Benefit reduction

Pension Benefit Guaranty Corporation 75-91 July 15, 1975 RE FERENCE: [*1] 4041 Termination by Plan Administrator404 3(b)(2) Reportable Events. Amendment Decreasing Benefits OP INION: This i s in response to your July 3, 1 975 letter to the Office of the General Counsel, Pension Benefit GuarantyCo rporation ("PBGC") in which you inquired if a reduction in pension benefits is considered a plan termination. Under Title IV of th e Employee Retirement Income Security Act of 1974 ("ERISA"), which establishes th e PBGC,the "reducti on" that you describe in your letter does not const itute a termination. However, it does appear to co nstitutea "repor table event" under ERISA, § 4043(b). As su ch, the plan administrator of your pension plan should notify thePB GC of the adoption of the proposed change within 30 days from the date of the adoption. (ERISA, § 4043(a)). I hop e this information has been helpful to you. Henry Rose Ge neral Counsel