<D C <D m c o w c <D CL c o to u_ o Q. £ C s co □ 0 CN cs in <u c □ O 00 <D C Q N m O\ 1 — < MO o o > 4^ B z s c5 <D a N One such reportable event is the active participant reduction event, which occurs when, as a result of a single cause (such as a reorganization or mass layoff), or through employee attrition, the number of active participants in a plan is reduced below 80 percent of the number at the beginning of the plan year. See 29 C.F.R. § 4043.23(a).

o o co a 3 <D o =5 c o a . aS c o o g rr> . H c O c c 03 o 3 o § o c § o c c: o o c o c3 F 5 □ C ctf 3 o o <D > -S 3 o 3 3 co O o <z> (D O £ =5 C C <3 O £ c3 s E <D I ob E <D C coo cd £ C O 5 i GO 6 a £ = O <D ’ ■E as .S O GO 3 c O •2 & cd t N ’ E cd B? o C O Q — < > O o o cd C co 4-> e cd £ o c 1 These types of transactions are expressly contemplated by ERISA and may also be employed by a plan sponsor for purposes of plan termination consistent with ERISA section 4041(b)(3)(A)(i).

This letter constitutes an opinion letter and is based on the facts and representations described in your request. Accordingly, it is subject to the provisions of PBGC ’ s Opinion Letter Program procedures, including the section relating to the effect of an opinion letter. 2 o W) cd O h resources/opinion-letters/procedures.