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[Official Guidance]
Text of Treasury Department Letter to Central States Pension Plan Denying Application to Reduce Benefits Under MPRA (PDF)
10 pages. "As Special Master, appointed by the Secretary, I am writing to notify you of Treasury's decision to deny the Application because the suspension fails to satisfy the statutory criteria for approval of benefit suspensions.... [A] key test for any application under Kline-Miller is whether the proposed benefit suspensions take a plan off the path to insolvency. As described further [in this letter], Treasury finds that the Plan's proposed benefit suspensions are not reasonably estimated to allow the Plan to avoid insolvency. "Specifically, after reviewing the Application and consulting with PBGC and DOL, Treasury has determined that the suspensions described in the Application fail to satisfy the following three requirements set forth in Kline-Miller: - that the proposed benefit suspensions, in the aggregate, be reasonably estimated to achieve, but not materially exceed,
the level that is necessary to avoid insolvency, because the investment return and entry age assumptions used for this purpose are not reasonable....
- that the proposed benefit suspensions be equitably distributed across the participant and beneficiary population....
- that the notices of proposed benefit suspensions be written so as to be understood by the average plan participant."
(U.S. Department of the Treasury)
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