This is where I will address the common questions and concerns that you might have in relation to the MPRA Filing.
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The Trustees of the Western Pennsylvania Teamsters and Employers Pension Fund filed a MPRA application with the United States Department of Treasury, who confirmed receipt of the filing on September 26, 2018.
The Department of Treasury will now review the application with the Trustees and the Fund’s attorney and actuary to determine if the benefit reduction design proposed in the application meets the requirements of MPRA. If the Department of Treasury determines that the benefit reduction design meets the requirements of MPRA, they will approve the application.
You should expect to receive in the mail a notice from the Fund regarding the MPRA application filing. Along with that notice will be an individualized impact statement that will identify the exact reduction to your pension if the application is approved and goes into effect.
The Secretary of Treasury must approve or deny the MPRA application within 225 days. This means we should know whether the application is approved or denied by May 9, 2019.
Once approved by the Department of Treasury, the benefit reduction design will be voted on by the Fund’s participants and their beneficiaries. The reduction will go into effect on August 1, 2019 unless a majority of the participants and beneficiaries vote to reject the benefit reduction.
The Trustees approved a 30% across the board benefit reduction with one exception. This reduction will only apply to benefits earned through December 31, 2017. If you are not a member of a class protected by MPRA (those over 80, limited protection for those receiving a disability pension, and prorated protection for those between 75 and 79), your pension will be reduced by 30%. As an example, if you are 68 and receive a $3,000 monthly pension, your pension will be reduced to $2,100.
The Trustees reviewed the MPRA applications which have received approval to provide guidance for a successful benefit reduction design. As a result of this review, the Trustees determined that a benefit reduction which would have the Fund bottom out at 20% funding and $200 million in assets would likely receive approval. With this goal in mind the Fund’s actuary reviewed many different reduction scenarios looking for the right scenario which would meet the Trustee’s goal while also meeting the requirements of MPRA. As a result the Trustees determined that the 30% reduction was most likely to lead to an application being approved.
The 30% benefit reduction will not apply to those participants who qualify for the special $3,500/month 30-and-out benefit level at age 55. Participants who qualify for this benefit will still have their monthly benefit reduced. However, the monthly benefit will not be reduced below the amount provided by this benefit.
All participants actively employed as of January 1, 2018 who are covered at the “Top Tier” contribution rate. According to the Trustees’ MPRA application, the “Top Tier” group is primarily populated by 1,117 participants employed by United Parcel Service (UPS).
The Trustees believe that protecting this benefit is necessary to prevent active participants from leaving the Fund. The Trustees determined that applying the 30% reduction to this benefit would create a scenario where active participants would leave the Fund which could put the Fund in an even more critical position than it is in currently. According to the MPRA application, UPS contributes approximately $31 million per year to the Fund. The Trustees felt protecting this benefit was necessary to ensure the Fund retains an active population which would allow the Fund to remain healthy enough to avoid insolvency.
The Trustees’ MPRA application is voluminous and I am in the process of reviewing it. At this point, I have come to no conclusion about whether the application meets the statutory requirement of representing an equitable distribution of pension cuts. Once I come to a conclusion I intend to share my opinion with the Treasury Department, but that will not be until after November 30, 2018.
The benefit reduction will be effective August 1, 2019. Until that date you will still receive your current monthly pension amount.
I have a favor that I’d like to ask from you…
Please do not spread information regarding the Pension Fund’s MPRA application that you do not personally know to be true. It helps no one and may actually cause others to become upset. If you hear a rumor about this process that worries you, e-mail me at firstname.lastname@example.org or call me at 724.382.4956 and ask me about it before you pass it along. Please. Thank you.