IRS written determination 202610022

Private letter rulings and published taxpayer determination letters. Native document type is retained separately; a determination letter is not labeled a private letter ruling. These taxpayer-specific releases cannot be used or cited as precedent under 26 USC 6110(k)(3); applicability and current legal force are not independently certified. Keep repeated UILC subjects attached to one actual numbered document.

Significant Index No. 0430.00-00

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TAX EXEMPT AND
GOVERNMENT LNTITIFS
DIVISION

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON. D.C. 20224
DEC 0 8 2025

Release Number: 202610022
Release Date: 3/6/26

Re: Ruling request for use of plan-specific base substitute mortality tables
Taxpayer =

EIN:
\-

Plan 1 =
EIN:
\-
(Plan No .:
)
Plan 2 =

EIN:
\-
(Plan No .:
)

Dear
:

This letter is to inform you that the Taxpayer's request to use substitute mortality tables for
making computations under section 430 of the Internal Revenue Code ("Code") for Plan 1 has
been granted with respect to the populations specified in this letter. This ruling is effective for a
period of up to 3 plan years beginning with the plan year commencing January 1, 2026. The
Taxpayer's request 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 11:

· Male participants (annuitants and non-annuitants), including disabled participants ("Male
Participants")

· Female participants (annuitants and non-annuitants), including disabled participants
("Female Participants")

This is the third request for use of substitute mortality tables for plans in Taxpayer's controlled
group. The Taxpayer previously requested to use substitute mortality tables under section
430(h)(3)(C) of the Code effective with the plan year beginning January 1, 2018. These tables
were approved on September 10, 2018.

1 Plan 2 listed above was merged into Plan 1 on December 31, 2022.

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Due to the significant change in population related to an annuity purchase and the acquisition
and later merger of Plan 2 into Plan 1, Taxpayer performed a new experience study and
requested use of new tables effective with the plan year beginning January 1, 2024. This
request was approved on November 13, 2023 for a period of 2 years.

Now that the two years have elapsed since the prior approval, Taxpayer submitted the current
request for substitute mortality tables to be approved for a 5-year period effective with the plan
year beginning January 1, 2026 for Plan 1. This request was tentatively denied on September
11, 2025 due to stability concerns in accordance with section 1.430(h)(3)-2(d)(4)(v) of the
Treasury Regulations ("Regulations") and the disaggregation of the union and non-union male
populations in a manner that did not satisfy section 1.430(h)(3)-2(d)(5)(i) of the Regulations.
On September 25, 2025, the authorized representative requested an amended ruling for a
period of 3 years and adjusted the experience study to aggregate the union and non-union
male populations.

The Taxpayer's 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 of the Regulations, and Revenue
Procedure 2024-32.

Section 430(h)(3)(A) of the Code states, in relevant part, that the Secretary shall by regulation
prescribe mortality tables to be used in determining any present value of making any
computation under section 430 of the Code.

Section 430(h)(3)(C)(i) of the Code states, in relevant part, that 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
section 430 of the Code during the period of consecutive plan years (not to exceed 10)
specified in the request.

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

(II) the date on which the plan actuary determines that such table does not meet the
requirements of clause (iii).

Section 430(h)(3)(C)(iii) of the Code states, in relevant part, that a mortality table meets the
requirements of this clause if-

(I) 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 (II), 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)-2(c)(3)(i) of the Regulations states that 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) or (e) of this
section and the mortality improvement factors described in paragraph (c)(3)(ii) of this section.

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Section 1.430(h)(3)-2(c)(3)(ii) of the Regulations states, in relevant part, that the mortality
improvement factor for an age and gender is the cumulative mortality improvement factor
determined under section 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.

Section 1.430(h)(3)-2(c)(5)(i) of the Regulations allows a plan sponsor to use the same
substitute mortality table for two or more of its plans provided that the rules of section
1.430(h)(3)-2 of the Regulations are applied by treating those plans as a single plan. In such a
case, the substitute mortality tables must be based on data collected with respect to those
aggregated plans.

Section 1.430(h)(3)-2(c)(6)(ii) of the Regulations states, in relevant part, that a plan'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);

(B) 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-affiliated 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 (see section
601.601(d) of the Regulations) in conjunction with a replacement of mortality tables
specified under section 430(h)(3)(A) of the Code and section 1.430(h)(3)-1 of the
Regulations (other than changes to the mortality improvement rates under section
1.430(h)(3)-1(b)(1)(iii) of the Regulations or annual updates to the static mortality tables
issued as noted in section 1.430(h)(3)-1(c)(1)(iv) of the Regulations).

Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations states, in relevant part, that:

(A) 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

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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) 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).

Section 1.430(h)(3)-2(d)(2)(i) of the Regulations states, in relevant part, that 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.

Section 1.430(h)(3)-2(d)(2)(ii) of the Regulations states, in relevant part, that:

(A) 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.

(B) If the plan sponsor submits a request for approval to use substitute mortality tables
more than 1 year (and less than 2 years) before the first day of the first plan year for
which the substitute mortality tables are to apply, the experience study period is not
treated as failing to satisfy the rule in paragraph (d)(2)(ii)(A) of this section if the last day
of the final year reflected in the experience data is less than 2 years before the date of
submission. For example, if an application for approval to use substitute mortality tables
that would apply for plan year beginning on or after January 1, 2019 is submitted in
2017, then an experience study using calendar year data may be based on data
collected for a period that ends as early as December 31, 2015.

Section 1.430(h)(3)-2(d)(2)(iii) of the Regulations states, in relevant part, that as provided in
paragraph (d)(4)(I) of this section, the mortality rates under the base substitute mortality tables
are amounts-weighted mortality rates that are derived from the experience study. An
individual's benefit amount (which is used to determine amounts-weighted mortality rates and
for other purposes under this paragraph (d)) is the individual's accrued benefit expressed in the
form of an annual benefit commencing at normal retirement age (or at the current age, if later)
if an individual has not commenced benefits and the individual's annual payment if the
individual has commenced benefits. Because amounts-weighted mortality rates for a plan are

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determined using benefit amounts, the experience study used to develop a base substitute
mortality table may not include periods before the plan was established.

Section 1.430(h)(3)-2(d)(3)(ii) of the Regulations states, in relevant part, that 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)(iii) 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
(dX3)(v) of this section).

Section 1.430(h)(3)-2(d)(4)(i) of the Regulations states, in relevant part, that 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 (d)(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)(ii)(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.

Section 1.430(h)(3)-2(d)(4)(ii) of the Regulations states, in relevant part, that:

(A) 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 all 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 all 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

(ii) The benefit amount for the individual.

Section 1.430(h)(3)-2(d)(4)(iii) of the Regulations states, in relevant part, that:

(A) 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 section 1.430(h)(3)-1(b)(2)(ii) of the Regulations to the base
mortality table under section 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 section 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.

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(B) If a 12-month period in the experience study period that begins after December 31,
2019, and before January 1, 2023, the probability of death for an individual under
paragraph (d)(4)(ii)(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. For example, for an experience study period that begins April 1, 2019,
and ends March 31, 2023, the probability of death for the year beginning April 1, 2022,
for a male annuitant who is age 65 as of that date is the probability of death from the
base mortality table (0.01087), multiplied by the cumulative mortality improvement factor
for the period from 2012 to 2021 (1.02292) and by the adjustment factor for the 2022
calendar year of 1.075, resulting in a probability of death of 0.01195.

Table 1 to paragraph (d)(4)(iii)(B)

Calendar year

Adjustment factor

2020

1.15

2021

1.15

2022

1.075

(C)If the population consists solely of annuitants, the annuitant base mortality table set
forth in section 1.430(h)(3)-1(d) must be used for purposes of paragraph (d)(4)(iii)(A) of
this section. If the population consists solely of nonannuitants, the nonannuitants base
mortality table set forth in section 1.430(h)(3)-1(d) must be used for that purpose. If the
population includes both annuitants and nonannuitants, a combination of the annuitant
and nonannuitant base tables set forth in section 1.430(h)(3)-1(d) of the Regulations
must be used for that purpose. The combined table is constructed using the weighting
factors for small plans that are set forth in section 1.430(h)(3)-1(d) of the Regulations.

Section 1.430(h)(3)-2(d)(4)(iv) of the Regulations states, in relevant part, that 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 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.

Section 1.430(h)(3)-2(d)(4)(v) of the Regulations generally provides that the experience data
cannot be used to develop a base table if the number of individuals in the population covered
by the substitute mortality table as of the last day of the plan year before the year the request
to use the substitute mortality tables is made is less than 80% or more than 120% 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, an exception is made if it is
satisfactorily demonstrated that the experience data is accurately predictive of future mortality
of the population after appropriate adjustments to the data are made.

