income. However, it is recommended that you review any 

quesUons you might have ln this regard with a competent tax advisor. 

SUSPENSION OF BENEFITS RULES: 

·1. What happens if I retire and then go back to work? 

If you withdraw from retirement by working in Disquatifying Employment, your benefits wlH be 

suspended. The definition of Disqualifying Employment and the way benefits are suspended !s 

different, depending on your age when you go back to work - either after Normaf Retirement Age or 

before Normal Retirement Age. 

In addition, the applicable suspension of benefits rules may depend on the date of your 

retirement 

We have included a summary flow chart as Appendix B at the end of this bookie! mustrating the 

suspension of benefits rules.. 

AFTER NORMAL RETIREMENT AGE: 

A member who, aftor reaching Normal Retirement Age, works 480 Hours of Service in Disqualifying 

Employment during a Plan Year, wlll have his or her benefits sL1spendad for every subsequent month 

in that P!,m Year in which he or she works 40 or more hours. Pension benefi!s will be adjusted at the 

end of the Plan Year ln which re-employment was te1mlnaled to include the adjusted age of the 

Participant and any additional employer contributions. 

Disqualifying Employment for Normal Retirement Age means employment or sett-employment 

{inch.idfng supetvislon): 

t in the bL1ilding and construction Industry and any other industry covered by the Plan when 

your monthly benefits began, 

11 

SWORCCPP2018-000336
in the geographic area covered by the Plan as defined in the current col!ecfive bargaining 

agreernent, including any other aroas covered by the Plan when your monthly benefits 

began and, 

3. in any occupation covered by the P!an when yotir monthly benefits began. 

BEFORE NORMAL RETIREMENT AGE: 

If you retired and your benefits payments commenced before April 30, 2010: 

A member who has retired before NormE:tl Retirement Age and who completes filly'. Hours of Service 

in rnso,ualifying Employment, as explained in A below, wm have his or her benefits suspended 

according to the guidelines set forth ln B, below. 

A Dlsquallfylng Employment Before Normal Retirement Age means employment or 

self-employment (including supervision}: 

ln an Industry covered by the Plan when your monthly benefits began, 

2. (a) for service credits earned BEFORE July i, 2005:, in the geographic 

area covered by the Plan when your monthly benefits began and, 

(b) for service credits earned AFTER June 30, 2005, ANYWHERE in the 

con.siruction indusiry, regardless of location. (Please see example, below.} 

. 

B. Benefits will be suspended according to the following for work Before Norma! 

Retirement Age: 

1. For ser.rice credits earned before Jury 1, 2005, for any member who works 

480 Hours of Service In D1squalifi;ing Empioymenl during a Plan Year, 

benefits will be suspended for eac:h remaining rnonth in a Plan Year during 

which the member completes at feast one (i) Hour of Service in 

Disqualifying Employment prior to his or her Normal Retirement Age, 

Pension benefits wlll be adjtH,ted al the end of the Plan Year in which reemployment was terminated to include the adjusted age of the Partidpan1 

and any additional employer contrlbutions. 

2, For service credits earned after June 30, 2005, benefits will be suspended 

until the Plan's Non11al Retirement Age. These benefits wm be adjusted at 

your Normal Retirement Age to include the adjusted age of the Participant 

and any additional employer contributions, 

EXAMPLE: Depending upon when you retire, your early retirement benefit may be subject 

to two different suspension rules - one rule that applies to those benefits you earned 

through June 30, 2005, and another rule that applies to those benefits you earned after 

June 30, 2005. 

12 

SWORCCPP2018-000337
For example, assume you take early retirement in 2009 wmi a monthly benefit of $2,500. Of 

that amount, $2,250 is subject to the suspension ru!e that was in effect through June 30, 

2005, and the remaining $250 ls subject to the more restrictive suspension rwe that took 

effect July ·1, 2005. Assume you then return to work in the construction lndL1stry in 

California. Because work in the construction industry in Cafifomia w·as not Disqualifying 

Employment under lhe early retirement benefit suspension rule in effect through June 30, 

2005, you would continue to receive a monthly bene'fit of $2,250. However, the $250 

monthly benefit that was earned after June 30, 2005 would be suspended. Th\s is because 

the early retirement st1spension rule !hat applies to service credits eamed after June 30, 

2005 does not allow you to work anywhere in !he conslructlon industry. The $250 benefit 

wm remair1 suspended unm your Normal Retirement Age, even If you stop worklng rn the 

construction industry before that time, lf you return to work in the construction lndustry in 

the geographic jurisdiction of the Collective Bargaining Agreement, your entire monlhly 

benefit of $2,500 would be subject to both of the Plan's suspension rules (through $2,250 

would only be suspended after you worked 480 Hours of Service in DisquaHfying 

Employment In that Plan Year.} 

If vou retired and your benefits commenced on or after April 30, 2010: 

A member who has retired before Normal Retirement Age and who completes fil1Y Hours of Service 

in Disqualifying Employment shall have his or her benefits suspended until Normal ReUrement Age. 

Disqualifying Employment Before Normal Retirement Age means employment or self-employment 

{including supervision) in an industry covered by the Plan when your monthly benefits began, 

regardless of location. 

2. What should I do if I decide to return to work after I retire? 

Before you start any work, you may ask for a determination whether such worf< wiH be considered 

"Disqualifying Employment" You should submit the request to lhe Plan Administrator. 

You must notify the Board of Trustees·ln wdtlng of any employment (Including self•empbyrnen!) or 

gainful pursuit within 15 days after the end of the month in which you have any earnings from 

OisquaHl'}tjng Employment If you do not foliow thls ru!e and the Trustees learn that you have been 

engaged in any employment (including self-employment} or gainful pursuit that is Disqua!ifylng 

Employment, regardless of the amount you earned, your pension benefit wlH be suspended. The 

Board of Trustees also has the right to request from you reasonable Information to verify your 

employment and lo ask you to certify that you are not working or that you are not doing the type of 

work which can result in a suspension of your pension benefit. The Board of Trustees has the rlghl 

to withhold your pension benefit until you provide the requested Information. 

lf you are receiving benefits from the Plan and the Board of Trustees learns that you are doing the 

type of work which can result in a suspension of your pension benefit, and if you have not notified the 

Board of Trustees (as required by fhe prevlous paragraph), the Board of Trustees can assume that 

(1) you have worked the number of hours durln,_q a month which can result in a suspension of your 

13 

SWORCCPP2018-000338
benefit, and (2) you have been worklng at the job sife as long as your employer had been working 

there. The Board of Trustees can then suspend your pension benefit accord!ngly, lt 1.ivi!I !hen be 

yo1,ir responsibility to prove that these assumptions were incorrect. 

Special Suspansion Rule for "Rule of 80" retirements: The Ru!e of 80 W'f'JS not lntended to allow 

an Individual to draw a monthly benefit while continuing to work In the trade. Therefore, a more 

restrictive suspension rule applies to any member who retires from active service under the Rule of 

80 provisions. That rule provides tbat if, after retiring under lhe Rule of 80 benefit, you return l.o work 

in the trade, either as a covered employee under this Plan or not, and you do not notify the Plan 

Administrator, as described above, your right to receive Early Retirement Benefits, Including the 

Rule of 80 benefit, will be permanently lost That is, if you are found to be working in the trade, 

your benefits wtll be suspended in accordance wilh the provisions previously discussed above, bllt 

when you again desire to retire, you will no! be able to do so under the Early Retirement provislons of 

the Plan. You wm retain your vested rtght to the benefit you have ec1rned under the Plan, but this 

benefit will not be payable until your Normal Retirement Age. 

For purposes of the Rule of 80 benefit, you "retire from active service'' If you had at least 1,000 hours 

of contrlbu!ions to the Plan for work !n Covered Employment during the 24-month period immediate}y 

preceding your Early Retirement. 

3. What must I do to start my monthly pensloi1 again after I stop working? 

Once pension benefits have been suspended, you must notify the Board of Trustees in writing that 

your Disqualifying Employment has ended and when your pet,sion benefft should again start. To do 

this, you should either write to the Board of Trustees or f!!e another benefit application form with the 

Plan Administrator. 

4. What wlll happen ff l receive pension benefits for a month in which they should have 

been suspended? 

If you receive benefit payments during a monih in which they should have been suspended, the 

excess payments will be recovered by using the offset rule. Under the offset rule, v!hen you are 

again eligible for benefit payments, the Trustees will withhold your benefits until the excess p,wments 

have been fully recovered, However, if the offset mle applles after your Normal Retirement Age, the 

Trustees may wilhholct your benefits for up to three (3) months. If this is not long enough to recover 

the overpayments ln full, your future mon!h!y benefits will be reduced by 25 percent untu the excess 

payments have been fully recovered, 

5. How can l find out more about the suspension of benefits rules? 

!f you have any questions regarding the suspension of beneffts rules, or if you would like to know in 

advance whether the type of work you propose to do will cause a suspension of your pension 

benefit, contact the Plan Administrator. 

If you ask for a determination on the application of the suspension mies or if your pension payments 

are suspended, yoll wili receive a written notice from the Plan Administrator. 

i4 

SWORCCPP2018-000339
If you disagree with any adions taken by the Trustees In suspending benefits, you can me an appeal 

with the Pian Administrator. Page 26 of this Summary Pian Description tells you how to file an 

appeal. 

FORM OF PENSfON PAYMENTS: 

1. In what form wHI my retirement pension be paid? 

The Plan aflows you to choose from several options tor the form of your monthly pension if you elect 

Normal or Early Re!lrement. (Payment of benefits for a Disability Retirement ls explained under the 

Seofion on Disability beginning on Page i9). 

