10-year approval of substitute mortality tables for Plan 2

Plain-English summary

A pension plan sponsor asked to use plan-specific substitute mortality tables for Plan 2 when calculating minimum funding under Code section 430. The IRS approved the tables for up to 10 plan years beginning January 1, 2026, for non-disabled male and female annuitants and nonannuitants. Disabled participants must continue using standard mortality tables. The sponsor used a 2019 through 2023 experience study with a 2021 base year because updated regulations prevented continued use of its earlier approved tables after 2025. In 2020, Plan 2 offered a lump-sum window that about 2,900 of 9,300 eligible terminated vested participants accepted, reducing the total plan population by about 4 percent without materially changing the population mix. A separate ruling covered Plan 1, while Plan 3 lacked credible mortality experience and would use standard tables. The IRS warned that Plan 3’s male population had 91 deaths during the five-year study period and would become credible at 100 deaths, which could affect the controlled-group rules.

Ruling snapshot

• Question: May the sponsor use plan-specific base substitute mortality tables for Plan 2 under section 430?
• Outcome: Approved (up to 10 plan years beginning January 1, 2026, for the specified non-disabled populations)
• Key authorities: IRC § 430(h)(3)(C); ERISA § 303(h)(3)(C); Treas. Reg. § 1.430(h)(3)-2; Rev. Proc. 2024-32

Full text (IRS public release)

Index No. 0430.00-00

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

AUG 22 2025

Release Number: 202552040
Release Date: 12/26/2025

Re: Request for use of plan-specific substitute mortality tables

Taxpayer =

EIN: -
Plan 1=

EIN: - (Plan No.: )
Plan 2 =

EIN: - (Plan No.: )
Plan 3 =

EIN: - (Plan No.: )

Dear

This letter is to inform the Taxpayer that their request to use base substitute mortality
tables for making computations under section 430 of the Internal Revenue Code
(“Code”) for Plan 2 has been granted with respect to the populations specified in this
ruling. This ruling is effective for a period of up to 10 plan years beginning with the plan
year commencing January 1, 2026 for Plan 2. Approval has been granted in accordance
with section 430(h)((3)(C)(i) of the Code and section 303(h)(3)(C)(i) of the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”).

This approval applies to the following specific populations of Plan 2
¢ Male annuitants and nonannuitants, excluding disabled participants
(“Non-Disabled Males”)
« Female annuitants and nonannuitants, excluding disabled participants
("Non-Disabled Females”)

Disabled participants of Plan 2 will continue to rely upon the standard mortality tables in
accordance with section 1.430(h)(3)-2(c)(4) of the Treasury Regulations (“Regulations”).

This ruling was originally requested by the Taxpayer in a letter postmarked on
December 17, 2024. In addition, supplemental information was provided by the
Taxpayer's authorized representatives on March 27, 2025.

Plan 2 previously received a ruling, dated July 13, 2023, granting the use of base
substitute mortality tables under section 430(h)(3(C)(i) of the Code, effective for a
period of up to 5 plan years beginning with the plan year commencing January 1, 2024.
However, in accordance with section 1.430(h)(3)-2(g) of the Regulations these
previously approved base substitute mortality tables can no longer be used beginning
January 1, 2026 because they were developed under the previous section 1.430(h)(3)-2
of the Regulations. The Taxpayer, therefore, prepared a new experience study and
submitted this request to use base substitute mortality tables effective with the plan year
beginning January 1, 2026 for a period of up to 10 years for the Non-Disabled Males
and the Non-Disabled Females.

The Taxpayer represents that Plan 1, Plan 2, and Plan 3 are all the plans subject to
section 430 of the Code within the Taxpayer's controlled group.

The Taxpayer submitted a separate request for approval to use base substitute mortality
tables for Plan 1 at the same time as this request for Plan 2. The ruling for Plan 1 will be
addressed in a separate ruling.

The Taxpayer does not intend to use base substitute mortality tables for Plan 3 due to a
lack of credible mortality experience and therefore, will use the standard mortality
tables for calculations under section 430 of the Code.

The Taxpayer represents that Plan 2 is not a newly affiliated plan under
section 1.430(h)(3)-2(f)(2) of the Regulations.

