Rp 2024-32

Revenue Procedure 2024-32
SECTION 1. PURPOSE
1. This revenue procedure sets forth the procedure by which the sponsor of a defined
benefit plan that is subject to the funding requirements of § 430 of the Internal
Revenue Code (Code) may request approval from the Internal Revenue Service
(IRS) for the use of plan-specific substitute mortality tables in accordance with
§ 430(h)(3)(C) and § 1.430(h)(3)-2 of the Treasury Regulations.1
2. This revenue procedure updates the procedures set forth in Rev. Proc. 2017-55,
2017-43 IRB 373, and reflects the amendments to § 1.430(h)(3)-2 that were
published in the Federal Register on July 31, 2024 (TD 10005, 89 FR _____).
3. In accordance with § 1.430(h)(3)-2(c)(6)(ii)(E), this revenue procedure also specifies
the date by which the use of a previously approved substitute mortality table must be
terminated in conjunction with the replacement of the generally applicable mortality
tables specified in § 430(h)(3)(A) and § 1.430(h)(3)-1.

SECTION 2. BACKGROUND INFORMATION
1. Statutory background. Section 412 sets forth minimum funding requirements for
defined benefit pension plans. In accordance with § 412(a)(2)(A), § 430 specifies the
minimum funding requirements for a defined benefit plan (other than a multiemployer
plan or a CSEC plan). Section 430(h)(3)(A) sets forth rules regarding the use of
generally applicable mortality tables for purposes of § 430, and § 430(h)(3)(B)
requires the Secretary to make periodic revisions (at least every 10 years) to those
mortality tables. Section 430(h)(3)(C) provides that the Secretary may approve planspecific substitute mortality tables to be used for a plan for a period not to exceed 10
Section 302 of the Employee Retirement Income Security Act of 1974, Pub. L. 93-406, as amended
(ERISA) sets forth funding rules that are parallel to those in § 412 of the Code, and section 303 of ERISA
sets forth additional funding rules for defined benefit plans (other than multiemployer plans) that are
parallel to those in § 430 of the Code. Section 303(h)(3)(C) of ERISA requires the approval of the
Secretary of the Treasury for the use of substitute mortality tables, and this revenue procedure applies for
that purpose.

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years in determining any present value or making any computation under § 430.
Substitute mortality tables meet the requirements for approval if the pension plan
has enough participants and has been maintained for a long enough period of time
to have credible mortality experience, and those tables reflect the actual experience
of the plan and projected trends in general mortality experience. Except as provided
by the Secretary, a plan sponsor may not use substitute mortality tables for any plan
unless substitute mortality tables are established and used for each plan subject to
§ 430 that is maintained by the plan sponsor or a member of the plan sponsor’s
controlled group.
2. Regulations regarding substitute mortality tables. Under § 1.430(h)(3)-2(c)(2),
substitute mortality tables must reflect the actual mortality experience of the pension
plan for which the tables are to be used, and that mortality experience must be
credible. Separate mortality tables must be established for each gender under the
plan and, in general, substitute mortality tables are permitted to be established for a
gender only if the plan has credible mortality experience (including partially credible
mortality experience) with respect to that gender. The regulations provide an option
for determining the credibility of mortality experience using the plan’s combined
mortality experience for both genders (and using that combined experience to
develop separate substitute mortality tables for each gender).
(1) Use of mortality ratios. Under § 1.430(h)(3)-2(c)(3), development of
substitute mortality tables under the regulations requires creation of a base
substitute mortality table (“Substitute Base Table”) with an associated base
year, which is used in conjunction with mortality improvement factors to
construct generational mortality tables. Under § 1.430(h)(3)-2(d), the
Substitute Base Table must be constructed in a multiple-step process based
on (a) a projection of the generally applicable mortality table to the base
year for the Substitute Base Table, and (b) an amounts-weighted mortality
ratio calculated from the experience study for the population. In the case of
a plan with partially credible mortality experience, § 1.430(h)(3)-2(e) requires
the application of a weighting factor based on the credibility of the plan’s
experience.
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(2) Controlled group consistency requirement. The regulations provide certain
exceptions to the general rule under § 430(h)(3)(C)(iv) and § 1.430(h)(3)2(c)(1)(i), under which a plan sponsor may not use substitute mortality
tables for any plan for a plan year unless substitute mortality tables are
established and used for each other plan subject to § 430 that is maintained
by the plan sponsor or a member of the plan sponsor’s controlled group (as
defined in § 1.430(h)(3)-2(c)(1)(i)) for that plan year. Under § 1.430(h)(3)2(c)(1)(ii), the use of substitute mortality tables for one plan is not prohibited
merely because another plan maintained by the plan sponsor (or by a
member of the plan sponsor’s controlled group) may not use substitute
mortality tables because neither the males nor the females under that other
plan have credible mortality information for a plan year. In addition, under §
1.430(h)(3)-2(f), the regulations provide a transition period for newly
affiliated plans.
(3) Treatment of disabled individuals. If separate mortality tables are used for
disabled individuals pursuant to § 430(h)(3)(D), then those individuals are
disregarded for all purposes under this revenue procedure.
(4) Treatment of multiple-employer plans. A multiple-employer plan for which
the proportion of the plan’s funding target attributable to employees and
former employees of the employer and members of the employer’s
controlled group is greater than 50 percent is treated as maintained by that
employer for purposes of the controlled group consistency requirement
pursuant to § 1.430(h)(3)-2(c)(7)(ii). By contrast, any other multipleemployer plan in which the employer or a member of the employer’s
controlled group participates is not treated as maintained by the employer
for purposes of the controlled group consistency requirement and is
disregarded under this revenue procedure.
3. Amendments to regulations relating to substitute mortality tables. TD 10005 includes