If you are not married on your benefit commencement date, your retirement benefit wm be paid as 

a Single Ufo Annuity. Under this form of payment, you will receive a monthly benefit payable for 

your lifetime. NO further monthly benefits will be payable to your beneficiaries or lo your estate after 

your death. This is the standard fom, of payment under the Plan for unmarried participants. It !s an 

optkma! fonn of payment for mμrrled particloants. 

lf you are married when your retirement pension begins, you will recefve your pension ln the form of 

a Joint and 100% Survivor Annutty, unless you elect otheiwlse with your spouse's written consent 

This form of payment provides you with a reduced retirement pension during your lifetime and 

survivor benefits for your spouse, Under this fom1 of benefit, if you predecease your spouse, the 

Plan will continue to payi 00% of your monthly pension benefits to your spouse for lhe remainder of 

his or her lifetime. The benefit ls reduced from the amount payable under a Single Life Annuity 

because It is payabie over the lifetimes of both you and your spouse. This ls the standard form of 

payment if you are married when your retirement pension Q~!n~, unless you elect otherwise with 

your spouse's written consent. 

Under the Joint and Survivor Annuity options, the spouse who receives the. survivor portion 

must be the person to whom yo11 were married when benefit payments to you began. If you 

divorce after retiring and subsequently remarry, your ex.~spouse wflf remain entitfed to your 

smvivor annuity payments, and your new spouse wifl NOT receive benefits Ifyou predecease 

him or her. 

2. What other forms of payment are offered under the Plan? 

!n addition to the two op!lons dfscussed in Question 1, there are three other forms that your monthly 

pension can take. You mt1st select your option before your benefits are to begin. If you prefer any of 

these opfions, you must obtain your spouso's written consent on forms furnished by the Plan 

Administrator, and these forms must be fiiect with the Plan Administrator before your retirement 

pension is to begin. This election can be made at any time in the 90 days before your pension 

begins. 

15 

SWORCCPP2018-000340
Before your benefits begin, you can q:mcel an)I election you have made by f!Hng fhe appropriate 

forms provided by the Ptan Administrator. Any opUonai form of payment WIii be canceled 

automatically if you die before the date your pension is to begin, or if you have elected one of the 

Joint and Survivor AnnultJ options, your spouse dies before the date your pension is to begin. You 

will not be allowed to change your form ofpayment afteryou start to receive benefits. 

The other options are: 

1. Joint and 75% Survivor Annuity: This fom1 of payment is similar to the 100% Survivor 

annuity, except that upon your death, if your spouse ls still living, 75% of your monthly 

pension continues to hlrn or her. 

2. Joint and 50% Survivor Annuity: This form of payment is again simflar to the 100% 

SuNivor annuity1 except that upon your death, if your spouse is stm tMng, 50% of your 

month!y pension continues to him or her. 

3. Single Life Annuity with a iO Year Certain Pa:,1ment: This ls a monthly pension payable 

for your ilfetlme, but if you die betore receiving at least payments for 10 years (i20 monthly 

payments}, the remaining payments •Nill be made to your designated beneficiary. 

Again, under thf:t Jolnt and SuNivor options for payment, the survivorship benefit Is only payable to 

the spouse you were marrled to when your benefit payments originaHy began. A subsequent spouse 

would not be eHgible for these benefits. 

When you are thinking of retiring, you may contact the Plan Administrator for information about the 

reduced amour.ts of benefits payable under each of the optional forms of payment. 

3. If I elect to receive my benefit In the form of a Joint and Survivor Annuity, how will my 

monthly pension be calculated? 

Since the Joint and Survivor Benefit(s) are paid over two lifetimes instead of one, the monthly 

amoun! payable is reduced from the Single life Annuity. To show you how your pension would be 

calculated If you were lo receive It in the form of a Joint and Survivor Annuity, the following tables list 

the factors that would be used to convert your Single Ufe Annuity iq a Joint and Survivor Annully. To 

use the tables, find your age and the age of your spouse as of the date of your retirement The 

corresponding entry is the factor to be applied to tho pension you would receive under the Single Life 

Annuity form of payment. 

Age of Percsntage Payable Under .Joint end 100% SurvivorAnnuity 

Souse Age of Retiree ___ _ 

62 60 58 55 

62 84.09% 86.38% 88.39% 90.95% 

58 81.27% 83.79% 86.05% 88.96% 

55 78.23% 81.89% 84.30% 87.45% 

52 77.31% 80.08% 82,60% 85.95% 

48 74.96% 77.82% 80.47% 84.02% 

16 

SWORCCPP2018-000341
Age of Percentage Payable Undgr Joint ancf 75% Survivor Annuity 

Spouse Age of Retiree 

62 60 58 55 

62 87.57% 89.42% 9i.03% 93.05% 

58 85.26% 87.33% 89.16% 91.49% 

55 83.57% 85.77% 87.74% 90.28% 

52 81.96% 84.27% 86.36% 89,08% 

48 79.97% 82.39% 84.60% 87.52% 

Age of Porcentage Payable Under Joint and 50% SutYivor Annuity 

Spouse Age of Retiree 

§1 60 58 55 

62 91.36% 92.69% 93.84% 95.29% 

58 89.67% 9'1.18% 92.50% 94.16% 

55 88.41% 90.04% 91.48% 93.30% 

52 87.20% 88.94% 90.47% 92.44% 

48 85.69% 87.53% 89,i8% 91.32% 

EXAMPLE 1: Joint and 100% survivor Annuity; Assume you retire at age 5!;! and have a wife age 

58. You decide to receive your pension in the form of a Joint and i00% Survivor Annuity. Assume 

further that the Single Life Annuity payable at your Early Retirement Age is $2,500.00. This amount 

wm be reduced to reflect 1.he increased cost of providing your benefit in the fom, of a Joint and '100% 

Survivor Annuity. According to the table, your benefit would be equal to $2, 151.25 (.8605 

$2,500.00). 

Assume you live for e\ght years after your retirement Whllc you ar1:: alive you wlll receive your 

reduced monthly penslon of $2,151.25. At the time of your death, your surviving spouse will start 

receiving a monthly Income equal to the pension you were receiving, or S2,15i.25 for the remainder 

of her llfefone. Under an Joint and Survivor Annuity op!ions, the spouse who receives the survivor 

portion must be ihe person to whom you were married when your benefit payments began, not a 

subsequent spouse. 

EXAMPLE 2: Joint and 75% Survivor Annuity: Assume you retire at age 62 and have a Wife age 

58. You declde to receive your pension in the form of a Jornt and 75% Survivor Annuity. Assume 

further thal the Single Life Annuity payable at your Normal Retirement Age is $3,000.00. This 

amount will be reduced to reflect the increased cos! of providing your benefit in the form of a Joint 

and 75% Survivor Annuity. According to the table, your benefit would be equal to $2,557.80 (.8526 x 

$3,000.00). 

Assume you Hve for eight years after your refiremenL \IVhife you are alive you wm receive your 

reduced monthly penslon of $2,557.80. At the time of your death, your suNiving spouse will start 

receMng a monthly income equal to 75% of the pension you were receiving, or $1,918.35 for the 

remainder of her lifetime. Under all Joint and Survivor Annuity options, !:he spouse who receives !.he 

survivor portion must be the person to whom you were married when your benefit payments began, 

not a subsequent spouse. 

17 

SWORCCPP2018-000342

x 
EXAMPLE 3: Joint and 50% Survivor Annuity: Assume you retire at age 55 and have a husband 

age 58. You decide to receive your pension in the form of a Joint and 50% Survivor Annuity. 

Assume further that the Single life Annuity payable al your Early Retirement Age Is $900.00. This 

amount wfll be reduced lo reflect the Increased cost of providing your benefit in the form of a Joint 

and 50% SurviVcr Annuity, According to the table, your benefit would be equal to $647.44 (.9416 x 

$900.00). 

Assume you live for five years after your re!lrement. While you are alive you v.rjH receive your 

reduced monthly pension of $847.44. At the time of \1our death, your survMng spouse will start 

receiving a monthly income equal to 50% of ihe pen.sion you were receiving, or $423. 72 for the 

remainder of his [ifetime, Agaln, unde, all of !he Joint and Survivor Annuity options, the spouse who 

receives the suN!vor portion must be the person to vmom you were married when your benefit 

payments began, not a subsequent spouse. 

4. How is the Single Life Annuity with a 10 Year Certain Payment calculated? 

Since the payments in this option are guaranteed for iO years (120 payments) and will not slop if 

you die during that time, the monthly amount payable ts reduced To show you how your pension 

wou1d be calou!a!ed if you ware to receive !t In the form of a Single Llfe Annuity with a iO Year 

Certain Payment, the following table Hsls the factors that would be used to convert your Single Life 

Annuity to a Single Life Annuity with a 10 Year Certain Payment. To use this table, find your age as 

of the date of your retirement The corresponding entry is the factor to be applied lo the pension you 

would receive under the Single Life Annuity fom1 of payment. 

Age Single Life Annuity 

w!th a 10 Year Certain Payment 

62 93.40% 

60 94.62% 

58 95,6'1% 

55 96.77% 

EXAMPLE: Assume you retire at your Nom1ai Retirement Age (Age 62). You decide to receive 

your pension In the form of a Single Ufo Annuity with a 10 Year Certain Payment. Assume further 

that the Single Lite Annuity payable at your Normal Retirement Age is $2,000.00. Thls amount \vill 

be reduced to reflect the increased cost of providing your benefit in the form of a Single Llfe Annuity 

with a iO Year Certain Payment According to the tab!e, your benefit would be equal to $1,868.00 

(.9340 X 2,000.00). 

While you are alive you will receive your reduced monthly penslon of $1,868.00. Assume, however, 

that you llve for eight years after your retlrement and have received 96 payments. At the time of your 

death, your beneficiary vl/lli start receiving a monthly income equal to the pension you were receiving 

($1,868.00) for two more years (24 mon!hly payments). After those 24 monthly payments have been 

made, no furlher benefi!s will be paid. 

18 

SWORCCPP2018-000343
5. Can 1 receive my pension benefits in a lump sum distribution? 

Generally, no. However, when you appfy for benefits, ff the present value of yovr pension benefit (as 

determined by the Plan's acluarJ) is not more than $5,000, you will receive your benefit in a single 

lump sum payment. 1he annuity form of paymenl is not eval!able. 

If you receive your benefit in a lump sum and subsequently become a participant in the Plan again, 

you can repay the amount you received, plus interest at the rate determined by ths Internal Revenue 

Service, and your benefit in the Plan will he restored. The repayment must be made within flve {5) 

years after you again become a parl:lclpant or before you have five (5) consecutive One-Year Breaks 

In Service after the distribution, whichever date comes ffrst. If you do not make this repayment, any 

future benefit to whlch you are entitled will not Include the vatue of the benefit that was represented 

by your lump sum payment. If you return to Covered Ernploymenl, you should contact the Plan 

Administrator immediately lf you want to repay any previous lump sum payment of your benefit 

(These repayment rules do not apply to a iump sum disability benefit you may have received. If you 

become a participant in the Pian aft.er you have received a lump sum disability benefit. the value of 

the benefit that was represented by your lump sum dtsablnty payment wlll auromatlcally be included 

In any future bennfil to which you are entitled.) 

TOTAL AND PERMANENT DISABILITY RETIREMENT: 

1. Are there any benefits payable If I become totally anti permanently disabled? 

Yes. The Plan provides a benefit for Tota\ and Permanent Disability. To be eligible for fh!s benefit 

you must have become totally and permanently disabled while an active participant. For purposes of 

this Disability Benefit only, you are an active participant if contributions were made to the Plan on 

your behalf w1thln the 12 month period before the date of your total and permanent disability. 

2. What is meant by "Total and Permanent Disabillty?" 

Total and Permanent Disability means a medicaUy-determinable physical or mental Impairment that 

makes you unable to enqaqe in any gainful empiovmant for the rest of your life. 

You will be considered totally and perm(mently disabled if you have received: 

1. A determination of Tola\ and Permanent Disabllity from the Soc!al Security Administration: or, 

2. A medical certification satisfactory to the Trustees that you are unable to engage in any gainful 

employment for the rest of your life. 

3. lf I am ellgible for Total and Permanent Disability, what will be the amount of my 

benefit? 

Your Total and Permanent d\sabilit'f\'!as incurred on or after July 1, 201 Oand you were an active 

participant when your disability was incurred and you have at least five (SJ Years of Vesting Service, 

you will be entitled to receive a monthly pension equal to your benefit at the time you become totally 

SWORCCPP2018-000344
and permanently disabled that is actuartaHy reduced to account for the number of months that your 

drsability retirement date precedes your Normal Retirement Date. 

4. How do l apply for a Total and Permanent Disability Retirement benefit? 

You must complete an application for a Total and Permanent Disabl(ity Benefit as soon as you 

believe you are disabled. You wtll also have to provide your birth certificate. The Plan Administrator 

wlll also need proof of your disability, in the form of either a determination of disabmty from Sodal 

Secur!!y or ftorn a physician {If you have not received a clisab!lity determination from Social Security). 

5. When will my Total and Permanent Disability pension start? 

For a Total and Pem1anent DisabHity, the starting date of your monthly pension ls determined as 

follows; 

1. If yoll have a Social Securlty Disability award, your benefit wilt start as of !he first day of the 

month coincident with or next following the date of your disability, as established by the 

Social Security Adminlstralion. 

2. If }'OU do not have a Social Security Disability award, but the Board of Trustees determines 

!hat you are entitled to a Total and Permanent Disability Benefit, your benefit wlll begin as of 

the first day of the month coincident wit11 or next following the later of (1) the receipt by the 

Board of Trustees of an application for the Total and Permanent Disabillty Benefit, or {2) the 

date you lncu1Ted the Total and Permanent D!sablli!y, based on a determination by the 

Board ofTrustees. 

6, Can I start receiving Early Retirement Benefits wh!le waiting for a dlsnbi!lty award? 

Yes. lf you apply for a Total and Permanent Disability Benefit, but you have not yet received your 

Social Secudly Disability award, and if you are eligible for Early Retirement from lhe Plan you may 

e!ect Early Retirement, and when you receive your DisabH!ty award from Soda! Security, your 

Oisabllily benefit from the Pian will start (retroactive to the date of your dlsabl!lty). An adjustment v.~U 

be made to reflect any Early Retirement benefits you received. 

7. What happens if l recover from my Total and Permanent Disability? 

Total and Permanent Disabllity benefits are payable only as long as you rema!n totally and 

permanently disabled. If you have recoverE>,d sufficiently to return to any type of work, your monthly 

disability benefit wm be stopped. 

However, under Social Security you are permilied to work on a limited basis to determine if recovery 

from your disability is possible. The Plan also allows for similar employment, but you wm not be 

enHUed to a monthly disability payment for any month during which you work more than 40 hours, If 

you do return to work (even on a ltmited basis), yoll must notify the Pfan Administrator in writing 

within 15 days of returnh,g to work, If such notlficatlon Is not made, your disability benefits vvlll be 

suspended for 12 months beyond the duration of such employment. The Trustees have the right to 

20 

SWORCCPP2018-000345
request that you provide information abOut your Damings and work whtle you are receiving a 

disability benefit, and to suspend your benefit until you provide thls information. This includes work 

both in and out of the carpentry trade. 

!f you recover from your dlsablHty and return to C',overed Employment, you will resume earning Years 

of Credited Service, and any subsequent pension to which you may be entitled will be based on the 

pension benefits you had earned prior to becoming disabled, plus those you earn after returning to 

Covered Employment. 

The Plan has the right to recover any monthly benefits patd to you in error when your benefits should 

have been suspended due to a return lo wotk in ''Disqualifying Empbyment" and offset the 

overpayment amount from future benefit paymenis. Once your benefit payments resume, the Plan 

wm withhold your benefi!s until the excess payments have been fUlly recovered. However, If the 

offset rule applies after your Normal Retirement Age, the Trustees will withhold your benefits for up lo 

three (3) months. !f this is not long enough lo recover any overpayments, your future monthly 

benefits will be reduced by 25 percent until the excess payments have been fully recovered. 

DISABLED FROM THE TRADE BENEFIT'S: 

1. Does the Plan providl'.3⁄4 benefits if I can no longar work as a carpenter? 

Disabled From The Trade means that based on medical evidence satisfactory to the Board of 

TfLtstees, yoll are unable, as a result of bodil)r injury or disease, to perto1m any of fhe work described 

in the collective bargaining agreement tor lhe remainder of your Hfe. lf you meet the following 

eligibility requirements, you are entitled to a Disabled From The Trade Benefit: 

1. You must provide rr1edical proof and documentation that you are no longer able to 1.:Vork ln 

the trade because of your disabfHty; and, 

2, You must have at least five {5) Years of Vesting Service; and, 

3. You must have worked in Covered Employment ln the 12-month period lmmectiate!y 

preceding the onset of your disabllfty; and, 

4. YoU must NOT be eltgibie for Early Retirement; atlc!, 

5. You must have appl!ed for a Disabled From The Trade Benefit on a form prescribed by the 

Trustees; and, 

6. The Trustees have approved your application, 

2. Wrrnt type of rrmdica! evidenco wHI be required for a determination of Disabled From 

The Trade Benefits? 

The Trustees have the sole discretion to make all determinations of whether yo\l quaHfy for a 

Disabled From The Trade Benefit In rnaking their decision, the Trustees may request that a 

21 

SWORCCPP2018-000346
pilysidan or physiclar,s of their· own choosing examine you at any reasonable ttme and place, or 

require you lo submit addlUona1 medical proof and/or documehtation that you are disabled and no 

longer abie to work in the trade as, in their discretion, the Trustees cleem appropriate. The cost of 

the examination or examlnations requesred by the Trustees wm be paid by ihe Pian. If the Trustees 

approve your application for a Disabled From The Trade Benefit, the irustees may require you to be 

examined as often as they deem nocessary to determine whether you continue to meet the Plan's 

Disabled From The Trade Benefit requirements. If you fail to submit to examination when requested 

by the Trustees, your benefit will be suspended (if it has started} or no further action will be taken on 

your application (!f yow· benefit has not slarted). 

3. What f$ the amount of the Disabled From The Trade Benefit? 

The Disabled From The Trade Benefit ls a monthly benefit equal io your Normal ReUrement Benefit, 

actuarially reduced for each month you are younger than age 62 when your Dlsab!ed from 'The 

Trade Benefit begins. The factors used to determine the reduced amount of the monthly benefit are 

based on a tabte of factors that has been prepared by the Plan Actuary. Questions concerning the 

calculation of your Disabled From The Trade Benefit should be direc!ed to the Plan Administrator. 

4. When wm my Disabled From The Trade Benefits start? 

The Disabled From The Trade Benefit will begin as of the latei of the first day of the month fo!IOW!ng 

(1) your applicaiion or (2} the occurrence of your cllsabl!lty, and wlll continue as long as your disability 

exists. !f you are sllll receiving a Disabled From The Trade Benefit when you reach your Norma! 

Retirement Age, the monthly Disabled From The Trade Benefit wm be considered to be your Normal 

Retirement Benefit You will also be given fhe opporturilty to elect. another form of payment, Note 

that If you are married at your Normal Retirement Date, your pension wm be paid as a Joint and 

100% Survivor Annuity unless elected otherwise ahd properly \valved by your spouse. 

5. What happens if l start receMng a Disabled From The Trade Benefit and lat<H receive 

a Total and Permanant Dlsabll!ty award from the Soclal Security Administration? 

lf you are receiving a Disabled from The Trade BenefH and you later receive a Social Security 

DlsabUlty award, your rnsab!ed From The Trade Benefit wrn be replaced by a Total and Permanent 

Disability Bcmofit retroactively effectiv\7 fo the first day of the mcnlh following the date of your 

ctisabi!ity, as determined by Socla\ Securlty. The tolal Disabled From The Trade Benefit paid to you 

will be deducted from !he Total and Permanent Disabllity Benefits due as of the date of the Soclal 

Security Dlsabllity award and if the Disabled From The Trade Benefit previously paid exceeded the 

Total and Permanent Disab!Uty Benefits due, the future Total and Permanent Disability Benefits 

payable will be offset dollar tor dollar unlll the difference is eHrninated. To be ellgfble for this 

conversion, your Total and Permanent Disabmty must have occurred wlthln 12 months of the last 

contributions made to the Plan on your behalf. 

6, C<1n my Disabled From The Trade Benefits be suspended? 