The Taxpayer represents that Plan 2 is not a multiple-employer plan, and the Taxpayer
does not sponsor or participate in any multiple-employer plans.

The Taxpayer represents that Plan 1 is not a multiple-employer plan, and the Taxpayer
does not sponsor or participate in any multiple-employer plans.

The Taxpayer represents that no plans were spun off from any plan within the
Taxpayer's controlled group within the last five years preceding the date of this request.

The Taxpayer represents that during the plan year beginning January 1, 2020, a
voluntary lump sum window was offered to the separated participants entitled to a
benefit in the future. The Taxpayer also represents that the terminated vested lump sum
window offering reduced the overall plan population by approximately 4% and did not
disproportionately affect the terminated vested population age, gender, or benefit
amount distribution relative to the plan year before the plan year in which the terminated
vested lump sum window offering occurred. The Taxpayer further represents that
approximately 2,900 of the 9,300 eligible terminated vested participants accepted the
lump sum offer in 2020.

The proposed base substitute mortality tables are constructed separately for the
Non-Disabled Males and the Non-Disabled Females. Disabled participants of Plan 2 will
continue to use the generally applicable tables for calculations under section 430 of the
Code and are excluded from the experience data included in the Taxpayer's request.

The Taxpayer represents that the simplified rule under section 1.430(h)(3)-2(c)(2)(ii)(B)
of the Regulations is not used.

This request is made in accordance with section 430(h)(3)(C)(i) of the Code,
section 303(h)(3)(C)(i) of ERISA, section 1.430(h)(3)-2(b)(1) of the Regulations, and
Revenue Procedure 2024-32.

Section 430(h)(3) of the Code states, in relevant part, that:

(A) In general. Except as provided in subparagraph (C) or (D), the Secretary shall by
regulation prescribe mortality tables to be used in determining any present value
or making any computation under this section. Such tables shall be based on the
actual experience of pension plans and projected trends in such experience. In
prescribing such tables, the Secretary shall take into account results of available
independent studies of mortality of individuals covered by pension plans.

(C) Substitute mortality table -

(i) In general. Upon request by the plan sponsor and approval by the
Secretary, a mortality table which meets the requirements of clause (iii)
shall be used in determining any present value or making any computation
under this section during the period of consecutive plan years (not to
exceed 10) specified in the request.

(ii) Early termination of period. Notwithstanding clause (i), a mortality table
described in clause (i) shall cease to be in effect as of the earliest of -

(i) the date on which there is a significant change in the participants in
the plan by reason of a plan spinoff or merger or otherwise, or
(il) the date on which the plan actuary determines that such table does
not meet the requirements of clause (ili).
(iii) Requirements. A mortality table meets the requirements of this clause if —

(1) there is a sufficient number of plan participants, and the pension
Plans have been maintained for a sufficient period of time, to have
credible information necessary for purposes of subclause (Il), and

(Ii) such table reflects the actual experience of the pension plans
maintained by the sponsor and projected trends in general mortality
experience.

Section 1.430(h)(3)-1 of the Regulations states, in relevant part, that:
(d) Base mortality tables. The following are the base mortality tables. The base year
for these tables is 2012’.

Section 1.430(h))((3)-2 of the Regulations states, in relevant part, that:
(b) Procedures for obtaining approval to use substitute mortality tables -
(1) Written request for approval to use substitute mortality tables —

(i) General requirements. To use substitute mortality tables, a plan
sponsor must first submit a written request to the Commissioner
demonstrating that those substitute mortality tables meet the
requirements of section 430(h))((3)(C) and this section. This request
must specify the first plan year, and the term of years (not more
than 10), for which the tables are to apply.

(i) Time for written request. Substitute mortality tables may not be
used for a plan year unless the plan sponsor submits the written
request described in paragraph (b)(1)(i) of this section at least 7
months before the first day of the first plan year for which the
substitute mortality tables are to apply.

(c) Development of substitute mortality tables -~
(2) Mortality experience requirements —

(ii) Credible mortality information —

(B) Simplified rule. Whether there is credible mortality
information for a gender may be determined by only taking
into account people who are at least age 50 and less than
age 100. If there is credible mortality information for a
gender using this simplified rule, the entire gender (not just
those who are at least age 50 and less than age 100) has
credible mortality information.

(3) Determination of substitute mortality tables —

(i) Requirement to use generational mortality table. A plan's substitute
mortality tables must be generational mortality tables. A plan's
substitute mortality tables are determined using the plan's base
substitute mortality tables developed pursuant to paragraph (d)

' Due to the length, these base mortality tables have not been included in this ruling,

or (e) of this section and the mortality improvement factors
described in paragraph (c)(3 (ii) of this section.

(ii) Determination of mortality improvement factors. The mortality
improvement factor for an age and gender is the cumulative
mortality improvement factor determined under
§ 1.430(h)(3)-1(b)(2)(ii) for that age and gender for the applicable
period. The applicable period is the period beginning with the base
year for the base substitute mortality table determined under
paragraph (d) or (e) of this section and ending in the calendar year
in which the individual attains the age for which the probability of
death is being determined. The base year for the base substitute
mortality table is the calendar year that contains the day before the
midpoint of the experience study period.

(4) Disabled individuals. Under section 430(h)(3)(D), separate mortality tables
are permitted to be used for certain disabled individuals. If the separate
mortality tables issued under section 430(h)(3)(D) for certain disabled
individuals are used, then those disabled individuals are disregarded for
all purposes under this section. Thus, if the mortality tables under
section 430(h)(3)(D) are used for disabled individuals under a plan,
mortality experience with respect to those individuais must be excluded in
developing mortality rates for substitute mortality tables under this section.

(6) Duration of use of tables —

(ii) Early termination of use of tables. A pian's substitute mortality
tables must not be used beginning with the earliest of —

(A) For a plan using a substitute mortality table for only one
gender because of a lack of credible mortality information
with respect to the other gender, the first plan year for which
there is credible mortality information with respect to the
gender that had lacked credible mortality information (unless
an approved substitute mortality table is used for that
gender);

(8) The first plan year for which the plan fails to satisfy the
requirements of paragraph (c)(1) of this section (regarding
use of substitute mortality tables for all plans in the
controlled group), taking into account the rules of
paragraph (f)(3) of this section (regarding the transition
period for newly-affitiated plans);

(C)The second plan year following the plan year for which there
is a significant change in individuals covered by the plan as
described in paragraph (c)(6)(iii) of this section;

(D) The first plan year following the plan year for which a
substitute mortality table used for a population is no longer
accurately predictive of future mortality of that population, as

determined by the Commissioner or as certified by the plan's
actuary to the satisfaction of the Commissioner, or

(E) The date specified in guidance published in the Internal
Revenue Bulletin in conjunction with a replacement of
mortality tables specified under section 430(h)(3)(A) and
§ 1.430(h)(3)+1 (other than changes to the mortality
improvement rates under § 1.430(h)(3)-1(b)(1)(iii) or annual
updates to the static mortality tables issued as noted in
§ 1.430(h)(3))-1(c)(1)(iv)).

(iii) Significant change in coverage —

(A) Change in coverage from time of experience study. For
Purposes of applying the rules of paragraph (c)(6)(ii)(C) of
this section, a significant change in the individuals covered
by a substitute mortality table for a plan year occurs if the
number of individuals covered by the substitute mortality
table for the plan year is less than 80 percent or more
than 120 percent of the average number of individuals in that
population over the years covered by the experience study
on which the substitute mortality tables are based. However,
a change in coverage is not treated as significant if the plan's
actuary certifies in writing to the satisfaction of the
Commissioner that the substitute mortality tables used for
the population continue to be accurately predictive of future
mortality of that population (taking into account the effect of
the change in the population).

(B) Change in coverage from time of certification. For purposes
of applying the rules of paragraph (c)(6)(ii)(C) of this section,
a significant change in the individuals covered by a
substitute mortality table for a plan year occurs if the number
of individuals covered by the substitute mortality table for the
plan year is less than 80 percent or more than 120 percent
of the number of individuals covered by the substitute
mortality table in a plan year for which a certification
described in paragraph (c)(6)(iii)(A) of this section was made
on account of a prior change in coverage. However, a
change in coverage is not treated as significant if the plan's
actuary certifies in writing to the satisfaction of the
Commissioner that the substitute mortality tables used by
the plan with respect to the covered population continue to
be accurately predictive of future mortality of that population
(taking into account the effect of the change in the
population).

(d) Full credibility —
(2) Experience study period requirements —

(i) General rule. The base substitute mortality table for a gender or
other population must be developed from an experience study of
the mortality experience of that population that is collected over an
experience study period. The experience study period must consist
of 2, 3, 4, or 5 consecutive 12-month periods, and must be the
same period for all populations except as provided in
paragraph (c)5)(iii) of this section.

(ii) Requirement to use recent experience data —

(A) General rule. Except as provided in paragraph (d)(2 )(ii)(B) of
this section, the last day of the experience study period must
be less than 3 years before the first day of the first plan year
for which the substitute mortality tables are to apply. For
example, if January 1, 2019, is the first day of the first plan
year for which the substitute mortality tables will be used,
then an experience study using calendar year data generally
must include data collected for a period that ends no earlier
than December 31, 2016.

(3) Full credibitity threshold —

(i) Threshold number of deaths. The full credibility threshold for a
gender or other population is the product of 1,082 and the
population's benefit dispersion factor. In calculating the population's
benefit dispersion factor, for purposes of paragraphs (d)( 3)(ill), (iv),
and (v) of this section, the population is adjusted, as appropriate,
for individuals who leave the population on account of a reason
other than death.

(ii) Population’s benefit dispersion factor. The population's benefit
dispersion factor is equal to—

(A) The number of expected deaths for the population during the
experience study period (as defined in paragraph (d))((3)(iti) of
this section); multiplied by

(B) The sum of the mortality-weighted squares of the benefits
(as defined in paragraph (d))(3)(iv) of this section); divided by

(C)The square of the sum of the mortality-weighted benefits (as
defined in paragraph (d)(3))(v) of this section).

(4) Development of mortality rates —

(i) In general. The mortality rates under the base substitute mortality
tables must be amounts-weighted mortality rates that are derived
from the experience study. Except as provided in
paragraph (d)(4)(iv) of this section, the mortality rate for an age and
gender is determined by multiplying the mortality rate for that age
and gender from the standard mortality table determined under

paragraph (0 4)(iii) of this section by the mortality ratio determined
under paragraph (d)(4)(ii) of this section. If the simplified rule of
paragraph (c)(2)(it(B) of this section is used for the population,
then the mortality ratio is determined only taking into account
people who are at least 50 years old and less than 100 years old,
but the mortality ratio is applied to all ages.

(i) Mortality ratio —

(A)in general. Except as provided in paragraph (d)(6) of this
section, a mortality ratio is determined for a gender or other
population within a gender, and is equal to the quotient
determined by dividing—

(1) The sum, for alt years in the experience study period,
of the benefit amount for all individuals in the
population at the beginning of the year who died
during the year, by

(2) The sum, for all years in the experience study period,
for ail individuals in the population at the beginning of
the year (adjusted, as appropriate, for individuals who
leave on account of reason other than death), of the
product of -

(i) The probability of death of the individual using
the mortality rate for the individual's age and
gender from the standard mortality table
determined under paragraph (d)(4)(iii) of this
section; and

(#) The benefit amount for the individual.

(iii) Standard mortality table —

(A) Projection of base table. Except as otherwise provided in this
paragraph (d)(4)(iii), the standard mortality table for a year is
the mortality table determined by applying cumulative
mortality improvement factors determined under
§ 1.430(h)(3)-1(b)(2)(i/) to the base mortality table under
§ 1.430(h)(3)-1(d) for the period beginning with the base
year for that mortality table and ending in the base year for
the base substitute mortality table determined under
paragraph (c)(3)(ii) of this section. For purposes of the
preceding sentence, the cumulative mortality improvement
factors are determined using the mortality improvement rates
described in § 1.430(h)(3)-1(b)(1)(iii) that apply for the
calendar year during which the plan sponsor submits the
request for approval to use substitute mortality tables.

(B) Adjustments to standard mortality table for 2020, 2021,
and 2022. If a 12—-month period in the experience study

period begins after December 31, 2019, and before
January 1, 2023, the probability of death for an individual
under paragraph (d)(4)(ti)(A)(2)() of this section is
determined as the mortality rate for the individual's age (at
the beginning of the year) and gender from the standard
mortality table determined under paragraph (d)(4)(iii)(A) of
this section multiplied by the adjustment factor in Table 1 for
the calendar year that includes the first day of the 12—month
period.

Table 1 to Paragraph (d)(4)(iii)(B)
_ Calendar Year | Adjustment factor |

2020. | 1.45
      202 ie ns. 15
      2022ecfuy | 1.075

(iv) Modification for ages 96 and older. Mortality rates for ages 96 and
older under the base substitute mortality table are determined using
the rules of paragraph (d)(4)i) of this section but substituting a
modified mortality ratio for the mortality ratio determined under
paragraph (d)4)(ii) of this section. The modified mortality ratio is
determined as follows—

(A) For ages 96 through 109, if the mortality ratio is greater
than 1.0, the modified mortality ratio is equal to the mortality
ratio for the population reduced by 1/15th of the excess of
the mortality ratio over 1.0 for each year that the age
exceeds 95.

(B) For ages 96 through 109, if the mortality ratio is less
than 1.0, the modified mortality ratio is equal to the mortality
ratio for the population increased by 1/15th of the excess
of 1.0 over the mortality ratio for each year that the age
exceeds 95.

(C)For ages 110 and older, the modified mortality ratio is equal
to 1.0.

(v) Change in number of individuals covered by table. Experience data
may not be used to develop a base table if the number of
individuals in the population covered by the table (for example, the
male annuitant population) as of the last day of the plan year before
the year the request for approval to use the substitute mortality
table is made is less than 80 percent or more than 120 percent of
the average number of individuals in that population over the years
covered by the experience study on which the substitute mortality
tables are based, unless it is demonstrated to the satisfaction of the
Commissioner that the experience data is accurately predictive of

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future mortality of that population (taking into account the effect of
the change in individuals) after appropriate adjustments to the data
are made (for example, excluding data from individuals with respect
to a spun-off portion of the plan). For this purpose, a reasonable
estimate of the number of individuals in the population covered by
the table may be used.

(e) Partial credibility -

(1) In general. The mortality experience with respect to a population has
partial credibility if the actual number of deaths for that population during
the experience study period described in paragraph (d)(2) of this section is
at least equal to 100 and is less than the full credibility threshold described
for the population in paragraph (d)(3) of this section. If the mortality
experience for the population has partial credibility, then in lieu of creating
a base substitute mortality table as described in paragraph (d) of this
section, the base substitute mortality tabie is created as the sum of—

(i) The product of —
(A) The partial credibility weighting factor determined under
paragraph (e)(2) of this section; and
(B) The mortality rates that are derived from the experience
study determined under paragraph (d)(4)(i) of this section:
and
(ti) The product of —
(A) One minus the partial credibility weighting factor described in
paragraph (e)(2) of this section; and
(8) The mortality rate from the standard mortality tables
described in paragraph (d)(4)(iii) of this section.

(2) Partial credibility weighting factor. The partial credibility weighting factor is

equal to the square root of the fraction—
(i) The numerator of which is the actual number of deaths for the
population during the experience study period, and
(it) The denominator of which is the full credibility threshold for the
population described in paragraph (d)(3) of this section.
(f) Special rules for newly-affiliated plans —

(2) Definition of newly-affiliated plan. For purposes of this paragraph (f), a
plan is a newly-affiliated plan if the plan sponsor becomes a member of
the new controlled group in connection with a merger, acquisition, or
similar transaction described in § 1.440(b)-2(f). A plan also is treated as a
newly-affiliated plan in connection with a merger, acquisition, or similar
transaction described in § 1.410(b)-2(f).

(g) Applicability date -

(1) General rule. This section applies for plan years beginning on or after

January 1, 2025. Except as provided in paragraph (g)(2) or (3) of this

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section, the substitute mortality table used for a plan for such a plan year
must comply with the rules of paragraphs (a) through (f) of this section.

(2) Transition rule for previously approved substitute mortality tables. If a plan
sponsor has received approval from the Commissioner to use substitute
mortality tables for a plan year beginning in 2025, then the plan's base
substitute mortality tables that were approved are treated as satisfying the
requirements of paragraph (d) or (e) of this section, as applicable, for that
plan year.

Section 303(h)(3) of ERISA states, in relevant part, that:
(C) Substitute mortality table.—

(i) In general.—Upon request by the pian sponsor and approval by the
Secretary of the Treasury, a mortality table which meets the requirements
of clause (iii) shall be used tn determining any present value or making
any computation under this section during the period of consecutive plan
years (not to exceed 10) specified in the request.

(iii) Requirements.—A mortality table meets the requirements of this clause
if—

(I) there is a sufficient number of participants, and the pension plans
have been maintained for a sufficient period of time, to have
credible information necessary for purposes of subclause (II), and

(Il) such table reflects the actual experience of the pension plans
maintained by the sponsor and projected trends in general mortality
experience.

Revenue Procedure 2024-32 sets forth the procedure by which the sponsor of a defined
benefit plan that is subject to the funding requirements of § 430 of the Code may
request approval from the Internal Revenue Service ("IRS") for the use of plan-specific
substitute mortality tables in accordance with § 430(h)((3)(C) and § 1.430(h)(3)-2 of the
Regulations.

Section 8.1. of Revenue Procedure 2024-32 states, in relevant part, that the following
information must be provided in tabular form for each population within the plan (or
aggregated group) for which approval to use substitute mortality tables is requested,
aggregating all plans that have the same plan year:
(1) The average number of individuals within the population during the experience
study period; and
(2) The number of individuals within the population as of the last day of the plan year
immediately preceding the plan year during which approval to use substitute
mortality tables is requested.

The Taxpayer's proposed base substitute mortality tables are developed based on an
experience study period from January 1, 2019 through December 31, 2023, with a base

12

year of 2021. This satisfies the requirements under section 1.430(h)((3)-2(d)(2) of the
Regulations.

The Taxpayer's proposed base substitute mortality tables are developed by adjusting
the applicable standard mortality tables in section 1.430(h)(3)-1(d) of the Regulations by
the mortality ratios, in accordance with section 1.430(h)(3)-2(d)(4)(i) of the Regulations,
and by the credibility weighting factors, in accordance with section 1.430(h)(3)-2(e)(1) of
the Regulations, shown below.

Mortality Ratio and Credibility Weighting Factor Table

[illegible]

The mortality ratios above are determined in accordance with

section 1.430(h)(3)-2(d)(4)(ii) of the Regulations and the credibility weighting factors
shown above are determined in accordance with section 1.430(h)((3)-2(e)((2) of the
Regulations.

Permission is hereby granted to use the base substitute mortality tables, shown below,
for the Non-Disabled Males and the Non-Disabled Females.

Base Substitute Mortality Tables
Approved for Use Beginning with the Plan Year Commencing January 1, 2026 for Plan 2
Base Year 2021

[illegible]

In granting this approval, we have only considered whether these base substitute
mortality rates are developed in accordance with section 1.430(h)((3)-2 of the
Regulations and Revenue Procedure 2024-32. Accordingly, we are not expressing any
opinion as to the accuracy or acceptability of any calculations or other material
submitted with the Taxpayer's request.

These approved base substitute mortality tables must be applied on a generational
basis, as provided in section 1.430(h)(3)-2(c)(3)(i) of the Regulations.

The Taxpayer's attention is called to section 430(h)(3)(C)(ii) of the Code and

section 1.430(h)(3)-2(c)(6)(ii) of the Regulations, which describe the circumstances in
which the use of these approved base substitute mortality tables will terminate before
the end of the 10-year period described above.

We also call the Taxpayer's attention to the fact that Plan 3 experienced 91 male deaths
during the experience study period (January 1, 2019 - December 31, 2023). This
population will have credible mortality experience if it experiences at least 100 deaths
during a 5-year period (corresponding to the length of the experience study period used
to construct the substitute mortality tables for the Non-Disabled Males and the

16

Non-Disabled Females). It is important to monitor this population to ensure that
appropriate action is taken should this occur, to avoid violating
section 1.430(h)(3)-2(c)(6)(ii)(B) of the Regulations.

The Taxpayer's attention is called to the fact that a certification must be provided each
plan year that it is required under section 1.430(h)(3)-2(c)(6)(iii) of the Regulations,
signed by the enrolled actuary for Plan 2, stating that the approved base substitute
mortality tables continue to be accurately predictive of the expected future mortality for
the Non-Disabled Males and the Non-Disabled Females. The certification must also
contain a statement that:

(1) The enrolled actuary is current with educational requirements set forth by the
Joint Board for the Enrollment of Actuaries as well as any other actuarial
designations asserted,

(2) The enrolled actuary was personally involved in the determination that these
approved base substitute mortality tables are still accurately predictive and
provides the actuary's best estimate for the Non-Disabled Males and the
Non-Disabled Females:

(3) In determining that these approved base substitute mortality tables are still
accurately predictive, the enrolled actuary took into consideration the effect of
business combinations, plan mergers or spinoffs and settlements/other risk
transfers, and other events that would have similar effects on the relevant
populations, and

(4) The enrolled actuary has the specific knowledge and experience to make the
judgments set forth above and attests to these representations.

All required certifications must be provided on or before the date Form 5500 is filed for
each plan year for which the certification is required and must be accompanied by the
supporting information relied upon by the enrolled actuary to make that certification. To
the extent possible, please also provide the following supporting information:

(1) The number of actual deaths during the experience study period used to develop
these approved base substitute mortality tables and the beginning and ending
dates of the experience study period;

(2) A table showing the number of expected deaths and actual deaths, reported
separately as of December 31, 2023 and for each subsequent plan year through
the plan year immediately preceding the most recent actuarial valuation, and in
total:

(3) A table similar to the stability demonstration required under section 8.1. of
Revenue Procedure 2024-32, showing the average number of participants in the
population covered by these approved base substitute mortality tables during the
experience study period and the number of participants in that population as of
the end of each plan year, beginning with December 31, 2023 through the plan
year immediately preceding the most recent actuarial valuation, expressed both

17

as a headcount and as a percentage of the average number of participants in the
experience study

(4) A table showing a comparison of (i) the average ages and (ii) the percentage of
the population, by the following monthly single life annuity brackets: under $100,
between $100 and $250, between $250 to $500, between $500 to $1,000,
between $1,000 and $1,500, and $1,500 and over, along with the average age
and average benefit amount for the population in total. This information should
also be provided for each population in the experience study and at the end of
each plan year, beginning with the valuation date for the first plan year that the
certification is required, through the date immediately preceding the most recent
actuarial valuation at the time the information is reported; and

(5) An explanation of any material changes in the population.

This information must be provided to David M. Ziegler (or to another individual
designated by the IRS) to the following address:

Internal Revenue Service
Attn: Mr. David M. Ziegler
TE/GE: SE:T-EP:RA:T:A2
1111 Constitution Ave, NW
IR-6213
Washington, DC 20224-0002

Failure to provide this information by the due date may result in a requirement that the
standard mortality tables must be used for purposes of section 430 of the Code,
beginning with the earlier of:
(1) the plan year for which the deadline for providing this information is missed, or
(2) the date required for early termination of the use of these approved base
substitute mortality tables pursuant to section 1.430(h)(3)-2(c)(6)(ii) of the
Regulations.

This ruling may be revoked or modified retroactively if there was a misstatement or
omission of controlling facts, the facts at the time of the transaction are materially
different from the controlling facts on which this ruling is based, or the transaction
involves a continuing action or series of actions, and the controlling facts change during
the course of the transaction.

No opinion is expressed as to the tax treatment of the transaction described herein
under the provisions of any other section of either the Code or Regulations which may
be applicable thereto, as appropriate.

18

When filing the Form 5500 for Plan 1 for plan years which these base 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.

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.

We have sent a copy of this ruling to the Taxpayer's authorized representatives
pursuant to the Power of Attorney and Declaration of Representative (Form 2848) on file
with the IRS. In addition, a copy of this ruling is being sent to the Manager, EP
Classification Group 4 in Houston, Texas.

If the Taxpayer wishes to inquire about this ruling, please contact Mr. [illegible] (ID Badge Number [illegible]) at [illegible].
Sincerely yours,
David M. Ziegler, Manager
Employee Plans Actuarial Group 2
Enclosures

Notice 437, Notice of Intention to Disclose (Rulings)
A deleted copy of the ruling

cc: