Three pension plans may use substitute mortality tables for five years

Plain-English summary

A sponsor of three defined benefit pension plans asked to use plan-specific substitute mortality tables when computing minimum funding obligations under IRC § 430. The request covered male and female annuitants and non-annuitants, including disabled participants, and used experience from 2019 through 2023 with a 2021 base year. The IRS found that the proposed rates were developed in accordance with the regulations and Revenue Procedure 2024-32. It approved the tables for up to five plan years beginning January 1, 2025. The approval can end early if coverage changes significantly, the tables stop accurately predicting mortality, controlled-group requirements fail, or replacement guidance applies. The sponsor must provide any required annual actuarial certifications and supporting information by the Form 5500 filing date.

Ruling snapshot

• Question: May the sponsor use substitute mortality tables for four participant populations across three pension plans?
• Outcome: Approved for up to five plan years beginning January 1, 2025
• Key authorities: IRC § 430(h)(3); ERISA § 303(h)(3); Treas. Reg. § 1.430(h)(3)-2; Rev. Proc. 2024-32

Full text (IRS public release)

Significant Index No. 0430.00-00

JUL 0 1 2025

Release Number: 202539016
Release Date: 9/26/2025

Re: Substitute Mortality Table Ruling

Taxpayer:
EIN: -

Plans for which substitute mortality tables are requested:

Plan 1:
EIN: - /PN
Plan 2:
EIN: - /PN
Plan 3:
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 Code for the above Plans has been granted with
respect to the populations specified in this letter. This ruling is effective for a period of up to 5
plan years beginning with the plan year commencing January 1, 2025 for Plan 1, Plan 2, and
Plan 3. 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 of Plan 1, Plan 2 and Plan 3

Male annuitants, including disabled participants
Female annuitants, including disabled participants
Male non-annuitants, including disabled participants
Female non-annuitants, including disabled participants

The Taxpayer submitted this request for a ruling to use a substitute mortality table for the plan
year beginning January 1, 2025 for Plan 1, Plan 2, and Plan 3, based on an experience study
period from January 1, 2019 through December 31, 2023, with a base year of 2021.

This is the second request for use of substitute mortality tables for plans in Taxpayer's
controlled group. Taxpayer previously requested to use substitute mortality tables for Plan 1
under section 430(h)(3)(C) of the Code for up to 10 plan years effective with the plan year
beginning January 1, 2019. These tables were approved on April 23, 2019.

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 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) 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:

(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),

(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 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.

(D) 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(c)(1)(iv) of the Regulations or
changes to the mortality improvement rates pursuant to 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 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. 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 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.
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(d)(4)(iii)(B) of the Regulations provides for adjustments to the probability
of death for an individual from the standard mortality table during a 12-month period in the
experience study period that begins after December 31, 2019, and before January 1, 2023. For
Plan years in which the first day of the Plan year is within 2020 or 2021, the base mortality
rates are increased by 15%, and for Plan years in which the first day of the Plan year is within
2022, the base mortality rates are increased by 7.5%.

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.

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

These were determined by aggregating male and female experience (including disabled
participants) for each group.

This approval applies to the following specific populations of Plans 1, 2 and 3:

Male annuitants, including disabled participants
Female annuitants, including disabled participants
Male non-annuitants, including disabled participants
Female non-annuitants, including disabled 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.¹

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
the Plans.

Substitute Mortality Tables
Approved for use beginning with the plan year commencing
January 1, 2025 for Plan 1, Plan 2, and Plan 3
Base year 2021

¹ Taxpayer represents that there was one other plan in the controlled group that was sponsored by Taxpayer. However,
Taxpayer represents that the plan was terminated effective October 31, 2024 and therefore excluded from the ruling request.

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) 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 5-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 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 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

(5) 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(c)(1)(iv) of the Regulations or
changes to the mortality improvement rates pursuant to 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 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.

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

A certification must be provided each year that it 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;

10

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:

(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, 2023 and for each plan year beginning with deaths during the plan
year ending December 31, 2023 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, 2023 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: 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:

11

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
(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 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 (ID# ) at

( ) -

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

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