After the end of the Fund's fiscal year on March 31, 2019, the Fund's actuary will begin the process of determining whether the Fund has entered critical and declining status for the next plan year (beginning April 1, 2019). That work will take some time to complete. The deadline for the Fund actuaries to certify the Fund status for the plan year beginning April 1, 2019 is June 28, 2019.
Once that determination has been made, all participants and beneficiaries will be notified within 30 days of the actuary's certification. The Fund will notify participants via the Fund website and through postal mail or eDelivery. Note: If you want email delivery, you must register on our website
and opt for eDelivery.
If the Fund is determined to be in critical and declining status for the plan year beginning April 1, 2019, the Trustees are expecting to submit by the end of 2019 an application to the Treasury Department under the Multiemployer Pension Reform Act (MPRA).
If Treasury approves the application, there will be a vote on the application among Fund participants and beneficiaries of deceased participants. Treasury will mail out ballots and voters will mail them back.
Under MPRA, there are some unique aspects to the voting process. For an application to be rejected, a majority of eligible voters must vote against it. So, unreturned ballots are counted as "yes" votes. Also, for very large plans like the Fund, which are deemed to be "systemically important" (that is, insolvency of that fund would have a disproportionately adverse impact on the entire multiemployer system), Treasury is required under the law to override a "no" vote by participants or revise the application so it can approve it.
After the voting process is completed, Treasury will give final authorization for approved benefit reductions to go into effect.
The MPRA approval process should take at least a year including review, public comment, Treasury approval, and a participant vote, so any benefit reductions approved by Treasury would not be expected to start until late 2020 or early 2021 at the earliest.