Pension Benefit Statements - CBA Plans

[JRG]

The PPA provides different effective dates for providing pension benefit statements to nonunion pension plans (due for 2009 plan year) and pension plans maintained pursuant to a CBA (for this plan, the 2011 plan year).

If a plan has both nonunion and union employees, can all benefit statements be provided for the 2011 plan year, or must the nonunion employees receive their benefit statements for the 2009 plan year?

[My 2 cents]

Perhaps the safest course is to treat a plan that does not exclusively cover people under a CBA as a non-CBA plan. In that case, you would provide the statements currently to all (with no delayed applicability).