Yes. Your Disabled From The Trade Benefit will be suspended tor any month in which you are 

employed in Disqualrfylng Ernplo:)'rnent before you have reached your Normal Retirement Age. 

22 

SWORCCPP2018-000347
Disqualifying Employment Before Normal Retirement Age ts defined in the Suspension of Benefits 

section, in the answer to Question No. i -A, starting on Page 12. If you do return to work (even on 

a limited basis), you must notify the Plan Administrator in writing within 15 days of relumlng to work 

!f such notification is not made, your dlsabllily benefits wm be suspended for the duration of such 

€rnp!oyment, plus an additional 12 months. The Trustees have the right to request that you provide 

information about your earnings and work while you are receiving a dlsab1llty benefit, and to Sllspend 

your benefit until you provlde th!s information. 

The Plan has the right to recover any monthly benefits paid to you in error when your benefits were 

to be suspended d11e to a return to work in Disqualifying Employment and offset the overpayment 

amo~mt from future benefit payments. Ones your benefit payments resume, the Ptan will wlthhold 

your benefits unlll the excess payments have been fully recovered. However, if the offset rule 

applies after your Normal Retirement Age, the Trustees will withhold your benefits for up to three {3) 

months. !f this ts not long enough to recover any overpayments, your future monthly benefits wiH be 

reduced by 25 percent untii the excess payments have been fully recovered. 

7. tf my Disabled From The Trade Benefits are suspended, how can I again apply for 

benefits? 

lf your Disabled From The Trade Benefit was suspended, you may apply for reinstaternent of your 

Disabled From The Trade Benefit once you again terminate employment, for such amount as you 

were receiving prlor to the suspension of your pension benefits. Your monthly benefit payments will 

resume no later than the first day of the third calendar month after the calendar month !n whlch you 

terminated your empfoyrnent, as long as you hal/e no!lfied the Plan Administrator In writtng that you 

have ceased such employment and the Trustees determine that you still satisfy the requirements for 

the Disabled From The Trade Benefit You may obtain a resumpHon of benefi!s forrn irorn the Plan 

Administrator, 

8. What happens If l rocover from my disability? 

!f tt is determined that you are no longer Dlsabled From The Trade, your benefitswlll be stopped, 

DEATH BENEPffS: 

1. What if J die before l retire? 

If you are married and you die after you have five (5) Years of Vesting Service, but before you retire, 

or while yoLl are receiving a disabirity pension, your spouse wi!I receive a Pre-Retirement Surviving 

Spouse's Benefit. This benefit provides your spouse wllh a penslon equal lo the monthly benefit that 

would havo been payable If you had retlred on ihe day before your death and elected a Joint & 50% 

Survivor form of pension payment. Payment of the Pre-Retirement Surviving Spouse's Benefit wlH 

begin on the first day of the month following the date on which you died, or if later, the first day of the 

month fol!owlng the month in which you would have attained age 55. 

If you die before retirement and are not married, or if you are married and have fewer than five (5) 

Years of Vesting Service, you wiH not receive a benefit from the Plan, 

23 

SWORCCPP2018-000348
2. Arn there any benefits payable upon my death when I die after I retire? 

lf you are receiving your pension In ihe form of a Stngle Ufe Annuity, which provides you v.~!h a 

monthly benefit payable for your lifetime only, your benefits wm cease with your death. 

If you are receiving your pension in the form of a, Joint and Survivor Annuity, after your death your 

spouse wiH receive a monthly payment according lo the Joint and Srnvivor Option elected at 

retlreinent. 

If you are receiving your pension in the form of a Ufe Annuity with 120 Payments Guaranteed, and 

you die before receiving al least 120 monthly payments, any rernalnlng payments wHI be made to 

your designated beneflc!arr 

3. How do [ designate my beneficiary? 

Because there are non-spousal death benefits under !he Plan in some limited circumstances, such 

as a single life annuity with a iO year certain pa)1ment, a beneficiary deslgnaUon form should be 

completed and filed with the Plan. You may designate your beneficiary at the time you elect your 

form of retirement benefit 

4. May l dMlgnate someone other than my spouse to receive the death benefits payable 

umler the Pian? 

Yes. You may designate any pGrson of your choosing to receive your remaining ·to year certain 

benefits if you elect such form, arid die prior lo receiving 10 years of payments. However, if you are 

married, your spouse must consent to this in writing for the eledlon to be valid. Your spouse's 

consent must also acknowledge fhe effect of the waiver of the survivor benefit, and mtist be 

witnessed fn writing by a Plan Representative or a notary public, ff this waiver is not signed and you 

are manied at the time of your death, then your spouse will receive the death benefit 

NOTE: This does not apply lo the Joint and Survivor torrn of payment, nor to the Pre-Retirement 

Surv!vtng Spouse benefil The beneficiary of those benefits must be the person to whom you were 

married when Joint and Swvivor Annuity began, or in the case of the Pre-Retirement Surviving 

Spouse benefit, the person to whom you were married when you died. 

5. What If l die before my Normal Retirement Age whHe ! am receiving a monthly 

dlsab!l!ty benefit? 

1f you are not married at the timi;; of your death, no further benefits will be paid lo you, your estate 

or yolir beneficiaries. 

If you are married at the tlme of your death, your surviving spouse wlll receive !he Pre-Retirement 

Surviving Spouse Benefit {Page 23, Ouestfon Number 1). 

24 

SWORCCPP2018-000349
TERMINATION OF BENEFITS: 

1. Will f be entitled to any benefits If I stop working in Covered Employment before my 

early retirement age? 

If you have at least five (5} Years of Vesting Service when you stop working in Covered Employment, 

you will be entitled to a pension al age 62 equal to your earned penslon at the time you stopped 

working in Covered Employment. 

If you deslre, your pension can begin as of the first day of ar1y month toHowrng your 551

i' birthda>1, but 

il will be payable in a reduced amount as provided under Early Retirement. 

PROVISIONS RELATING TO VETERANS' REEMPLOYMENT: 

1. What happ,ms io my benefits under the Plan if l enter military service? 

Federal law governs your rights !f you enter the mllltary. It is possible fot you to receive credit (for 

both service and benefits) if certain conditions are met. 

To protect your rights under the Plan, you must leave the geographic Jurlsdldlon of ihe Plan for 

seNice ir. the uniformed military service before your partlcipailon ceases, and you must notify your 

Employer (or the Plan Administrator) before you leave. (The notification requirement is excused by 

federal law lfyou could not give advance notice because of militaiy necessity or if giving the advance 

notice was impossible for unreasonable.) 

To further protect your rights under the Plan, you must apply for work in Covered Employment within 

a certain period of time after you are released from military duty under honorable conditions, The 

time period durlng which you must apply depends on how long you served In the miiitary service, as 

fo!IOVJS'. 

If th€! period Of servlco In the uniformed . 

Applicahle.deadHne; ~services: 

Consisted solely of a physical or medical By the beginning of the next regular work 

examination to verify fitness period 

Within one day after discharge (allowing Lasted fewer thsn 31 days 

travel time plus 8 hours) 

Lastc<l mom than 30 ctays but fewer than Within i4 days after discharge 

18i days 

Within 90 days after discharge Lasted for 180 days nr more 

Ends while you are hospltaltzed or Atter you have recovered, but not more 

than two years after the injury or illness convalescing from an injury or illness 

incurred in the uniformed service 

25 

SWORCCPP2018-000350
You must then nollfy the Plan Administrator of your military service in writing no later than 120 days 

after the applicable deadline for re-applying for work in covered Employment. The Plan 

Administrator wm request that you provide written documentation regarding your service in the 

uniformed l.>ervices. 

lf you satisfy the requirements for protecting your rights as a veteran, and provide the Pian 

Administrator wlth the documentation necessary io verify your military service, you will receive credit 

for eligibility, vesting and benefits under !he Platt Credit for benefit service is limited to a maximum of 

five (5) years, and wm be reduced by prevlous periods of milftary service. Generany speaking, tho 

benefits credited to you for your milltary service vvill be based on the number of hours you worked in 

Covered Employment during the 12-month period that immediately preceded your entry into military 

service. 

For purposes of federal law, your military service may be with the Armed Forces of the United States, 

the Army National Guard or the Air Nallona! Guard when engaged ln aclive duty for training, inactive 

duly training or full-lime National Guard duty, ihe Commissioned Corps of the Public Health Servlce 

and any other category designated by the President ln time of war or emergency. "Service" means 

the performance of duly on a voluntary or involuntary basis, including active. duty, active duly for 

training, initial active duty for training, inactive duty training, full-time National Guard Duty, and a 

period for which you are absen! from etnployment for a physical exam!naliof'l to determine your ability 

to perform service in the uniformed services. 

APPUCAT!0N FOR BENEFITS, CLAIM$ PROCEDURES AND APPEALS PROCESS: 

1. How do I apply for Pension Benefits? 

Call the Plan Administrator and request the necessary application form. This fonr1 must be 

completed and returned at least one (1) month in advance of fhe first month in whlch you want 

benefits to start The Plan Administrator wiH tell you what other documents must be furnished, 

Your application will be presented to the Board of Trustees (or, in the case of a dalm for a drsabl!ity 

benefit, lo a subcommittee), v,;hlch must approve au benefits. 

2. When wll! l !J-e noUfied about the status of my application for benefits and what 

Information will I receive? 

ff your app!lcafion for benefits (other than a disability benefit) is denied in whole or In part, you 

(or your beneficiary in the case of a death benefit) or your authmized representafive will be 

notified ln writing. This notification wm include: 

D the specific reason or reasons for the denial; 

D specific references to the Plan provlslons on which lhe deri!al was based; 

D a description of any additional material or Information nee.ded lo perfect your c!alrn and 

an explanation of why !hat material or h,fonnallon ls needed; and, 

Cl an explanation of the procedure for appealing the denial of your claim. 

26 

SWORCCPP2018-000351
The wrltten explanation will normally be provided wlthln 90 days after the c.faim is flied. However, 

if special circumstances require, the Board of Trustees may take up to an addiUonal 90 days to 

notify you of its decision. The Board will nofify you of this extension and the reason for the delay 

before the end of the initial 90-day period. 

If your application for a disability benefit is denied in whole or in part, you will be notified in 

wr1ting. This notification will include: 

U the specific reason or reasons for the denial; 

o specific references to the Plan provisions on which the denial was based; 

D a descrrption of any additional material or information necessary to perfect your claim and 

an explanation of why that malarial or information is needed; 

O an explanation of the procedure for appealing the denial; 

D a statement of ,1our right to bring a clvil action under Section 502 of ERISA fo!lowlng a 

denial of your claim on review; 

D notification of the right to receive, upon reques~ a cop}' of any internal rules, guideBnes, 

protocols, or other similar criteria used as a basis for the denial; and, 

O no!lfication of the right to receive, upon request, an explanation of the sclenHfic or cHnical 

judgment that was used in applying the terms of the Plan to the medical circumstances. 

You wm be notified in writing of any decision about your claim for a disability benefit within a 

reasonable period of time, but not later than 45 days after yo~i submit your claim. However, this 

45-<iay period may be extended for an additional 30 days if necessary due to matters beyond the 

control of the Plan. A second 30-day extension is also permitted. 

if any information is missing from your claim, you wiH have 45 days to provide the missing 

Information. 

You may request copies of aH documents, records and other information rek,vant to the denied 

claim. You may also request access to: 

u any policy, statement, or guidance concerning the condition, regardless of whether it s,vas 

relied upon in the denial; and, 

 the Identity of medical or vocational experts whose advice was obtained on behalf of the 

Plan In connection with the denial, regardless of whether the advice was relied upon in 

the denial. 

You may file a written appeal, al your own expense, of the denial of your claim for a benefit (other 

than a disability benefit) with the Board of Trustees. If you want to appeal an application that has 

been denied, be siire to do so within 60 days after the denial. You (or your beneficiary in the 

case of a death benefit) or your authorized rapresentaUve has Um rlght to review any pertinent 

dootiments relating to the application and to submit any comments in wrtling. 

The Board of Trustees wl!! generally acl on the appeal w1thin 60 dats after receiving your request 

unless special circumstances, such as the need lo have a meeting, require a longer period of up 

io an additional 60 days. You will be informe-d, in writing, of the decision, with a foll explanation of 

the specific reasons for the final decision. 

27 

SWORCCPP2018-000352
Appeal Procedures for Denial of Disabmty Benefit 

If your clatm for a <Hsability benefit is denied, you or your authorized representative may appeal, 

at your own expense, the denial of your claim wlth the Board of Trustees. You must make your 

appeal within 180 days of the date you received written notice of the denial. You or your 

authorized representative; 

D may request in writing that the Board of Trustees review the denial; 

 may revlew pertinent documents; and, 

o may submit issues and comments in wrlting. 

The decision to revlew your claim wl!I be made wiU1in a reasonable period of lime, but not later 

than 45 days after the Board of Trustees receives your request for review. If there are special 

circumstances requiring an extension of time for processing your appeal, a decision will be 

rendered as soon as possible, bul not later than 90 days after receipt of the request for review. If 

Stich an extension of time is required, written notice of the extension wm be furnished before the 

end of the origfnal 45-day period. The decision on review will be made in writing; will be wrilten in 

a manner designed to be eas!ly understood; and wiH include specific references to lne provisions 

of the Plan on which the denial is based, If the decision on review is not furnished within the time 

specified above, the claim will be considered denied on review. 

3. What rights do r hav~ following my appeal? 

if you have exhausted your daim review and appeals rights under the procedures set forth above, 

you may pursue any other legal remectres ava!lab!e, which may Include bringing a civil action 

under ER!SA Section 502(a). This provides for judicial review of the adverse determination 

regarding your claim in order to recover benefits due !o you under the Plan's terms, to enforce 

your rights under the Plan's terms, or to clarify your rights to future benefits under the Plan. You 

may obtain additional information about your right to pursue other legal remedies from the local 

office of the United States Department of Labor. 

MISCELLANEOUS: 

1. Who administers the plan? 

As requlred by federal law, the Plan ls administered by an equal number of labor and management 

trustees. 

2. Who contributes to the Plan? 

Only Employers contr/oute to the Plan, No employee contributions are permitted. The collective 

bargaining agreement or participation agreement determines tbe amount of contributions the 

Employers make to the Plan. 

If you work for a Contributing Employer that becomes definquent in making contrtbutions to the Plan, 

you may be entitled to certain vestlng and benefit credit If you work in Covered Employment. You 

tnust furnish the Fund Office with proof of hours worked ln Covered Employment, such as check 

stubs or copies of employee checks, along with evidence satisfactory to the Trustees thal idenfifies 

28 

SWORCCPP2018-000353
fhe geographic location of jobs worked. If you do not provide sufficient employment records and 

detail Indicating the number of hours work in Covered Employment for a delinquent employer, you 

will not be eligible to receive vesting and benefit service credit for the delinquent contributions. 

3. How are the funds to provide pension benefits accumulated? 

The Plan is funded by a trust. The Southwest Ohio Regional Council of Carpenters Pension Trust 

Fund holds and invests !he Employer contributions made to the Pian. Assets in the Trust are 

invested by registered investment managers. these Plan assets, as well as any earnings that may 

accrue on the assets, are used to pay participant benefits and Plan expenses. 

4. Will I rnceive a statement of my status under the Plan? 

Yes. Once each year, you wHI receive a stalBment of your Vesting Service, earned monthly 

pension, and accumulated Death Benefit through the previous December 31. 

5. Can I assign my benefits under the Plan? 

Generally, no. However, Federal law allows all or a portion of your pension benefit to be allocated 

to a former spouse under the term_s of a Qualified Domestic Relations Order (QDRO) arising !n 

connection with a divorce or d!ssolutlon. A Domestic Relat\ons Order must satisfy certain 

conditlons to be considered ''Qualified" under the Internal Revenue Code. The Plan Administrator 

wit! be able to assist you if you are faced with such a situation. Please note that under any 

QDRO, the Plan cannot be required to pay any form of bahetit that it would not ordinarl!y pay to a 

Plan participant, such as a lump sum payment. Also, the Social Security Supplemental 

Benefit/Retirement Incentive 8enefit is not payable to an Alternate Payee under a Quafified 

DomesUc Relations Order. 

Parliclpants and bQneflclarles can obtain, without charge, a copy of the Plan's procedures 

govemlng Qualified Domestic Relations Orders. A request should be directed to the Board of 

Trustees al !he address noted on Page 2. 

6. Can the Plan be changed (amended) or termlnatetl? 

The Trustees reserve !he tight to amend the Plan at any time. 

The Plan can only be terminated as a result of collective bargainlng. lf the Plan fs terminated, you 

will be vested in your benefit as of the effective date of the termination, and the value of the benefits 

you earned through the date of terminaflon will be paid to you when you would have been e!lglble for 

a pension benefit lf the Plan had not been tem1inated. 

7. Are my benefits i1nderthe Plan insured? 

Your pension benefits under this multiernp!oyer plan are insured by the Pension Benefit Guaranty 

Corporation (PBGC), a federal insurance agency. A multiemployer plan is a co!lec!lvely 

29 

SWORCCPP2018-000354
bargained pension arrangement Involving two or more unrelated employers, usually in a common 

industry, 

Under the multiemployer plan program, the PBGC provides financial assistance through loans to 

plans that are insolvent. A mumemployer plan is considered insolvent If the plan is unable to pay 

benefits (at least equal to the PBGC's guaranteed benefit limlt) when due. 

TI1e maximum benefit that [he PBGC guarantees is set by law. Under the mu!tiempioyer 

program, the PBGC guarantee equals a participant's years of servlce muftlplied by (1) ·t 00 

percent of the first$'! i of the monfhly benefit accrual rate and (2) 75 percent of the next $33. The 

PBGC's maximum guarantee limit rs $35.75 per month times a participant's years of se;vice. For 

axamp!e, the maxlrnum annual guarantee for a retiree with 30 years of service would be $12,870, 

The PBGC guarantee generally covers: (i) normal and early retirement benefits; (2) disability 

benefits if yoL1 become disabled before the plan becomes insolvent; and, (3) certain be11efits for 

your survivors. 

The PBGC guarantee generally does not cover: (1) benefits greater that the maximum 

guaranteed amount set by !aw; (2) behaflt tncreases and new benefits based on plan provislo11s 

that have bean in place for fewer than five years at the earlier of: (i) the dale the plan terminates, 

or (H) the ttme the plan becomes insolvent; (3) benefits that are not vested because you have not 

worked long enough; (4) benefits for which you have not met a!! of the requirements at the time 

the plan becomes insotvent; and, (5) non-pension benefits, such as health insumnce, life 

Insurance, certain death benefits, vacation pay and severance pay. 

For more information about the PBGC and the benefits it guarantees, ask the Plan Administrator or 

contaci the PBGC's Technical Assistance Division, 1200 K Street N.W., Suite 930, Washington, D.C. 

20005-4026, or call 202-326-4000 (not a toll-free number). TTYffDD users may call the federal relay 

service toll-free at 1-800-877--8339 and ask to be connected to 202-326-4000. Additional information 

about the PBGC's pension insurance program is available through the PBGC's webslle on the 

Internet at http:/.1\vww.pbgc.gov. 

8. Are there legal documents covering the Pl.-m? 

Ye.<1. This ls only a summary of the more Important features of the Plah. The legal documents 

containing all the details are on tile in the Plan Administrator and consist of the Plan and the Trust 

Agreement. The administration of the Plan and Trust are governed in alt respects by these legal 

documents. 

30 

SWORCCPP2018-000355
STATEMENT OF YOUR ER[SA RIGHTS 

(THE EMPLOYEE RETIREMENT INCOME SECURiTY ACT OF 1974, AS AMENDED) 

As a participant in fhe Southwest Ohio Regional Council of Carpenters Pension Plan, you are entltled to 

certain rights and protectlons under the Employee Retirement Income Security Act of 1974 (ERISA), as 

amended. ERISA provides that all Plan participants shall be entlUed to: 

 Examine, without charge, at the Plan Administrator's office and at other speclfled 

locations, such as worksltes and the Union HaH, all documents governing the Ptan, 

including collective bargaining agreements, insurance contracts, and copies of the latesl 

annual report (Form 5500 series) filed by the P!an with the U.S. Department of Labor and 

available at l:he Public Disclosure Room of the Employee Benefits Security 

Administration. 

 Obtain, upon written request to the Board ofTrustees, copies of documents governing tho 

operation of the Plan, inc!udlng collective bargaining agreements, Insurance contracts, 

copies of the latest annual report {Form 5500 series), and an updated summary plan 

description. A reasonable fee may be charged tor copying expenses. 

 Receive a sumrnary of the Plan's annual financial report, The Board of Trustees is 

required by law to furnish each partic1panl with a copy of the Plan's Summary Annu1;1[ 

Report. 

 Obtain a statement telling you whether you have a right to receive a pension benefit at 

Normal Retirement Age {the later of age 62 or the fifth anniversary of Plan participaUon, 

with participation before a Forfeiture of Service disregarded) and, If so, what your benefits 

would be at Normal Retirement Age If you stop working under the Pian now. Jf you do not 

have a right to a pension benefit, the st.,tement wll! tell you how many more years yoL1 

have to work to be entitled to a pension. This statement mL1st be requested in writing 

and is not required to be given more !han once every i2 months. The Pian must provide 

this statement free of charge. 

in addition to creating rights for Plan participants, ER!SA imposes duties upon the people who are 

responsible for the operation of an employee benefit plan. The people who operate the Pension Plan, 

called "fiduciaries" of the Plan, have a duty to cto so prudently and In the Interest of Plan participants and 

beneficiaries. 

No one, including your employer, your Unlot1, or any other person may fire you or otherwise dfscrlminate 

against you In any way to pre.vent you from obtaining a pension benefit or exercising your rights tmder 

ERIS.A.. 

If your claim for a penslr;n benefit is denied or Ignored, in whole or in part, you have a right to know why 

this was done, to obtain copies of documents relating to the dedslon wlthout charge and t.o appear any 

denial, al[ withln certaln time schedules. 

SWORCCPP2018-000356
Under ERtSA, there are steps you can take to enforce the above rights. For exampte, if you request a 

copy of Plan documents or the latest annual report from the Plan and do not receive them within 30 days, 

you may file suit in a Federal court. In such a case, tha court may require fhe Board of Trustees fo 

provide the materials and pay you up lo $110 a day until you receive the materials, untess the materials 

were not sent because of reasons beyond the control of the Board of Trustees. 

If you have a c!alm for benefits that is denied or ignored, !n whole or ln part you may fl!e suit In a state or 

Federal court, In addlilon, lfyou dtsagree with the Plan's decislon or lack thereof concem1ng the qualified 

status of a domestic relatlons order, you may file sutt in Federal court. 

!f rt should happen thal Plan fiduciaries misuse the Plan's money, or ff you are discriminated against for 

asserting your r1ghts, you may seek assistance from the U.S. Department of Labor, or you may file suit in 

a Federal court. The court will decide who should pay court costs and legal fees. If you are successful, 

the court may order the person yoL1 have sued to pay these cosls and fees. lf you lose, the court may 

order you to pay these costs and fees, for example, if it finds your claim is frivolous. 

lf you have any questions about your Plan, yoLl should contact the Board of Trustees. !f you have any 

questions about this statement or about your rights under ER!SA, or if you need assistance in obtaln[ng 

documents from the Board of Trustees. you should .contact the nearest office of the Employee Benefits 

Security Administration, U.S, Department of Labor {see your local telephone directory) or the Division of 

Technical Assistance and tnqulries, Employee Benefits Security Administration, U.S. Department of 

Labor, 200 Constitution Avenue, N.W., Washington, DC 20210, You may obtain certain pubHcations 

about your rights and responstbiliUes under ER!SA by calling the publications hotline of the Employee 

Benefits Security Administration. 

32 

SWORCCPP2018-000357
65 

APPENDIX A 

REDUCTION FACTORS FOR EARLY RETIREMENT 

UP-1~84 MORTALITY TABLE AT 7.0% 

MEMBER 

YBAR$ 0 1 z 3 

62 1.000000 

Si 0.899718 0.907300 0.915011 0.9228GG 

60 

l 

O.ilii:'!55 0.1Hll050 fl.llM1l57 (Lll31771l 

59 0.7:i:l247 0.7:39177 0.745204 0.751:'.l:'.lO 

58 I 0.663996 0.669264 0.674El15 0.680053 

57 0.602424 Q,607115 0.6ti881 -0.616721 

i .._..__._ 56 0.547533 0.551722 0.555976 0.560296 

0.4\/3472 tl.60%222 0.51'5029 0.5098!>4 

COMPLETED MONTHS __ ,_ ---·--·-· 

4 6 6 7 8 I 

-····- ··--··· 9 10 11 I 

il.fl:lilil;t::I 0.931!951 OJ,47212 i'l,!lf,fif,20 n.00117e \ 0.972091 0.901762 0.990797 

0.038-816 0.845974 (),853255 OJl60oaa 0.86ti20 • 0.87587t 0.883678 0.891$26 

-0.757557 0.763888 0.770325 0.776874 0.783534 0.79-0306 0.797202 0.604216 

0.685579 0.691196 0.696906 0.702710 0,7086·13 0.714615 0.!20719 0.726929 

0,621639 0.62663(5 . 0.6&1713 0.63(,874 0,642·120 0,847453 0.65W75 0.658$89 

0.5!,4683 0.560140 _0__._57'Jf,68 0.5782o9 0.582944 Q,til>.!!,iU5 0.692524 O_otf/43:l 

0.b131'\19 0.517804 0.521852 0J,i26983 il.530140 0_53,,384 0.G'.10090 OI:,43078 

SWORCCPP2018-000358
APPENO!XB 

SUMM,\!lY (WSt/S'J>.l!J'ISlON Ol? lni:NJ.Wl'fS 1•1WVJS!ON$ trcm THK SOUTHWEST omo REGIONAL

COUl'lClL or: CAl<f'ENTERS"Pl~NSlONnJ..N 

!Mor~ April ;10, 201& Will',!'( J>W Y(ll) Rt:"B.IW? 

. ·---~-... A!UlYOU; AtrnYOI), 

Yotl/1/,<i lls1!l"t~62 ----' llavo yell! Jlav< }'O~ mnkcd ttl loo.\l 481! • W"<kcrl !n lite !;nma ()f11rwlc~ h> llw l!;i'/e y-ou: Pu"r/b 11.- wo, h~l 4SO hourn

Jn,!11;1,;; t(»'c,rd 1,, hwh>,11)' e,1\'¢m! l>y lliQ Pinn • \l',>rkcd h, l)m <)f ~mk~ in 11,¢ iodllliur

!lwPlan; in !he p,totr.>jlhk 4r¢~ lnd11Slry wvereu by coverc-d hy tho !'411 lu 11><:

• RQt,,1J~;of,\hm, e,;,1\'1l.",l or th~ c11llcC1h'C !l1tl'lt&!l, i;,,o,;rop\J.o """' covan:<lhy

!l,e W(l{k •=mtl"" Lr~gaiohig Rgted t:cnt i11ufog • ll!:p,a:rlle,H,ftl:c th¢ c~lle.:tlvo hni'{',,lllio~

th¢ m1mltei c,fhuur.s"i IMtrurodarym? 1rnui\,s-r <:>rh,;,trr,; "t"""'""' tlu,ine tho

• R•coi.!l.,.H>f whtro .--.;lm)iir,(m'/

YFS L. lltr wiuk txcmml1 ND 

ll<l><Hl>·<>)<tuco1 AFl13R

Junc%,20<'.15ruolruSJ""Hfod

\!lllll }\>U )~i~ll Ofji' ~2. 

. ----- , _____ ...S'-----------, iJ:~ttfil~mu 

Yl1~ 

llmcm, M'w,ps;n<k<l. fo1 "'"PIT,;lt<f until >fnv1: )~\I \1⁄4)!}a.":,J al lc:.Jl'\1 ~itO c•oh ,~muini Ill/ m;m!l1 fo lh.: ~v.uctieh ai:,c 62, .,,.,,. in lh;'1n,~,u,v °'<"'««\ c;,k1wM:/Nt f,1 wlu.-.!1 yon hy 1hu 11,u In th<> ii::<>t"'1•hlc ,1wke1 ko\1 M,h,)urnof M<~ ewe.ltd by !l~ Prm ptfo1 iet'Yiccf 14 utl\>lnln,: ~;;• !,2. -------------·---

....

vr-s

s, ....... ---•·• lltlltfltsmrued onrolm Joo; 30, I',_....,.,.......,...,J 1005 "'t.su,p,,,>skd fotr.u:h

1t·..inrt:ning numili in tho~J1t."'i')<t.:tr

~<idrt,vhkh }'¢11 \\-t.k Ji! lt01I !

l.tv-J.r-ufnn·k\!, 

SWORCCPP2018-000359
Southwest Ohio Regional Council of Carpenters' 

Fringe Benefit Funds 

Health Fund: P.O. Box 1257, Troy, MI 48099 

Pension Fund: 33 Fitch Blvd., Austintown, OH 44515 

Phone: 330-779-8862 

Website: www.ocbenefits.org 

SOUTHWEST OHIO REGIONAL COUNCIL OF CARPENTERS PENSION PLAN 

IMPORTANT NOTICE REGARDING PLAN BENEFITS 

June 29, 2018 

This Notice outlines the changes that have been adopted by the Board of Trustees and is 

intended to be a summary of material modifications and notification of reductions in Plan 

benefits. You should keep this letter with your Summary Plan Description ("SPD") booklet. 

Effective August 1, 2018, the Plan will no longer provide for a benefit for Trade Disability. 

As defined by the Plan, a Trade Disability meant a disability that based on medical evidence 

satisfactory to the Board of Trustees a person is unable to, as a result of bodily injury or disease, 

to perform any of the work described in the Collective Bargaining Agreement for the remainder 

of his or her life. The Trade Disability benefit was available for a Participan t with at least 5 Years 

of Vesting Service, who was not eligible for a Normal or Early Retirement Benefit, who incmred 

a Trade Disability and on whose behalf Employer conh'ibutions were made during the 12-

month period immediately preceding the date of his or her Trade Disability. The Trade 

Disability benefit was a full actuarial reduction of a participant's Accrued Benefit based on the 

number of months the participant commenced benefits prior to his or her Normal Retirement 

Date. The Trade Disability Benefit has been eliminated and shall no longer exist as of August 1, 

2018. 

Effective August 1, 2018, the Plan's definition of "Total and Permanent Disability" for 

purposes of receiving a Disability Benefit from the Plan shall mean a determination by the 

Social Security Administration that an individual is totally and permanently disabled and 

entitled to a disability benefit under the Old Age and Survivors Disability Insurance 

(OASDI) program. Previously, "Total and Permanent Disability" meant that based on evidence 

satisfactory to the Board of Trustees, a person is totally unable, as a result of bodily injury or 

disease, to engage in any fmther employment or gainful pursuit for the remainder of his or her 

life. Thus, on and after August 1, 2018, any application for Disability Benefits will require a 

detemtination from the Social Security Administrntion that the individual is total and 

permanently and entitled to a disability benefit under the Old Age and Smvivors Disability 

Insurance (OASDI) program. 

Effective August 1, 2018, the Plan's Earliest Retirement Date shall be defined as the first day 

of the month prior to the Normal Retirement Date as of which the Participant attains the age 

of at least 55 years and has completed at least 5 Years of Vesting Service. Previously, the 

Earliest Retirement Date was defined as the first day of the month prior to the Normal 

Retirement Date as of which the Participant attained the age of at least 50 years and had 

completed at least 5 Years of Vesting Service. 

Sincerely, 

Board of Trustees 

SWORCCPP2018-00!Hi8 
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #38 – 7.07 Collective Bargaining Agreements 

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

and side agreements? 

See Section 7.07 of Revenue Procedure 2017-43. 

The required the required excerpts from the relevant collective bargaining agreements and side 

agreements are listed on Document 38.1. 

SWORCCPP2018-000361
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 38.1 

Excerpts from Collective Bargaining Agreements 

1. 2017-2020 Southwest Ohio Carpenters' Agreement between West Central Ohio Division 

General and Forming Contractors Section of the Labor Relations Division Ohio Building Chapter, 

Inc. Associated General Contractors of America and Carpenters & Lather Employers Division of 

the Walls and Ceilings Contractors Association of Greater Cincinnati and Labor Relations 

Division, Cincinnati Division, AGC of Ohio, Inc., Associated General Contractors of America and 

Indiana / Kentucky / Ohio Regional Council of Carpenters United Brotherhood of Carpenters and 

Joiners of America. 

ARTICLE XIII 

HEALTH & WELFARE, ANNUITY, PENSION PLANS 

(97) Pension Plan – During the continuation of this Agreement, and subject to the limitations 

provided in Section 2.4 of the Pension Plan Agreement, each Employer shall pay to the Pension Trust 

Fund, for each hour such Employer compensates each Employees at his/her straight time or overtime 

hourly rate in the amount as stated and approved in the Zones of this Agreement. 

(98) The contribution payments of the Employer shall be used exclusively to provide pension benefits 

to eligible employees in such form and amounts as the trustees of the pension fund may determine, 

including allowances for the organization and administration expenses of the Pension Fund. 

(99) The Pension Fund shall be administered pursuant to an Agreement and Declaration of Trust 

administered jointly by an equal number of representatives from the Association and the Union, which 

Agreement and Declaration of Trust, together with any amendments thereto, shall be considered as part of 

this Agreement, as though set forth here at length. The Pension Fund increases as stated in the 

Memorandum of Understanding relative to the Rehabilitation Plan are to be considered temporary 

increases. Once the Plan is 100% funded the Union agrees to limit the contribution rate to a maximum of 

20% of the wage rate. 

2. Agreement between Indiana / Kentucky / Ohio Regional Council of Carpenters United 

Brotherhood of Carpenters and Joiners of America and Cedar Fair Southwest, Incorporated d/b/a 

Kings Island – Effective date September 1, 2014 – August 31, 2019. 

"VI. PENSION PLAN 

The Employer hereby agrees to pay each month the per hour contribution amounts set forth in 

Appendix A, below, to a Pension Fund for each employee covered by this Agreement as follows: 

The Employer shall pay to the Plan Trustees for credit to the Pension Fund, for each hour worked 

by the employees at the applicable straight or overtime rate established by the Master Agreement 

then in effect. 

The Union shall give the Employer thirty (30) days written notification of the applicable rates and 

any changes therein. 

The contribution payments of the Employer shall be used exclusively to provide pension benefits 

to eligible employees in such form and amounts as the Trustees of the Pension Fund may 

Document #38.1 

SWORCCPP2018-000362
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

determine, including allowances for the organization and administration expenses of the Pension 

Fund. 

The Pension Fund shall be administered pursuant to an agreement and declaration of trust 

administered jointly by an equal number of representatives from Employers and the Union, which 

agreement and declaration of trust, together with any amendments thereto, shall be considered as 

part of this Agreement, as though set forth here at length. 

No contributions shall be accepted by the Trustees of the Funds unless a signed copy of this 

Agreement or other document binding the Employer to the obligations hereto is on file. 

The monthly contribution period shall include the Employer’s last full bi-weekly pay period of 

the month reported on report forms furnished by the Funds. Said report and contribution 

payments are due and payable on or before the twentieth (20th) day of each month for all 

amounts due for the preceding month(s) and forwarded in accordance with the instructions on the 

forms. Failure on the part of the Employer to pay the amounts due by him shall be deemed a 

breach of this Agreement by the Employer." 

3. Southwest Ohio Residential Agreement 2014-2017 between West Central Ohio Division 

General and Forming Contractors Section of the Labor Relations Division Ohio Building Chapter, 

Inc. Associated General Contractors of America and Labor Relations Division, Cincinnati Division, 

AGC of Ohio, Inc., Associated General Contractors of America and Indiana / Kentucky / Ohio 

Regional Council of Carpenters United Brotherhood of Carpenters and Joiners of America. 

ARTICLE VI. 

WAGE RATES AND CONTRIBUTIONS 

Section 2. The Employer agrees to participate in and make contributions towards the appropriate 

Fringe Benefit Funds as set forth in the attached Appendix, the contents of which are hereby incorporated 

herein. 

Section 3. Each Employer agrees to permit an audit or examination of such books, records, papers 

or reports of the Employer as may be necessary to determine whether the Employer is making full and 

prompt payment of all sums required to be paid by it to the Fringe Benefit Funds referenced in the 

attached Appendix. The audit or examination shall be performed by the appropriate Fringe Benefit 

Fund(s) auditor or by its/their agents; provided, however, at the Employer’s request and own expense,

such audit or examination shall be performed by an independent certified public account acceptable to the 

Fringe Benefit Fund(s). If, as a result of said audit or examination, a substantial deficiency in payments 

to the Fringe Benefit Fund(s) of said audit or examination, a substantial deficiency in payments to the 

Fringe Benefit Fund(s) is discovered, the Trustees of the Funds may assess their costs in performing the 

audit or examination to the Employer, and said costs shall be collectible as any other amount due from the 

Employer of the Funds. 

Section 4. The respective Trustees and their respective successors in office under each of the 

Agreements and Declarations of the Trust of the Fringe Benefit Funds referenced in the attached 

Appendix shall be deemed to be joint and several beneficiaries of this Agreement for the purpose of each 

or all of the said Agreements and Declarations of Trust and shall, in addition to and with or without the 

Union, have standing to use on this Agreement to enforce the terms of said respective Agreements and 

Declarations of Trust. A delinquent Employer shall also be liable for and obligated to pay the 

delinquency assessments provided for herein, reasonable interest, all court costs, attorneys’ fees and other

expenses incurred by the Trustees in the collection of contributions due from said delinquent Employer. 

Document #38.1 

SWORCCPP2018-000363
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Trustees shall further have all such other relief (including temporary and permanent injunctive relief) 

and remedies against a delinquent Employer to which they may be entitled at law or in equity. The 

Trustees may compel and enforce the payment of contributions in any manner which they deem proper; 

and the trustees may make such additional rules and regulations to facilitate and enforce the collection 

and payment thereof as they deem appropriate. 

Section 5. The contribution and deductions designated in the Appendix shall be due on the fifteenth 

(15th) day of each calendar month for the hours worked during the preceding calendar month and shall be 

sent with an appropriate reporting form to C.P.I., except as herein provided. 

Section 6. Any Employer who is delinquent in making its payments as herein required or who fails 

to file an accurate and acceptable monthly report by the thirtieth (30th) day of the calendar month in which 

the report, contributions and deductions are due shall be subject to one (1) or more of the following: 

A. A liquidated damage assessment on behalf of the Funds based on the current 

interest rate charged by the Internal Revenue Service for late payments of Federal 

income taxes. 

B. The services of the Employees may be withheld from the Employer after the 

provision of at least five (5) days’ notice to the Employer by telegram or certified

mail of the Union’s intention to do so because of the Employer’s delinquency.

No such work stoppage shall be considered a breach of this Agreement or any 

other Agreement. 

C. The Employer may be required to post a bond of double the delinquent amount of 

Ten Thousand Dollars ($10,000.00), whichever is greater. 

D. The Employer may be required to remit the required report, contributions and 

deductions on a weekly, rather than monthly, basis. 

4. Southwest Ohio Floorlayers Agreement 2014-2019 between the Indiana / Kentucky / Ohio 

Regional Council of Carpenters United Brotherhood of Carpenters and Joiners of America and the 

signatory employer that executes the agreement. 

PENSION FUND 

Section 1. The COMPANY agrees to contribute to the Southwest Ohio Regional Council of 

Carpenters Pension Plan, or its successor for each straight time and each overtime hour worked by 

Employees covered by this Agreement at the contribution rates then in effect as set forth in the 

Appendices which the UNION shall make available to the COMPANY. 