amendments to the rules used to construct substitute mortality tables under
§ 1.430(h)(3)-2. Under those amendments, in determining the mortality ratio used to
develop plan-specific substitute mortality tables, certain adjustments to the
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probability of death must be made to the mortality rates from the standard mortality
table. These adjustments, which are specified in § 1.430(h)(3)-2(d)(4)(iii)(B), apply
for 12-month periods beginning in 2020, 2021, or 2022.
4. Revenue Procedure 2017-55. Revenue Procedure 2017-55 provides the procedures
for the approval of substitute mortality tables.

SECTION 3. GENERAL ADMINISTRATIVE PROCEDURES
1. In general. A request for approval to use substitute mortality tables for a plan that
would first apply for a plan year beginning on or after January 1, 2025, must satisfy
the requirements of § 1.430(h)(3)-2 and this revenue procedure. Except as provided
in this revenue procedure, the procedures set forth in Rev. Proc. 2024-4 (or its
successors) apply to a request for approval to use substitute mortality tables.
2. Address and user fee for application. A request for approval to use substitute
mortality tables must be submitted to the address specified in section 31 of Rev.
Proc. 2024-4, 2024-1 IRB 160 (or the corresponding section of its successors).
The user fee required by section 6.02(15) of Rev. Proc. 2024-4 (or the
corresponding section of its successors) must be sent with the request.
3. Necessary procedural documents. A request will not be considered for approval
unless it complies with this section 3.03.
(1) The request (and any subsequently provided additional information) must be
signed by the plan sponsor (“applicant”) or an authorized representative of
the applicant who is described in section 6.02(11)(a), (b), (c), (d) or (e) of
Rev. Proc. 2024-4 (or the corresponding sections of its successors).2 If an
authorized representative signs the request or will appear before the IRS in
connection with the request, a properly signed and dated Form 2848, Power
of Attorney and Declaration of Representative, must be submitted with the

It is recommended that an actuary who is able to answer technical questions about the construction of
the substitute mortality tables be designated as an authorized representative. Not having an actuary
available to discuss these tables with the IRS may cause a delay in the processing of a request for
approval.
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request. An individual is not an authorized representative of the applicant
merely because the individual is the administrator or a trustee of the plan.
(2) The request must include a declaration in the following form: “Under
penalties of perjury, I declare that I have examined this request, or this
modification to the request, including accompanying documents, and, to the
best of my knowledge and belief, the request or the modification includes all
the relevant facts relating to the request, and such facts are true, correct,
and complete.” This declaration must be signed by the applicant (for
example, by an authorized officer of a corporate applicant), in compliance
with section 6.02(14) of Rev. Proc. 2024-4 (or the corresponding section of
its successors). The signature of an individual with a power of attorney will
not satisfy the requirements of this section 3.03(2).
(3) Because a request for approval to use substitute mortality tables constitutes
a request for a ruling, compliance with § 6110 of the Code is required.
Section 601.201 of the Statement of Procedural Rules sets forth the
requirements applicable to requests for rulings and determination letters that
are subject to § 6110. Section 601.201(e) provides specific instructions to
applicants.
The applicant must include with the request either a statement of proposed
deletions and the statutory basis for each proposed deletion, or a statement that no
information other than names, addresses, and taxpayer identifying numbers need
be deleted.
(4) The checklist set forth in Appendix A of this revenue procedure must be
completed, signed, and dated by the applicant or authorized representative,
and included at the front of the request.
4. Optional use of electronic format for certain information. In addition to providing the
submission in written format, an applicant may provide the information required
under sections 7.04 and 7.05 of this revenue procedure and section 10.02 or 10.03
of this revenue procedure, as applicable, in electronic format (such as a spreadsheet
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on a USB drive). An applicant may also include Form 15314 (TE/GE Secure
Messaging Taxpayer Agreement Authorization of Disclosure to Designated Users)
with their application which provides permission by the taxpayer to allow for the
digital exchange of information with the IRS. Providing that information in electronic
format may expedite the IRS review of the applicant’s request.

