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Pension Rights Center Comments to Treasury Department in Opposition to the American Federation of Musicians and Employers' Pension Fund Application to Reduce Benefits Under MPRA (PDF)
Pension Rights Center 
[Opinion] Mar. 3, 2020 "The statute requires the Treasury to apply a multipart test to determine whether a cutback scheme may be licitly applied. However, the factors are quite subjective -- what is an 'equitable' distribution of benefit reductions? How much discrepancy is allowed? Is the discrepancy measured on a dollar or percentage basis? The Treasury Department has issued no public guidance that outlines how the Department evaluates each factor.... Moreover, some relevant information is not in the public record." |
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