Significant Index No. 0430.00-00 TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, O.C. 20224 SEP 12202Z Re: Substitute Mortality Table Ruling Taxpayer= Plan for which substitute mortality tables are requested: Plan= EIN: , (Plan No. ) 202249023 T:EP::RA:A2 Other Plan in the controlled group for which substitute mortality tables are not requested: Newly-Affiliated Plan = EIN: , (Plan No. ) Dear This letter is to inform you that your request to use substitute mortality tables for making computations under section 430 of the Code for the above Plan has been granted with respect to the populations specified in this letter. This ruling is effective for a period of up to 10 plan years beginning with the plan year commencing November 1, 2022. 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. This approval applies to the following specific populations: • Male annuitants and female annuitants, including disabled participants The Plan previously received a ruling, dated January 11, 2021, granting the use of a substitute mortality table for the same population, effective for a period up to a 10 years beginning with the plan year commencing November 1, 2020. The study period used to construct that table was based on the calendar years 2017 and 2018. The Taxpayer submitted this new request for a ruling to use a substitute mortality table for the plan year beginning November 1, 2022. The Taxpayer represented they wanted to reflect an

202249023 2 additional year of experience (calendar year 2019) and that reflecting the additional year would give the Plan full credibility and a more accurte assessment of the Plan's mortality experience. This request is made in accordance with section 430(h)(3)(C) of the Code, section 303(h)(3) of the Employee Retirement Income Security Act of 1974, section 1.430(h)(3)-2 of the Treasury Regulations ("Regulations"), and Revenue Procedure 2017-55. The Taxpayer represented that the Newly-Affiliated Plan became part of the controlled group belonging to the Taxpayer on February 3, 2020. During the study period, it had approximately 20 participants and fewer than 100 deaths. As such, the Newly-Affiliated Plan is exempt from the requirement that all members of the controlled group must use the same substitute mortality table. 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) of the Code states, that upon request by the plan sponsor and approval by the Secretary, a mortality table 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, a substitute mortality table shall cease to be in effect as of the earliest of: (1) 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 (2) the date on which the plan actuary determines that such substitute mortality table does not meet the following requirements of Section 430(h)(3)(C)(iii) of the Code. Section 430(h)(3)(C)(iii) of the Code states, in relevant part, that a mortality table meets the requirements of this section 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, and (II) such substitute mortality 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) of the Regulations states, in relevant part, that 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. Additionally, a plan's substitute mortality tables must be generational mortality tables. 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:

202249023 3 (A) 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), (8) The first plan year in which the plan fails to satisfy 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 (taking into account the transition period for newly affiliated companies), (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 Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations. (0) 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 annual updates to the static mortality tables issued pursuant to section 1.430(h)(3)-1 (a)(3) of the Regulations or changes to the mortality improvement rates pursuant to section 1.430(h)(3)- 1 (a)(2)(i)(C) of the Regulations. Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations states, in relevant part, 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% or more than 120% of either the average number of individuals in that population over the years covered by the experience study on which the substitute mortality tables are based, or the number of individuals covered by the substitute mortality table in a plan year for which a certification (described below) 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 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). Section 1.430(h)(3)-2(d)(2) of the Regulations states, in relevant part, that 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. 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. ---------

202249023 4 Section 1.430(h)(3)-2(d)(4) of the Regulations states, in relevant part, that the base mortality rates are determined by multiplying the mortality rate from the standard mortality table by the mortality ratio. Section 1.430(h)(3)-2(e)(1) of the Regulations states, in relevant part, that if the actual number of deaths is less than the full credibility threshold, then the base mortality rates are determined using a partial credibility weighting factor. Section 1.430(h)(3)-2(f) of the Regulations provides special rules for newly-affiliated plans-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 § 1.41 0(b )- 2(f). A plan also is treated as a newly-affiliated plan for purposes of this section if the plan is established in connection with a transfer of assets and liabilities from another employer's plan in connection with a merger, acquisition, or similar transaction described in§ 1.410(b)-2(f). The use of substitute mortality tables for a plan within a controlled group is not prohibited merely because, during the transition period, substitute mortality tables are not used for a newly-affiliated plan that fails to demonstrate a lack of credible mortality information during that period. Similarly, during the transition period, the use of substitute mortality tables for a newlyaffiliated plan is not prohibited merely because substitute mortality tables are not used for another plan within the controlled group that fails to demonstrate a lack of credible mortality information during that period. The transition period begins on the date of the transaction that results in the plan becoming a newly-affiliated plan and ends on the last day of the plan year that immediately follows the latest ending period described in section 410(b)(6)(C)(ii) with respect to that transaction for any of the plans in the controlled group. The substitute mortality tables were developed based on an experience study period from January 1, 2017 through December 31, 2019, with a base year of 2018. 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 Credlblllty Weighting Factor Table Aggregated Male and Female Annuitants, lncludin Dlsabled Annuitants These were determined by aggregating male and female annuitant experience (including disabled annuitants). These adjustments are required under sections 1.430(h)(3)-2(d)(4) and (e)(1) of the Regulations. Because the information submitted demonstrates that the Plan's annuitant population has credible mortality experience and the Plan's nonannuitant population has a lack of credible

202249023 5 mortality experience, the Plan meets the requirement for applying substitute mortality tables for annuitants without applying substitute mortality table to nonannuitants. On this basis, application of the substitute mortality mortality table to the plan population will be as follows: This approval applies to the following specific populations: • Male annuitants and female annuitants, including disabled participants Based on the information provided by the Taxpayer, the following populations do not have credible mortality experience, and therefore the standard mortality tables will be used for calculations under section 430 of the Code: • Male and female nonannuitants In granting this approval, we have only considered whether the substitute mortality rates were developed in accordance with section 1.430(h)(3}-2 of the Regulations and Revenue Procedure 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 table below for the Plan. Substitute Mortality Tables Approved for use beginning with the plan year commencing November 1, 2022 Base year 2018 Age Male Female Annuitants Annuitants 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33

202249023 6 Age Male Female Annuitants Annuitants 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78

202249023 7 Age Male Female Annuitants Annuitants 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 The above mortality rates were developed based on an experience study period from January 1, 2017 through December 31, 2019, with a base year of 2018.

8 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 developed in accordance with section 1.430(h)(3)-2 of the Regulations and Revenue Procedure 2017-55. 202249023 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( c)(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: (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 requiremeint 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 (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 signiHcant 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 (5) The date specified in guidance published in the Internal Revenue BullE~tin 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 annual updates to the static mortality tables issued pursuant to section 1.430(h)(3)-1(a)(3) of the Regulations or changes to the mortality improvement rates pursuant to section 1.430(h)(3)- 1 (a)(2)(i)(C) of the Regulations. We draw your attention to the fact that the nonannuitants experienced 62 dlea1ths during the experience study period. Note that this population will have credible mortality experience if it experiences at least 100 deaths during a 3-year period ( corresponding to the l1ength of the experience study used to construct the substitute mortality tables for the other- populations). It

202249023 9 is important to monitor this population to ensure that appropriate action is takEm should this occur, to avoid violating paragraph (2) above. Also note that section 1.430(h)(3)-2(c)(6)(iii) of the Regulations provides that 1he use of 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 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 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 substitute mortality table is based, or (2) the number of individuals covered by the substitute mortality table 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. For reference, the average number of the combined male and female annuitants in the Plan over the years covered by the experience study, as well as the most recent n1Jmber of combined male and female annuitants in the submission, are as follows: Combined Male and Female Annuitants Average during the experience study oeriod Most recent data in the submission (October 31, 2021) A certification must be provided each year that it is required under the Reguls1tions, as described above, signed by the enrolled actuary for the plan and stating that the substitute mortality tables continue to be accurately predictive of the expected future mortality for the plan. The 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 experienc:e to make the judgements set forth above and attests to these representations.

202249023 10 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 the 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, 2019 and for each plan year beginning with deaths during the plan year ending October 31, 2022 through calendar year immediately preceding the most recent actuarial valuation, and in total. (3) A table similar to the stability demonstration required under section 8 of Revenue Procedure 2017-55, 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 October 31, 2022through 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. (4) 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. (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 Service) to the following address .. Internal Revenue Service Attn: Mr. David M. Ziegler 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 - ------------

202249023 11 (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 ruling is directed only to the taxpayer that requested it. Section 611 0(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. Pursuant to a power of attorney on file with this office, a copy of this letter ruling is being sent to your authorized representatives. Additionally, a copy of this letter ruling is being sent to the Manager, EP Classification in Houston, Texas and to the Manager, EP Compliance Unit in Chicago, Illinois. If you require further assistance in this matter, please contact (ID# ) at ( ) Enclosures Sincerely, David M. Ziegler, Manager Employee Plans Actuarial Group 2 Notice 437, Notice of Intention to Disclose (Rulings) A deleted copy of the ruling cc: Manager, EP Classification Houston, TX Manager, EP Compliance Unit Chicago, Illinois