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Section 1.430(h)(3)-2(d)(6) of the Regulations states, in relevant part, that base substitute
mortality tables for a plan may be constructed by developing and applying a single mortality
ratio for both genders, but only if the substitute mortality tables used for all plans maintained by
members of the plan sponsor's controlled group (except for plans for which both the male and
female populations, considered separately, have mortality experience with full credibility) are
constructed in this manner. If the option under this paragraph (d)(6) is applied for a plan then,
for all plans maintained by members of the plan sponsor's controlled group, whether both the
male and female populations within the plan have credible mortality information (and, if that
combined population's mortality experience does not have full credibility, the partial credibility
weighting factor for the plan) is determined using the combined mortality experience for both
genders.

Section 1.430(h)(3)-2(e)(1) of the Regulations states, in relevant part, that 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 table 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

(ii) The product of-

(A) One minus the partial credibility weighting factor described in paragraph (e)(2) of
this section; and

(B) The mortality rate from the standard mortality tables described in paragraph
(d)(4)(iii) of this section.

Section 1.430(h)(3)-(e)(2) of the Regulations states, in relevant part, that 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

(ii) The denominator of which is the full credibility threshold for the population described in
paragraph (d)(3) of this section.

Section 1.430(h)(3)-2(g) of the Regulations states, in relevant part, that:

(1) This section applies for plan years beginning on or after January 1, 2025. Except as
provided in paragraph (g)(2) or (3) of this section, the substitute mortality table used for
a plan for such plan year must comply with the rules of paragraphs (a) through (f) of this
section.

(2) 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.

(3) A written request described in paragraph (b)(1)(i) of this section to use substitute
mortality tables for a plan year that begins during 2025 does not fail to satisfy the timing

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requirement of paragraph (b)(1)(ii) of this section if it is submitted no later than October
31, 2024, provided that the plan sponsor agrees to a 90-day extension of the 180-day
review period in accordance with paragraph (b)(2)(iv) of this section.

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 section 430 of the Code may request
approval from the Internal Revenue Service for the use of plan-specific substitute mortality
tables in accordance with section 430(h)(3)(C) and section 1.430(h)(3)-2 of the Regulations.

The substitute mortality tables were developed based on an experience study period from
January 1, 2019 through December 31, 2023, with a base year of 2021. This satisfies the
requirements under sections 1.430(h)(3)-2(c)(3) and (d)(2) of the Regulations.

The substitute mortality tables were developed by adjusting the applicable standard mortality
tables in section 1.430(h)(3)-1(d) of the Regulations with the mortality ratio and credibility
weighting factors shown below.

Mortality Ratio and Credibility Weighting Factor Table

Population

Mortality ratio

Credibility Weighting factor

Male participants

Female participants

Based on the information provided by the Taxpayer, there are no populations that lack credible
mortality experience. Therefore, there are no populations for which the standard mortality
tables will be used for calculations under section 430 of the Code.

In granting this approval, we have only considered whether the Taxpayer's proposed base
substitute mortality tables were 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 materials submitted with the
Taxpayer's request.

Permission is hereby granted to use the substitute mortality rates shown in the table below for
Plan 1.

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# Proposed Substitute Mortality Tables Approved for use beginning with the plan year commencing January 1, 2026 for Plan 1 Base year 2021

Age

Male Participants

Female Participants

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

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Age

Male Participants

Female Participants

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101

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Age

Male Participants

Female Participants

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

The above base substitute mortality tables were developed based on an experience study
period from January 1, 2019 through December 31, 2023, with a base year of 2021. The base
substitute mortality tables listed above were verified by the Taxpayer's authorized
representatives on December 3, 2025.

The Internal Revenue Service ("IRS") has reviewed the Taxpayer's proposed base substitute
mortality tables and supporting information, and has determined that based on the information
submitted, the Taxpayer's proposed base substitute mortality tables have been developed in
accordance with section 1.430(h)(3)-2 of the Regulations and Revenue Procedure 2024-32.