SECTION 4. TIMING PROVISIONS RELATED TO REQUESTS FOR
APPROVAL TO USE SUBSTITUTE MORTALITY TABLES
1. In general. A request for approval to use substitute mortality tables generally must be
submitted at least 7 months before the first day of the first plan year for which the
substitute mortality tables are to apply. Thus, for example, if the first plan year to which
substitute mortality tables are to apply is the plan year that begins January 1, 2026, then
the deadline for submitting a request for approval to use substitute mortality tables is
June 1, 2025.
2. Incomplete requests. An incomplete request for approval to use substitute mortality
tables will be denied unless the IRS and the applicant mutually agree to extend the 180day period specified under § 430(h)(3)(C)(v)(II). If the request does not include
substantially all of the applicable information specified in sections 5 through 11 of this
revenue procedure, the IRS will ordinarily reject the request without considering the
substance of the request (rather than agree to extend the 180-day period for review of
the request) and refund the user fee.
3. Request for delay for other plans. If other plans subject to § 430 maintained by the
applicant (or members of the applicant’s controlled group) have credible mortality
information and a request for approval to use substitute mortality tables will be made for
those plans in one or more separate applications, the applicant must request that the
180-day review period be extended by 90 days. Upon receiving the request for
extension of the review period, except as provided in section 4.02 of this revenue
procedure, the IRS will agree to that extension and give the applicant 90 days to submit
those additional applications (which must be submitted no later than the deadline that
applies to each such separate request under section 4.01 or 4.04 of this revenue
procedure). The IRS will summarily reject the initial application if it does not include a
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request for a 90-day extension of the 180-day review period, or if any of the additional
applications are not submitted within 90 days after the submission of the initial
application (on the grounds that at least one plan with credible mortality information
maintained by the applicant (or a member of the applicant’s controlled group) would not
be using substitute mortality tables).
Example. Employer E maintains Plans A and B, each of which have credible mortality
information. Plan A’s plan year is the calendar year and Plan B’s plan year runs from
July 1 through June 30. Employer E submits a request for approval to use substitute
mortality tables for Plan A for the 2026 plan year on May 31, 2025 (“Plan A Request”).
To avoid denial of the Plan A Request on the grounds that substitute mortality tables
would not be used for all plans with credible mortality information maintained by the
applicant, Employer E requests that the 180-day review period for the Plan A Request
be extended by 90 days to provide Employer E additional time to submit a separate
request for approval to use substitute mortality tables for Plan B for the 2026 plan year.
The IRS agrees to this extension in accordance with this section 4.03. The IRS will
summarily reject the Plan A Request unless Employer E submits a separate request for
approval to use substitute mortality tables for Plan B no later than August 29, 2025.\
4. Transition rule for submissions for plan years beginning in 2025. Notwithstanding the
generally applicable deadline in section 4.01 of this revenue procedure, a request for
approval to use substitute mortality tables for a plan year beginning in 2025 will be
considered timely if it is submitted on or before October 31, 2024, provided that the
applicant requests a 90-day extension of the 180-day review period. Except as provided
in section 4.02 of this revenue procedure, the IRS will agree to such a request.

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SECTION 5. GENERAL RULES
1. Contents of request. A request for approval to use substitute mortality tables must
include the general information described in this section 5, the plan identification
information described in section 6 of this revenue procedure, the credible mortality
information demonstrations described in section 7 of this revenue procedure, the
population stability demonstrations described in section 8 of this revenue procedure,
the information regarding other plans in the applicant’s controlled group described in
section 9 of this revenue procedure, the Substitute Base Table construction
information described in section 10 of this revenue procedure, and the
demonstrations described in section 11 of this revenue procedure.
2. General standard for approval. The IRS will approve a request for approval to use
substitute mortality tables that meet the requirements of § 1.430(h)(3)-2 and this
revenue procedure unless the IRS determines that the Substitute Base Table does
not sufficiently reflect the mortality experience of the applicable plan population.
3. Proposed period of use. A separate request must be made with respect to each plan
(“Plan”), or group of plans that are aggregated under § 1.430(h)(3)-2(c)(5)
(“Aggregated Group”), for which approval to use substitute mortality tables is
requested. The request must state the first day of the first plan year for which the
substitute mortality tables are to be applicable (“Requested Effective Plan Year”) and
must state the term of years (not more than 10) for which the tables would be used.
4. Description of populations. The request must include a description of the populations
within the Plan (or the Aggregated Group) covered by the request for approval to
use substitute mortality tables and a description of the populations, if any, for which
the generally applicable mortality tables will be used.
For example, if approval to use substitute mortality tables is requested for
nondisabled female individuals (but no other individuals) under a plan for which the
mortality tables set forth in Rev. Rul. 96-7, 1996-1 CB 59, are used for disabled
individuals pursuant to § 430(h)(3)(D), then the population covered by the request
for approval to use substitute mortality tables would be described as “Nondisabled

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Females” and the population for whom the generally applicable mortality tables will
be used would be described as “Nondisabled Males.”
Similarly, if approval to use substitute mortality tables is requested for male
annuitants (but not male nonannuitants) and for females on a combined
annuitant/nonannuitant basis, in each case including disabled individuals, then the
populations covered by the request for approval to use substitute mortality tables
would be described as “Male Annuitants” and “Females,” and the population for
whom the generally applicable mortality tables will be used would be described as
“Male Nonannuitants.”

SECTION 6. IDENTIFICATION OF PLANS
1. Information for plan for which approval to use substitute mortality tables is
requested. The following plan information must be provided for the Plan (or for each
plan within the Aggregated Group) for which approval to use substitute mortality
tables is requested:
(1) Plan name;
(2) Plan number;
(3) Plan year (calendar year, or if a fiscal year, the first and last day of the plan
year);
(4) Employer identification number;
(5) Date of plan establishment; and
(6) Copies of the actuarial valuation reports for each plan year that begins or
ends during the Experience Study Period as defined in section 7.01 of this
revenue procedure.
2. Plans for which substitute mortality tables are not intended to be used. The following
information must be provided for each plan that is subject to § 430 covering
employees of the applicant, or a member of the applicant’s controlled group, for
which substitute mortality tables are not intended to be used:
(1) Plan name;
(2) Plan number;
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(3) Plan year (calendar year, or if a fiscal year, the first and last day of the plan
year);
(4) Employer identification number;
(5) Date of plan establishment;
(6) If the plan is a newly-affiliated plan under § 1.430(h)(3)-2(f)(2), the date of
the merger, acquisition, or similar transaction described in § 1.410(b)-2(f),
and the last day of the transition period described in § 1.430(h)(3)-2(f)(3);
and
(7) If the applicant or a member of the applicant’s controlled group is an
employer whose employees participate in a multiple-employer plan, whether
the portion of the multiple-employer plan’s funding target attributable to
employees and former employees of the applicant and the members of the
applicant’s controlled group is less than or equal to 50 percent (so that the
multiple-employer plan is not treated as being maintained by the applicant or
a member of the applicant’s controlled group under § 1.430(h)(3)-2(c)(7)(ii)).
3. Other plans for which substitute mortality tables are being used or are intended to be
used. The following information must be provided for each plan that is subject to
§ 430 covering employees of the applicant, or a member of the applicant’s controlled
group (including a multiple-employer plan that is treated as maintained by the
applicant or a member of the applicant’s controlled group pursuant to § 1.430(h)(3)2(c)(7)(ii)), for which substitute mortality tables are being used or for which a request
for approval to use substitute mortality tables has been submitted or will be
submitted:
(1) Plan name;
(2) Plan number;
(3) Plan year (calendar year, or if a fiscal year, the first and last day of the plan
year);
(4) Employer identification number;
(5) Date of plan establishment;

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(6) If the applicant has received previous approval to use substitute mortality
tables for that plan, the date of that approval;
(7) If the applicant has requested approval to use substitute mortality tables for
that plan (but not yet received approval), the date of that request; and
(8) If the applicant has not yet requested approval to use substitute mortality
tables for that plan, the expected date of the submission.
4. Special rule for multiple-employer plans. If the applicant is the plan administrator of a
multiple-employer plan (who is treated as the plan sponsor under § 1.430(h)(3)2(c)(7)(i)), the request for approval to use substitute mortality tables must include
either:
(1) A statement that none of the employers whose employees participate in the
plan are treated as maintaining the plan under § 1.430(h)(3)-2(c)(7)(ii); or
(2) If one or more of the participating employers is treated as maintaining the
plan under § 1.430(h)(3)-2(c)(7)(ii), the information specified in section 6.02
and 6.03 of this revenue procedure, as applicable, treating each such
employer as the applicant.
5. Spun-off plans. The following additional information must be provided with respect to
each plan that is subject to § 430 and is maintained by the applicant or a member of
the applicant’s controlled group, that was spun off from another plan (“original plan”)
maintained by the applicant or a member of the applicant’s controlled group within
the 5-year period preceding the date of the request:
(1) The plan name and the plan number of the spun-off plan, and the plan name
and number of the original plan;
(2) The employer identification number of the employer maintaining the spun-off
plan and the employer identification number of the employer maintaining the
original plan;
(3) The date of the spinoff;
(4) The approximate number of individuals covered by the spun-off plan as of
the date of the spinoff and the approximate number of individuals covered
by the original plan immediately before the spinoff; and
(5) The reason for the spinoff.
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SECTION 7. DEMONSTRATIONS OF CREDIBLE MORTALITY INFORMATION
1. Experience Study Period. The applicant must identify the period of time covered by
the mortality experience study (“Experience Study Period”) used to develop the
Substitute Base Table(s) and the base year for the Substitute Base Table(s). See
§ 1.430(h)(3)-2(d)(2) and (f)(4) (regarding the selection of an experience study
period) and § 1.430(h)(3)-2(c)(3)(ii) (regarding identification of the base year).
2. Full credibility threshold. The applicant must identify the full credibility threshold in
§ 1.430(h)(3)-2(d)(3) and the number of actual deaths in the Experience Study
Period.
3. Optional rules.
(1) Simplified rule. The applicant must identify whether it used the simplified rule
under which the determination of whether there is credible mortality
information for a gender is made by only taking into account individuals who
are at least age 50 and less than age 100. See § 1.430(h)(3)-2(c)(2)(ii)(B).
(2) Combined genders rule. The applicant must identify whether it used the rule
under which a single mortality ratio is developed and applied for both
genders to construct Substitute Base Tables for the Plan (or Aggregated
Group). See § 1.430(h)(3)-2(d)(6).
4. Required information. The information required in section 7.04(1)-(12) of this
revenue procedure must be provided in tabular form for all individuals within each
population for whom separate approval to use substitute mortality tables is
requested, for all ages between 18 and 100 (unless the applicant is using the
simplified rule as provided in section 7.03(1) of this revenue procedure, in which
case, only those individuals who are at least age 50 and less than age 100 are
considered). This information must be provided separately for each 12-month period
in the Experience Study Period and also as an aggregate amount for all 12-month
periods in the Experience Study Period.
(1) The total number of individuals at that age at the beginning of the 12-month
period, excluding individuals who left the population during the 12-month
period for reasons other than death.
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(2) The total number of individuals at that age at the beginning of the 12-month
period who left the population for reasons other than death.
(3) The total number of individuals at that age at the beginning of the 12-month
period who died during the 12-month period.
(4) The number of expected deaths for individuals at that age determined by
multiplying the mortality rate from the standard mortality table described in
section 7.05(1) of this revenue procedure by the total of the individuals
determined in section 7.04(1) and (2) of this revenue procedure, adjusted for
exposure periods of less than 12 months.
(5) The sum of the benefit amounts described in § 1.430(h)(3)-2(d)(2)(iii) for all
individuals at that age at the beginning of the 12-month period, excluding
individuals who left the population during the 12-month period for reasons
other than death.
(6) The sum of the benefit amounts described in § 1.430(h)(3)-2(d)(2)(iii) for
individuals at that age who left the population during the 12-month period for
reasons other than death.
(7) The sum of the benefit amounts described in § 1.430(h)(3)-2(d)(2)(iii) for
individuals at that age who left the population during the 12-month period on
account of death.
(8) The amount determined by multiplying the mortality rate for that age from
the standard mortality table described in section 7.05(1) of this revenue
procedure, by the total of the amounts determined in section 7.04(5) and (6)
of this revenue procedure, adjusted for exposure periods of less than 12
months.
(9) The amount determined under section 7.04(8) of this revenue procedure,
except that, if the 12-month period in the experience study period begins in
2020, 2021, or 2022, then the mortality rate must be from the adjusted
standard mortality table in section 7.05(2) of this revenue procedure.
(10) The sum of the squares of the benefit amounts described in § 1.430(h)(3)2(d)(2)(iii) for all individuals at that age at the beginning of the 12-month

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period excluding individuals who left the population during the 12-month
period for reasons other than death.
(11) The sum of the squares of the benefit amounts described in § 1.430(h)(3)2(d)(2)(iii) for individuals at that age who left the population during the 12month period for reasons other than death.
(12) The amount determined by multiplying the mortality rate from the standard
mortality table described in section 7.05(1) of this revenue procedure by the
total of the amounts determined in section 7.04(10) and (11) of this revenue
procedure, adjusted for exposure periods of less than 12 months.
5. Standard mortality table.
(1) The request must include the standard mortality table for the base year for
the Substitute Base Table, determined pursuant to § 1.430(h)(3)-2(d)(4)(iii).
(2) If a 12-month period in the experience study period begins in 2020, 2021, or

2022, then the request must also include the standard mortality table for the
calendar year in which the 12-month period begins reflecting the adjustment
provided for in § 1.430(h)(3)-2(d)(4)(iii)(B) for the 12-month period.
6. Adjustment for exposure periods of less than 12 months. The request must include a
description of the method or methods used to make adjustments for individuals who
left the population for reasons other than death to reflect exposure periods of less
than 12 months.
7. Adjustments to make experience study predictive of future mortality experience in
light of changes to the plan population. The request must include a description of
any method used to adjust the experience study data to reflect changes in the
population during the Experience Study Period. For example, if an annuity purchase,
lump sum window or other risk transfer activity occurred during the experience
study, the request should include a description of how those populations were
treated in the study.
8. Other data adjustments. The request must include a description of any other method
used to adjust experience study data.
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9. Other relevant information. The request should also note if any future risk transfer
activity is anticipated, and, if so, a description of how that would affect the
population.

SECTION 8. DEMONSTRATION OF POPULATION STABILITY
1. Required comparison of population count. The following information must be
provided in tabular form for each population within the Plan (or Aggregated Group)
for which approval to use substitute mortality tables is requested, aggregating all
plans that have the same plan year:
(1) The average number of individuals within the population during the
Experience Study Period; and
(2) The number of individuals within the population as of the last day of the plan
year immediately preceding the plan year during which approval to use
substitute mortality tables is requested.
2. Additional requirement for significant change in participant count. If the number of
individuals described in section 8.01(2) of this revenue procedure is less than 80
percent or more than 120 percent of the number of individuals described in section
8.01(1) of this revenue procedure, then the request must provide information and
analysis that shows that the mortality experience during the Experience Study
Period (taking into account any adjustments described in section 7.07 or 7.08 of this
revenue procedure) is accurately predictive of the future mortality of the population.

SECTION 9. INFORMATION REGARDING OTHER PLANS IN THE
APPLICANT’S CONTROLLED GROUP
1. General rule. Under § 1.430(h)(3)-2(e), a population lacks credible mortality
information if the number of deaths during the experience study is less than 100. For
all plans maintained by the applicant or a member of the applicant’s controlled group
(other than a plan for which approval to use substitute mortality tables is requested
or used for all populations or a newly-affiliated plan with respect to which the
transition period has not ended before the first day of the Requested Effective Plan
Year), the applicant must identify the following information for any population for
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which there is a lack of credible mortality information (such that substitute mortality
tables may not be used for that population):
(1) The period of time used to demonstrate a lack of credible mortality
information (“Demonstration Period”), and
(2) The number of deaths during that period.
2. Alternative demonstrations of lack of credible mortality information. In lieu of the
information described in section 9.01(2) of this revenue procedure, a lack of credible
mortality information may be demonstrated by providing alternative information that
demonstrates to the satisfaction of the Commissioner that the number of male
and/or female deaths did not exceed 100 during the Demonstration Period. For
example, a year-by-year reconciliation of the participant population (such as might
be shown in an actuarial valuation report) might be submitted showing that the total
number of participants leaving the plan during the Demonstration Period is less than
100, as this would demonstrate that the number of male and female deaths must
also be less than 100 during that period. Similarly, if the total number of participants
in the Plan does not exceed 100 for any year during the Demonstration Period, the
year-by-year number of participants in the Plan during such period might be
submitted in lieu of the information described in section 9.01(2) of this revenue
procedure, as this would show that the number of male and female deaths must also
be less than 100 during that period.

SECTION 10. SUBSTITUTE BASE TABLE CONSTRUCTION
1. Mortality ratio. For each population for which approval to use substitute mortality
tables is requested, the applicant’s request must include the mortality ratio
determined pursuant to § 1.430(h)(3)-2(d)(4)(ii).
2. Substitute Base Table for population with full credibility. With respect to a population
with mortality experience that is fully credible, the applicant’s request must contain
the Substitute Base Table constructed pursuant to § 1.430(h)(3)-2(d)(4).
3. Substitute Base Table for population with partial credibility. With respect to a
population with mortality experience that is only partially credible, the applicant’s
request must include:
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(1) A base substitute mortality table constructed using the rules in § 1.430(h)(3)2(d)(4) as if the population had mortality experience that is fully credible;
(2) The partial credibility weighting factor for the population determined
pursuant to § 1.430(h)(3)-2(e)(2); and
(3) The Substitute Base Table constructed using the rules in § 1.430(h)(3)2(e)(1).

SECTION 11. DEMONSTRATIONS WITH RESPECT TO BASE TABLES
1. Funding target comparison. For the Plan (or each plan within the Aggregated Group)

for which approval to use substitute mortality tables is requested, the applicant must
provide a comparison of: (1) the plan’s funding target (determined without regard to
at-risk assumptions under § 430(i)) calculated using the generally applicable
generational mortality tables, and (2) the amount that funding target would have
been if the substitute mortality tables had been used to determine the funding target,
holding all other assumptions constant.
These amounts must be determined as of the valuation date for a plan year ending
no earlier than one year and one day before the first day of the Requested Effective
Plan Year, using the data and interest rates that were used for that valuation. The
amounts must be provided in total and separately for: (1) active participants, (2)
terminated vested participants, and (3) retired participants and beneficiaries
receiving payment.
2. Generational mortality tables. For each population for which approval to use

substitute mortality tables is requested, the applicant’s request must include sample
generational mortality tables, as of the Requested Effective Plan Year, for individuals
whose years of birth are 1950, 1970, and 1990, respectively, constructed from the
Substitute Base Table using the rules of § 1.430(h)(3)-2(c)(3).
3. Annuity factors. For each population for which approval to use substitute mortality

tables is requested, the applicant’s request must include the following annuity factors
based on the substitute mortality table for an individual whose year of birth is 20

17

years before the base year for the Substitute Base Table, determined using the
same interest rates as those used under section 11.01 of this revenue procedure.
(1) For a Substitute Base Table that is not an annuitant Substitute Base Table,

deferred to age 55 factors at quinquennial ages from 20 to 50.
(2) For a Substitute Base Table that is not a nonannuitant Substitute Base
Table, immediate annuity factors at quinquennial ages from 50 to 90.

SECTION 12. EARLY TERMINATION OF PREVIOUSLY APPROVED
SUBSTITUTE MORTALITY TABLES IN CONJUCTION WITH THE
REPLACEMENT OF GENERALLY APPLICABLE MORTALITY TABLES
1. Regulatory requirement to terminate use of previously approved substitute mortality
tables. Section 1.430(h)(3)-2(c)(6)(ii)(E) provides that guidance published in the
Internal Revenue Bulletin will specify the date by which the use of a plan’s substitute
mortality tables must be terminated in conjunction with the replacement of the
generally applicable mortality tables specified in § 430(h)(3)(A) and § 1.430(h)(3)-1.
The generally applicable mortality tables were replaced for plan years beginning on
or after January 1, 2024, in TD 9983, 88 FR 72357.
2. Plans with significant changes in coverage. If a substitute mortality table was first
approved for use for a plan year that began before January 1, 2025, and the number
of individuals covered by the substitute mortality table is less than 80 percent or
more than 120 percent of the average number of individuals in that population over
the 12-month periods covered by the experience study, then the substitute mortality
table may not be used for a plan year beginning on or after January 1, 2026. This
termination, which is pursuant to § 1.430(h)(3)-2(c)(6)(ii)(E), applies without regard
to whether the actuary makes the certification described in § 1.430(h)(3)2(c)(6)(iii)(A).
3. Other plans. If a plan is not described in section 12.02 of this revenue procedure,

there is no early termination of the use of previously approved substitute mortality
tables merely because of the replacement of the generally applicable mortality tables
specified in § 430(h)(3)(A) and § 1.430(h)(3)-1 described in section 12.01 of this
revenue procedure.
18

SECTION 13. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2017-55 is superseded. Sections 24.01(11), 26.02(4), and 31.01(1) of Rev.
Proc. 2024-4 are modified to refer to this revenue procedure in lieu of Rev. Proc. 201755.

SECTION 14. EFFECTIVE DATE
This revenue procedure is effective for all requests for approval to use plan-specific
substitute mortality tables in accordance with § 430(h)(3)(C) of the Code for which the
Requested Effective Plan Year begins on or after January 1, 2025.

SECTION 15. PAPERWORK REDUCTION ACT
The collection of information included in this revenue procedure has been reviewed and
approved by the Office of Management and Budget in accordance with the Paperwork
Reduction Act (44 U.S.C. section 3507) under control number 1545-2073.
An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless the collection of information displays a valid OMB
control number.
The collection of information in this revenue procedure is in sections 3 through 11 of this
revenue procedure. This collection of information is required to provide sufficient
information to enable the IRS to evaluate, process, and rule on the request for approval
to use substitute mortality tables. This information will be used to make determinations
under § 430(h)(3) of the Code. The likely respondents are businesses or other for-profit
institutions and nonprofit institutions.
The estimated total annual reporting/recordkeeping burden is 4,000 hours.
The estimated burden per respondent/recordkeeper varies from 167 to 900 hours,
depending on individual circumstances, with an estimated average burden of 267 hours.
The estimated average number of expected respondents/recordkeepers is 15 per year.
19

The estimated frequency of responses is once every 10 years.
Books or records relating to a collection of information must be retained as long as their
contents may become material in the administration of any internal revenue law.
Generally, tax returns and tax return information are confidential, as required by 26
U.S.C. section 6103.

