Permission Granted to Use Substitute Mortality Tables

Significant Index No. 0430.00-00

Date: September 11, 2018

Refer Reply To: SE:T:EP:RA:A2

Re: Request for the use of plan-specific substitute mortality tables for:
EIN * * * - * * *; (Plan No. * * *)
EIN * * * - * * *; (Plan No. * * *)

LEGEND:

Taxpayer = * * *
Plan 1 = * * *
Plan 2 = * * *

Dear * * *:

This letter is to inform you that your request to use substitute mortality tables for making computations under section 430 of the Internal Revenue Code (the “Code”) for Plan 1 and Plan 2 has been granted with respect to the populations specified in this letter, effective for a period of 10 plan years beginning with the plan year commencing January 1, * * *. Your request has been granted in accordance with section 430(h)(3) of the Code and section 303(h)(3) of the Employee Retirement Income Security Act of 1974.

Specifically, this approval applies to the following population:

• Plans 1 and 2 combined — Male and female annuitants, including disabled participants

Based on the information provided by the Taxpayer, the following population does not have credible mortality experience, and therefore the standard mortality tables will be used for calculations under section 430 of the Code;

• Plans 1 and 2 combined — male and female nonannuitants

In granting this approval, we have only considered whether the substitute mortality rates were developed correctly in accordance with section 1.430(h)(3)-2 of the Treasury Regulations (“Regulations”) and Revenue Ruling 2017-55. Accordingly, we are not expressing any opinion as to the accuracy or acceptability of any calculations or other material submitted with your request.

Permission is hereby granted to use the substitute mortality rates shown in the tables below for the Plans 1 and 2:

Substitute Mortality Tables
Approved for use beginning with the plan year commencing January 1, Base year

Age	Male Annuitants	Female Annuitants
1	* * *	* * *
2	* * *	* * *
3	* * *	* * *
4	* * *	* * *
5	* * *	* * *
6	* * *	* * *
7	* * *	* * *
8	* * *	* * *
9	* * *	* * *
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115	* * *	* * *
116	* * *	* * *
117	* * *	* * *
118	* * *	* * *
119	* * *	* * *
120	* * *	* * *

The above rates were developed based on an experience study period from January 1, * * * through December 31, * * * with a base year of * * *. The rates were calculated by adjusting the applicable standard mortality tables in section 1.430(h)(3)-1(d) of the Regulations indicated in the table below, using the mortality ratio and credibility weighting factor determined by aggregating male and female experience, as shown in the table below.

Population	Standard base mortality table	Mortality ratio	Credibility factor
Plans 1 and 2, male annuitants	Male annuitant mortality table	1.550271	0.569920
Plans 1 and 2, female annuitants	Female annuitant mortality table	1.550271	0.569920

The Internal Revenue Service has reviewed the substitute mortality rates and supporting information, and has determined that based on the information submitted, the rates were correctly developed in accordance with section 1.430(h)(3)-2 of the Regulations and Revenue Ruling 2017-55.

The above rates must be applied on a generational basis, as provided in section 1.430(h)(3)-2(c)(3) of the Regulations.

Your attention is called to section 430(h)(3)(C)(ii) of the Code and section 1.430(h)(3)-2(d)(6) of the Regulations, which describe the circumstances in which the use of the substitute mortality table will terminate before the end of the 10-year period described above. In general, the substitute mortality tables can no longer be used as of the earliest of:

This ruling is directed only to the taxpayer that requested it. Section 6110(k)(3) of the Code provides that it may not be used or cited by others as precedent.

When filing Form 5500 for the plan years for which the substitute mortality tables are used, please note the information that is required to be attached to Schedule SB (Actuarial Information) in accordance with the instructions to that form.

We have sent a copy of this letter to your authorized representative pursuant to a power of attorney on file in this office and to the Manager, EP Classification in Columbus, Ohio and to the Manager, EP Compliance Unit in Chicago, Illinois.

If you have any questions regarding this matter, please contact * * * (ID # * * *) at * * *.

Sincerely,

David M. Ziegler, Manager
Employee Plans Actuarial Group 2

cc:
* * *