The above base substitute mortality tables 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(c)(6)(ii) of the Regulations, which describe the circumstances in which the use of the base
substitute mortality tables will terminate before the end of the 10-year period described above.
In general, the base substitute mortality tables can no longer be used as of the earliest of:

(1) For a plan using a substitute mortality table for only one gender, the first plan year for
which there is full or partial credible mortality information with respect to the other
gender that had lacked credible mortality information (unless an approved substitute
mortality table is used for that gender),

(2) The first plan year in which the plan fails to satisfy the requirements of
section 1.430(h)(3)-2(c)(1) of the Regulations, regarding the requirement that other
plans and populations in the controlled group must also use substitute mortality tables
unless it can be demonstrated that they do not have credible mortality information

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(taking into account the transition period for newly affiliated companies in section
1.430(h)(3)-2(f)(3) of the Regulations),

(3) The second plan year following the plan year for which there is a significant change in
individuals covered by the plan as described in section 1.430(h)(3)-2(c)(6)(iii) of the
Regulations,

(4) The plan year following the plan year in which a substitute mortality table used for a
plan 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 pursuant to a
replacement of mortality tables specified under section 430(h)(3)(A) of the Code and
section 1.430(h)(3)-1 of the Regulations, other than changes to the mortality
improvement rates under section 1.430(h)(3)-1(b)(1)(iii) of the Regulations or annual
updates to the static mortality tables issued as noted in section 1.430(h)(3)-1(c)(1)(iv)
of the Regulations.

Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations provides that the use of the base substitute
mortality tables must be discontinued after a significant change in coverage unless the plan's
actuary certifies in writing to the satisfaction of the Commissioner that the base substitute
mortality tables used for the population continue to be accurately predictive of future mortality
of the population (taking into account the effect of the change in the population). For this
purpose, a significant change in coverage occurs if the number of individuals covered by the
base substitute mortality table for a plan year is less than 80 percent or more than 120 percent
of either:

(1) the average number of individuals in that population over the years covered by the
experience study on which the base substitute mortality tables are based, or

(2) the number of individuals covered by the base substitute mortality tables in a plan year
for which a certification described in section 1.430(h)(3)-2(c)(6)(iii)(A) of the Regulations
was made.

The following information was submitted by the Taxpayer to demonstrate stability:

Population

Average Number During Experience Study Period

Number as of 12/31/2023

Percentage Difference

Male Participants

Female Participants

Since the decrease in the number of participants in the male population as of December 31,
2024 exceeds 20% of the average number of individuals during the experience study period,
the Taxpayer has not satisfied the stability requirement of section 1.430(h)(3)-2(d)(4)(v) of the
Regulations. However, the IRS considered all the facts, including that this threshold was
slightly exceeded by only one of the populations and the Taxpayer requested the use of these
substitute mortality tables for only 3 plan years.

A certification must be provided each year that it is required under the section 1.430(h)(3)-
2(c)(6)(ii)(C) of the Regulations, as described above, signed by the enrolled actuary for Plan 1,

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stating that the base substitute mortality tables continue to be accurately predictive of the
expected future mortality for Plan 1. This certification must also contain a statement that:

(A) 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;

(B) The enrolled actuary was personally involved in the determination that the substitute
mortality table is still accurately predictive and provides the actuary's best estimate for
the Plan;

(C)In determining that the substitute mortality table is 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,

(D) The enrolled actuary has the specific knowledge and experience to make the
judgements 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:

(A) The number of actual deaths during the experience study period used to develop the
substitute mortality tables and the beginning and ending dates of the experience study
period.

(B) A table showing the number of expected deaths and actual deaths, reported separately
as of December 31, 2024 and for each plan year beginning with deaths during the plan
year ending December 31, 2024 through the plan year immediately preceding the most
recent actuarial valuation, and in total.

(C)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 the substitute mortality table 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, 2024 through the plan year immediately preceding the most recent
actuarial valuation, expressed both as a headcount and as a percentage of the average
number of participants in the experience study.

(D)A table showing a comparison of (i) the average ages and (ii) 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 the 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.

(E) 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 Service) to the following address:

Internal Revenue Service
Attn: Mr. David M. Ziegler

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TE/GE: SE:T:EP:RA:T:A2
IR-6213
1111 Constitution Ave. NW
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 the substitute mortality tables
pursuant to section 1.430(h)(3)-2(c)(6)(ii) of the Regulations.

This letter 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 the letter ruling was based, or the transaction involves a
continuing action or series of actions and the controlling facts change during the course of the
transaction.

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 the Form 5500 for Plan 1 for the plan years for 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.

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.
Additionally, a copy of this letter ruling is being sent to the Manager, Classification Group 4 in
Houston, Texas.

If you require further assistance in this matter, please contact
) at (
)

(ID#

Sincerely,

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: