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GO TO REGULATIONS.GOV IN SEARCH ENTER 2015 0009 1303 DOWNLOAD PDF FILE ANOTHER INTRESTING READ...

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United States Department of the Treasury
1500 Pennsylvania Avenue, N.W.
Washington, District of Columbia 20220
! Dear Mr. Secretary:
! This letter supplements my earlier correspondence to you, dated December 2, 2015, concerning Central States, Southeast and Southwest Areas Pension Fund (“CSPF”). In that submission, I stated that all reasonable measures have not been taken to avoid insolvency of CSPF. In furtherance of insuring that all reasonable measures have been taken, I ask that you immediately require CSPF to bring in an independent, professional pension fund administrator with proven experience in reorganizing near bankrupt benefit funds: (1) to review its internal operations; (2) to review the performance of its investment managers and the reasonableness of their fees; (3) to determine whether any changes can be made to its program of benefits to attract new employers and their much needed contribution income; and, (4) to determine whether, in his or her expert opinion, CSPF administration has done everything possible to accomplish a turnaround of this organization.
! I ask you to consider the action, described above, because CSPF administration has, to date, been unable to explain what avenues of recovery it has explored or attempted to pull CSPF out of its death spiral other than repeated benefit cuts. First, through its “Rehabilitation Plan” and now through its “Rescue Plan.” What further erosion of retiree benefits will be next since CSPF administration, by its own admission, has stated that CSPF has only slightly more than a “50/50” chance of long term survival even if Treasury approves the plan now under review? CSPF administration does not seem to be able to come up with anything but the easiest, most obvious solutions to the nagging financial problems CSPF is facing.
! Accordingly, to determine, once and for all, whether CSPF administration simply lacks the know-how to develop a more creative plan than the slash and burn proposal submitted to the Treasury or whether there is just no other alternative to these benefit cuts, it is time for a fresh look by a seasoned set of eyes belonging to someone who has experience with bringing back organizations, like CSPF, from their slow walk to the grave. Someone who is acquainted with, and will be able to draw ideas from the best minds in the employee benefit field. Surely, with the vast resources available to the federal government, finding such a turnaround specialist is possible. Large troubled corporations do it all the time. Apple is a prime example. General Motors flourished after Mr. Wagoner stepped down. And, these are only the first success stories that come to mind. There are countless more. So, leadership and new thinking are huge factors. They are, more often than not, game changers. The retirement lives of too many CSPF retirees, actives and their families hang in the balance to do anything less than to try everything possible before resorting to the most punishing fix. No profit minded, publicly traded company would stand for the kind of apparent ineffective management CSPF seems to have had for years now without already having make a change in leadership. Stockholders are far less forgiving and much more quick to pressure a corporate board to act when they do not see the results they expect. They also have the power to effectuate management change. A power that retirees of an employee benefit plan lack.
! Mr. Nyhan, the CSPF Executive Director, claims that there is great urgency to push the button on the pension reductions it intends to implement and insists that unless these reductions are made as scheduled, it may be too late to save CSPF from complete bankruptcy and turnover to PBGC. To safeguard against this outcome, I would suggest that the federal government consider a deal structured
along the same lines as its rescue of General Motors. Provide CSPF with some sort of financial assistance to guarantee, at least, the benefit reduction amounts already calculated until the independent, professional administrator completes his or her work. Announcing this plan, would go a long way in settling the growing unrest sweeping through the ranks of CSPF retirees across this country. A groundswell that is surely to surface on the national stage once these movements attract media attention. And, that is sure to happen. Failure, by the federal government, to take every imaginable action to avoid these draconian cuts is sure to be an embarrassment of epic proportions. Seeing scores of abandoned seniors of this country on the nightly news is not going to be a pleasant or welcome sight.
! I have now been contacted by several retirees who are members of Retiree Chapters across this country that are fighting the CSPF benefit cuts. I have also had the opportunity to speak with some of the leadership of these organizations. They all tell me that they cannot get any answers out of the CSPF administration. That their requests for face to face meetings with CSPF administration officials are refused. That requests by the officers of the Teamster local unions, that represented them during their working days, to CSPF administration for meetings, at their geographic locations, once a commonplace occurrence, have been refused. That they and their members have “no confidence” in CSPF leadership at every level. So, I urge you to take the suggestions I present in this letter seriously.
! I assure you that I have absolutely no ax to grind with CSPF or any of its employees, including Mr. Nyhan whom, I truly believe, is a very competent and talented lawyer. I left that organization voluntarily. Any office politics, common between employees in any business where differing viewpoints are held, have been in my rear view mirror for many years. I now lead a thrilling life in an industry completely separate and apart from the world of everyday business. I wanted to get away from CSPF entirely. I would cringe whenever I saw mail from CSPF because I knew, sooner or later, bad news was coming. I have taken a keen interest in this tragic matter to do what I can to help the hundreds of thousands of wonderful hard working men and women who stand to lose the dignified retirement they have earned through their back breaking labors; so many of whom I had the honor and distinct pleasure of meeting personally. It was so nice to hear from so many of them again.
! I appreciate the opportunity to supplement my earlier comments on this matter and look forward to your reply. I have enclosed a copy of a booklet I put together back in the late 1980’s to describe the position of CSPF on becoming fully funded. Almost 500,000 copies of this document were distributed. My regret is that the objectives I stated in this booklet were never followed.
! Thank you for your time and attention.
! Sincerely,
! Bruce C. Trojak Bruce C. Troja
 
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