Section 2. The COMPANY shall make its Pension Fund contributions to the Corporate Trustee. 

Section 3. The COMPANY shall pay its contribution to the Corporate Trustee monthly on or before 

the 20th day of each calendar month on account of hours for which it compensates Employees during the 

preceding calendar month. With each such payment, the COMPANY shall deliver to the Corporate 

Trustee a schedule relating thereto in such form as the Board of Administration of such Plan requires. 

The Board of Administration of said Plan may require weekly contributions from the COMPANY to the 

extent provided in paragraph (b) of Section 2.3 of the Pension Plan Agreement. 

Document #38.1 

SWORCCPP2018-000364
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Section 4. The COMPANY hereby adopts the Pension Fund’s Agreement and Declaration of Trust

and consent to the appointment of the current and all future management Trustees. 

5. Labor Management Agreement by and between the City of Cincinnati and the Cincinnati 

Building Trades Council (as agent for the Indiana / Kentucky / Ohio Regional Council of 

Carpenters United Brotherhood of Carpenters and Joiners of America), effective August 1, 2015. 

“ARTICLE 17 

RETIREMENT SYSTEMS 

All Bargaining Unit employees may remain in their current retirement system, subject to the rules, 

regulations, and the requirements enacted by the appropriate governing body. All future new hires, who 

are not currently in a State of Ohio public retirement system, shall become members of the City of 

Cincinnati Retirement System." 

6. Millwrights Local No. 1090, Southwest Ohio, Indiana / Kentucky / Ohio Regional Council of 

Carpenters United Brotherhood of Carpenters and Joiners of America and the signatory employer 

that executes the agreement, effective date September 1, 2016 – August 31, 2019. 

Section 10 

Pension 

The employer hereby agrees to pay each month the per hour contributions amounts set forth below to a 

pension fund for each employee covered by this agreement as follows; all pension contributions shall be 

paid as per hours worked as per wage sheet. The contributions payments of the employer shall be used 

exclusively to provide pension benefits to eligible employees in such form an amount as the trustees of 

the pension fund may determine, including allowances for the organization and administration expenses 

of the pension fund. The pension fund shall be administered pursuant to an agreement and declaration of 

trust administered jointly by an equal number of representatives from Employers and the union, which 

agreement and declaration of trust, together with any amendments thereto shall be considered as part of 

this agreement as through set forth here at length. No contributions shall be accepted by the trustees of 

the funds unless a signed copy of this agreement or other document binding the employer to the 

obligations hereto is on file. The monthly contributions period shall include the employers last full 

weekly pay period of the month reported on report forms, furnished by the fund. Said report and 

contributions payments are due and payable on or before the fifteenth (15) day of each month of all 

amounts due for the preceding months and forwarded in accordance with the instructions on the forms. 

Failure on part of the employer to pay the amounts due by him shall be deemed a breach of this agreement 

by such employer. 

7. Highway – Heavy Construction Agreement between the Labor Relations Division of the 

Ohio Contractors Association and Indiana / Kentucky / Ohio Regional Council of Carpenters 

United Brotherhood of Carpenters and Joiners of America, effective date May 1, 2016. 

ARTICLE XVII 

FRINGE BENEFITS 

17.1. Health and Welfare Plan: The Contract shall make contributions to the Health & Welfare 

fringe program as required under the schedule of Wages for the area covered as listed under Exhibit “A.”

The Contractor shall be bound by the Trust Agreement established for the appropriate Fund. It is agreed 

Document #38.1 

SWORCCPP2018-000365
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

that the provisions of the Trust fund as established by the Trustees, including rules of eligibility and all 

other terms and conditions, shall become a part of this Agreement as though fully written herein. 

17.2. For the purpose of this provision, the rate of contribution to the Health & Welfare Fund 

and or the Pension Plan shall be established by this Agreement under Exhibit “A” and may only be 

changed upon a written notice from the Trustees to the parties to this Agreement at least forty-five (45) 

days in advance of any wage adjustment due under terms of this Agreement. Payments by the Contractor 

shall be made for all hours paid, including Reporting pay and/or Show Up Pay. The contractor shall make 

the payments required in a manner prescribed by the Trustees of said Welfare Fund on a form provided by 

the appropriate Union or Fund office. 

17.3. The Contractor agrees that duly authorized representatives of the Trustees shall, upon 

reasonable notice and during regular business hours, have the right to examine all payroll records 

necessary to determine proper compliance with the obligation imposed by this Article. 

17.4. The Contractor shall make payments to the appropriate Fringe Benefit Fund within 

fifteen (15) days from the end of the month during which the employment occurred. Any penalty for late 

payment shall be established by the Trustees of the affected Fund. 

17.5. The Contractor, upon request to the Trustees, shall be given a copy of the Trust 

Agreement established for the Fund. 

17.6. Pension Plan: The same rules as provided for Health & Welfare shall apply to Pension 

Fund payments required under terms of Exhibit “A” in this Agreement.

8. Middletown Energy Center, Middletown, Ohio, Community Development Agreement 

between Gemma Power Systems, LLC and the Butler County Building & Construction Trades 

Council. 

ARTICLE X 

WAGE AND BENEFITS 

SECTION 2. The Contractor agrees to pay contributions to the established employee benefit 

funds and industry promotion funds and other Funds and programs in the amounts designated in the 

appropriate Schedule A. 

Document #38.1 

SWORCCPP2018-000366
 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

EIN/Plan # 31-6127287/001 

Checklist Item #39 – 7.08 Most Recently Filed Form 5500 

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

See Section 7.08 of Revenue Procedure 2017-43. 

The required excerpts from the most recently filed Form 5500 are attached as Document 39.1. 

SWORCCPP2018-000367
 

 

 

Southwest Ohio Regional Council of Carpenters Pension Plan 

Document 39.1 

The required excerpts from the most recently filed Form 5500 are attached below. 

SWORCCPP2018-000368
Form5500 

Deparnm.nt9t111e·Trea1u,y lnlenwl ROl'eliu,i-Se1'<lcif 

Annual Return/Report of Employee Benefit Plan 

Thi!. form is required to l;l.e lfl:ed for employee bene~ plaos .Under sadiont 104 

~d4005 oftbe !;:mployee Retirement lncome·security A(:t of 1974 (ERISA) and 

sections 6057(b) and 6058(a) ofthe lntemal Revenue Code (the ~ode). 

, Complete:.all entries In accordance with 

the Instructions to the Form.5500. 

OIIJIS Nos. f:?10-0110 

1210-uosg 

2016 

This Form Is Open to Pu'blrc 

Ins ·ec.llon 

f-£ef.i~fj~ Ann1,1al Re· ort ldentlfleatic:>n lnform~tioh 

Fer·calendar plan year'2016 or fiscal plan year begln.m.n""'------"0,,,.1~0"'!1~2..:0::..l:..;6.._ ___ .....,a::.;nc=.d-=en.:.:.d:.:l.:. n·._____ _,1'-'2'-'--':3""'1"-'-'2e:..O=l.:.6______

A This return/report ts for, · ~ a niultiemployer plan Oa miiltiple;emp!o~r pran (Fliers ctiecklng .U.li~ box.must.111tact;1 a·Os t of 

participating employer Information in accorqanceWith IJle for!ll fnstructiqns.) D11 slngle-emprov.er· plan Oa DFE (specify) _ 

B This retum/r~port Is: 0 l he first retumtreport Othe .fina! return/report 

0 el\ amended ~tutp/rePQrt Oa shorl plan year rejumireport (l_ess th.an 12months)• 

C If the plafi Is ~ .C()llec.tively-bargai~d.plan, check here. •. ,..... ... . . ... .. ., ...... ... ... .. , . ... ... , ... ..... . , ..... ... .. ij 

b Check boxlrlllln.g.und~r: ~ Form 5558 0 auloma1i9-exlen~lqn Othe DFVC program 

special extel'l$lon (enter des~ll)Uon) 

:-ifftn$lftt Basic Plan lnform~tion--enter all re.'uesle(I informaJioli 

1a Name ofplan 

8.W .QH ije.gion~l Council of Ca:rpent·e.ts .Pensi on Plan 

2~ Plan i;pons-or's name (employer, if for a sirigte-employ~r plan} 

1b ·rhree-dlgrt plan 

numtier PN · 1c •Efrectivetlate·orplan 

05/01/L:964 . 

QOl 

Mallrng address (inol.!lde room, _apl., s~te.no. encl street, or P.O. Box) 

City ortown, stale or.pro\'inoo, country. and ZIP 9r foreign postal.c(l{fe (iftQl~ign, 11ee·instructions) 

·sw OH Regional Cou,ic:i.l of· 

2.b _employer ldenliOcalion 

Number{EIN)' 

.31-,-61272'87 

·2c Plan Spo.nso(g telephone number Ca·rpenters. 

700 Tol-{e.i D:r.:lve, $ui.te 3QO 

Ttoy MI f809a 

(:24.&J 813-9800 

2Q Buslhess. cod.e tsee 

lnsiructlons}

238100 

qautlon: .A penalty {or thit late or-Incomplete flllng of this return/report wlll lie clssossod unlo~s rensohable tause rs ostabllslied. 

Uflder pe1111l!ies of perjQry and other p.enaltles set forth ifi the lnstructlons,.r declare that I have examined l~i.s ~ tuq1/report, fncludll)g aci;ompanyJng sl,;hedutes, 

statemen · · · · eluql/report, and to ttie ~llst Qfniy knowledge and belief, ll ls.tn1e, correct, and complete. 

SI rta.ture of DFE 

Porm 5500 1201 ~) 

10..6.17 Mar Weir 

Date Enter name oflndivldual.sl nln as !an administrator 

Eryka Stamatakos 

Dato. 

Date· Entername of indlvrduarsl oln as DFE 

Preparer'a name (Including firm name, ifapplicablef~md address (Include room or suite number) Pte'parer's tel.ephone numt;,et 

For PaperworkReduction Act Notice, ~e.ethe lnstnicflons-for Form 6500. 

v. 160205 

SWORCCPP2018-000369