What Are the Voting Procedures Required to Suspend Benefits in a Multiemployer Plan?

In September, the Department of Treasury issued rules for administering the participant vote on an application to suspend benefits under the Multiemployer Pension Plan Reform Act of 2014 (“MPRA”). The trustees must distribute a package containing all required disclosures and ballot materials to eligible voters. The packages should be unique to each voter, containing the voter’s address and an individualized impact statement. The Plan must collect and tabulate the votes using an automated voting system that allows participants to cast their votes electronically or through an interactive voice telephone system. Finally, the Treasury determines, in consultation with the Department of Labor and the PBGC, if a majority of eligible voters have voted to reject the suspension.