IRS written determination 202640011

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 ENTITIES
DIVISION

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON D.C. 20224
JUL 0 9 2026

Release Number: 202640011
Release Date: 10/2/26

Re: Substitute Mortality Table Ruling

Taxpayer =
EIN:
\-

Plan 1 =
EIN:
\-
; PN:

Other Plan For Which Substitute Mortality Tables Are Not Intended to Be Used:

Plan 2 =
EIN:
\-
; PN:

Dear
:

This letter is to inform you that your request to use substitute mortality tables for making
computations under section 430 of the Internal Revenue Code of 1986 ("Code") for the
above Plan 1 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 years
commencing November 1, 2026 for Plan 1. 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 ("ERISA").

This approval applies to the following specific populations of Plan 1:

· Combined male and female annuitants

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

Taxpayer previously received a ruling, dated January 11, 2021, granting the use of
substitute mortality tables for Plan 1, effective with the plan years commencing

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November 1, 2020. Taxpayer performed a new experience study and requested use of
new tables for a 10-year period effective with the plan year beginning November 1.
2022. This request was approved on September 12, 2022. Due to the amendments to
section 1.430(h)(3)-2 of the Regulations published in the Federal Register on July 31,
2024, Taxpayer submitted this new request for a ruling to use substitute mortality tables
for the plan years beginning November 1, 2026 for Plan 1.

Based on the information provided by Taxpayer, the combined male and female
nonannuitant population of Plan 1 and the total population of Plan 2 lack credible
mortality experience. Therefore, the standard mortality tables will be used for
calculations under section 430 of the Code for the nonannuitant population of Plan 1
and all of Plan 2. Taxpayer represents that there are no other plans subject to section
430 of the Code maintained by the Taxpayer or a member of the controlled group that
was spun off from another plan within the five-year period preceding the date of this
request. Taxpayer also represents that it does not sponsor a multiple employer plan.

# Applicable Law

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:

(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.
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.

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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)(4) of the Regulations states, in relevant part, that if separate
mortality tables are used for certain disabled individuals as permitted under section
430(h)(3)(D) of the Code, then those disabled individuals are disregarded for all
purposes under section 1.430(h)(3)-2 of the Regulations, and mortality experience with
respect to those individuals must be excluded in developing mortality rates for substitute
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:

(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 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 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 Section 1.430(h)(3)-
2(c)(6)(iii) of the Regulations,

(D) The first plan year following the plan year for 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 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 annual updates to the static mortality tables issued as noted in
section 1.430(h)(3)-1(c)(1)(iv) of the Regulations or changes to the mortality
improvement rates under section 1.430(h)(3)-1(b)(1)(iii) 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

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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.1 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. However, if the plan sponsor submits a request
for approval to use of 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, then the experience study is not treated as failing to satisfy the rule in
section 1.430(h)(3)-2(d)(2)(ii)(A) of the Regulations if the last day of the final year
reflected in the experience data is less than 2 years before the date of submission.

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. If the simplified rule under section 1.430(h)(3)-
2(c)(2)(ii)(B) of the Regulations 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)(iii)(B) of the Regulations require that adjustments be made
to the standard mortality table for any 12-month period in the experience study that
begins after December 31, 2019 and before January 1, 2023. Such adjustment factors
are 15% increases for calendar years 2020 and 2021 and a 7.5% increase for calendar
year 2022.

Section 1.430(h)(3)-2(e)(1) of the Regulations states, in relevant part, that if the actual
number of deaths is at least equal to 100 and is less than the full credibility threshold,
then the base mortality rates are determined using a partial credibility weighting factor
as calculated under section 1.430(h)(3)-2(e)(2).

# Facts and Analysis

The substitute mortality tables were developed based on an experience study period
from January 1, 2021 through December 31, 2023, with a base year of 2022. This
satisfies the requirements under sections 1.430(h)(3)-2(c)(3) and (d)(2) of the
Regulations.

' If two or more plans are aggregated and not all of the plans have the same plan year, then the
experience study period may be a period that is not a multiple of 12 months provided that four criteria
under section 1.430(h)(3)-2(c)(5)(iii) are met

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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.

Population

Mortality ratio

Credibility factor

Male and female annuitants

These were determined by combining male and female annuitant (including disabled
annuitant) experience.

Based on the information provided by Taxpayer, the combined male and female
nonannuitant population of Plan 1 and the total population of Plan 2 lack credible
mortality experience. Therefore, the standard mortality tables will be used for
calculations under section 430 of the Code for the nonannuitant population of Plan 1
and all of Plan 2.

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 2024-32. 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 Plan 1.

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# Substitute Mortality Tables Approved for use beginning with the plan years commencing November 1, 2026 for Plan 1 Annultants: Base year 2022

Age

Males

Females

Age

Males

Females

Age

Males

Females

15

51

86

16

52

87

17

53

88

18

54

89

19

55

90

20

56

91

21

57

92

22

58

93

23

59

94

24

60

95

25

61

96

26

62

97

27

63

98

28

64

99

29

65

100

30

66

101

31

67

102

32

68

103

33

69

104

34

70

105

35

71

106

36

72

107

37

73

108

38

74

109

39

75

110

40

76

111

41

77

112

42

78

113

43

79

114

44

80

115

45

81

116

46

82

117

47

83

118

48

84

119

49

85

120

50

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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 2024-32.

The above rates must be applied on a generational basis, as provided in
section 1.430(h)(3)-2(c)(3)(i) 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 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 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),

(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 (taking into account the transition period for newly-affiliated
plans 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 first plan year following the plan year for 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 Bulletin 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 annual updates to the static mortality tables issued as noted in
section 1.430(h)(3)-1(c)(1)(iv) of the Regulations or changes to the mortality
improvement rates under section 1.430(h)(3)-1(b)(1)(iii) of the Regulations.

Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations provides that the 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

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future mortality of the population (taking into account the effect of the change in the
population). As noted on page 4 of this letter, 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.

The following information was submitted by Taxpayer to demonstrate stability:

Population

Average Number During Experience Study Period

Number as of 10/31/2025

Percentage Difference

Combined male and female annuitants

A certification must be provided each year that is required under the Regulations, 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 experience to make the
judgements set forth above and attests to these representations.

All required certifications must be provided on or before the date the 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.

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(2) A table showing the number of expected deaths and actual deaths, reported
separately as of December 31, 2025 and for each plan year beginning with
deaths during the plan year ending December 31, 2025 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 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, 2025 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.

(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:

a. under $100,

b. between $100 and $250,

c. between $250 and $500,

d. between $500 and $1,000,

e. between $1,000 and $1,500, and

f. $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

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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 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 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.

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.

Pursuant to a Power of Attorney and Declaration of Representative (Form 2848) 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,
Classification Group 4 in Houston, Texas.

If you require further assistance in this matter, please contact Mr.
(ID#
) at (
1

Sincerely,

David M. Ziegler, Manager
Employee Plans Actuarial Group 2

Enclosures
Notice 437, Notice of Intention to Disclose (Rulings)
Deleted copy of the letter ruling

cc: