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If a participant applies for early retirement prior to the plan being certified as critical but the benefit payments would not start until after certification (notice of critical status), can the benefit be cut? No cutback can be made when the participant/beneficiary is already receiving the benefits, but what if the benefit has no yet started payment?

Thanks

Benjamin Smith

Senior Manager - Indirect Tax

Ernst & Young

317.681.7495

Benjamin.Smith@ey.com

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