Potential measures to ease AMO membership access to earned benefits from the AMO Pension Plan will soon be submitted to the Internal Revenue Service for approval as required by federal law.

Four specific proposals will be presented to the IRS by the AMO Pension Plan's actuarial consultants, a procedure specified in the 2006 Pension Protection Act, the principal statute governing single and multiemployer defined benefit retirement plans.

The proposals - ranging from the optional receipt of monthly benefits from the AMO Pension Plan while remaining at work under AMO contract to a one-time partial lump-sum payment of accrued benefits to vested AMO members - were developed by the joint union-employer AMO Pension Plan trustees during a meeting March 7 at AMO Plans in Dania Beach, Florida. The trustees will meet again the week of May 20.

AMO Plans Executive Director Steve Nickerson, additional AMO Plans administrative personnel, the actuaries, AMO Plans counsel and the independent certified public accountant who audits AMO Plans participated in the March 7 discussion.

The trustees' proposals were vetted as required through "preliminary analysis" by the actuaries.

Details on each of the four proposals must be withheld for now to shield confidential financial data and to acknowledge the possibility that each proposal's mechanics are subject to modification by the IRS during the agency's deliberations.

Tactical considerations also require confidentiality at this point. One proposal is especially sensitive because it is based on an unusual but legitimate premise, and it requires an unprecedented strategic approach.

These developments represent the first practical opportunity under the Pension Protection Act to pursue retirement relief for active AMO members since the AMO Pension Plan was suspended as deficient and vested benefits were frozen under the law on December 31, 2009.

The AMO Pension Plan languished as "critical" in the Pension Protection Act's "red zone" at a funded status of 60 percent from fiscal 2009 through 2011 and as "endangered" in the statute's "yellow zone" at a funded status of 70 percent from fiscal 2012 through 2017.

Corrective measures were not permitted until the AMO Pension Plan reached the Pension Protection Act's "green zone" - with a funded status of 82.3 percent - at the close of its fiscal year 2018 last September 30. The actuaries project 100 percent funding of the AMO Pension Plan by 2021, based on current actuarial assumptions.

While this real movement to address complicated AMO Pension Plan issues is encouraging, considerable legal restrictions remain in force.

For example, AMO Pension Plan trustees can take no action that could force the Plan back into the Pension Protection Act's "yellow" or "red" funded status zones.

Nor can the trustees do anything that could limit the AMO Pension Plan's ability to sustain monthly benefits to current AMO retirees or their survivors through actuarial projections of longer lifespans.

Moreover, the trustees can do nothing that could jeopardize benefits due at age 65 to individuals vested in the AMO Pension Plan but no longer working under AMO contract.

Given these constraints, the AMO Pension Plan and its actuarial and accounting professionals are calculating the potential cost to the Plan of each proposed remedial measure.

This is a tough task because AMO Pension Plan assets will have to overcome a likely increase in liabilities, and the Plan's asset-to-liability ratio is variable, subject to assumption and vulnerable to change up or down every business day.

For example, the Dow Jones industrial Average on March 22 plunged 460 points. Like all individual and institutional investors, the AMO Pension Plan lost money that day. The markets have since recovered, but the jarring number from Wall Street evoked memories of the record investment losses logged in the fourth quarter of calendar year 2018, and it reminded all of us of the fragile financial conditions affecting retirement planning not only for all AMO families, but also for all working men and women at sea and ashore.

This is one reason the AMO Pension Plan trustees last year transferred its money management to an investment firm working exclusively with defined benefit retirement funds.

As our union's lead benefit fund trustee, I will keep all AMO members informed of each AMO Pension Plan development as it occurs and as strategic sense allows. Meanwhile, I thank you for your extraordinary patience during a long, difficult and frustrating stretch. I assure you that the AMO Pension Plan trustees are committed to a fair, responsible and legally permissible end to this crisis.

Paul Doell
National President, American Maritime Officers
Secretary, AMO Pension Plan Board of Trustees