DRAFTING INFORMATION
The principal author of this revenue procedure is Arslan Malik of the Office of the
Associate Chief Counsel, Employee Benefits, Exempt Organizations, and Employment
Taxes (CC:EEE). For further information regarding the submission of a request for
approval to use substitute mortality tables, please contact Christopher Denning at (202)
317-5755.

20

Appendix A
REQUEST FOR APPROVAL TO USE SUBSTITUE MORTALITY TABLES CHECKLIST
Instructions
You must include a completed copy of this checklist with your submission. Answer each
question in the checklist by circling Yes, No, or N/A; explanations must be provided for
“No” or “N/A” responses. If a completed checklist is not included, or if explanations are
not provided for “No” and “N/A” responses, then your submission will be considered
incomplete for purposes of section 4.02 of this revenue procedure.
Sign and date the checklist (as plan sponsor or authorized representative) and
place it on top of your request.
Response

Item
number

Description of item

Yes
No
N/A

1.

Have you included the user fee required under Rev. Proc. 2024-4 or its
successors? (See section 3.02)

Yes
No
N/A

2.

If you are designating an authorized representative, have you included
a properly executed Form 2848 (Power of Attorney)? (See
section 3.03(1))

Yes
No
N/A

3.

Have you satisfied all the requirements of Rev. Proc. 2024-4 or its
successors (especially concerning original signatures, penalties of
perjury statement, and statement of proposed deletions)? (See section
3.03(2) and (3))

Yes
No
N/A

4.

If any separate application for approval to use substitute mortality tables
will be made for other plans maintained within the applicant’s controlled
group, have you requested that the 180-day review period be
extended? (See section 4.03)

Yes
No
N/A

5.

For a request for approval to use substitute mortality tables submitted
for a plan year beginning during 2025 less than 7 months before the
first day of the plan year, and no later than October 31, 2024, have you
included a request for a 90-day extension of the 180-day review period?
(See section 4.04)

Yes
No
N/A

6.

Have you identified the first day of the first plan year for which approval
to use substitute mortality tables is requested and the number of years
for which the substitute mortality tables would be used? (See section
5.03)

Yes
No
N/A

7.

Have you included a description of the populations for which approval to
use substitute mortality tables is requested? (See section 5.04)

21

Page number
in
application

Yes
No
N/A

8.

Have you included the identification information required under section
6.01 for the Plan (or for each plan in the Aggregated Group) for which
approval to use substitute mortality tables is requested?

Yes
No
N/A

9.

Have you provided the information required for each plan for which
substitute mortality tables are not intended to be used? (See section
6.02)

Yes
No
N/A
Yes
No
N/A

10.

Have you provided the information required for each other plan for
which substitute mortality tables are being used or are intended to be
used? (See section 6.03)
If the applicant is a plan sponsor of a multiple-employer plan, have you
provided either (1) a statement that none of the employers whose
employees participate in the plan are treated as maintaining the plan
under § 1.430(h)(3)-2(c)(7)(ii); or (2) if one or more of the participating
employers is treated as maintaining the plan under § 1.430(h)(3)2(c)(7)(ii), the information specified in section 6.02 and 6.03 of this
revenue procedure, as applicable, treating each such employer as the
applicant? (See section 6.04)

Yes
No
N/A

12.

Have you provided the required information for any plans that were
spun off from another plan maintained by the applicant or a member of
the applicant’s controlled group within the past 5 years? (See section
6.05)

Yes
No
N/A

13.

Have you identified the Experience Study Period and the base year for
the Substitute Base Tables? (See section 7.01)

Yes
No
N/A

14.

Have you provided the full credibility threshold and the number of actual
deaths during the Experience Study Period for each population within
the Plan (or Aggregated Group) for which approval to use substitute
mortality tables is requested (see section 7.02)?

Yes
No
N/A

15.

Have you identified whether the applicant used either or both of the
optional rules specified in section 7.03?

Yes
No
N/A

16.

Have you included a table showing the required information for each
applicable population within the Plan (or Aggregated Group), for each
12-month period of the Experience Study Period and also as an
aggregate amount for all 12-month periods in the Experience Study
Period? (See section 7.04)

Yes
No
N/A

17.

Have you included the relevant standard mortality tables (which is the
base mortality table under § 1.430(h)(3)-1(d) projected with mortality
improvement to the base year for the Substitute Base Tables)? (See
section 7.05(1))

Yes
No
N/A

18.

If any 12-month period in the experience study period begins in 2020,
2021, or 2022, have you included the standard mortality table for the
calendar year in which the 12-month period begins reflecting the
adjustment provided for in § 1.430(h)(3)-2(d)(4)(iii)(B) for the 12-month
period? (See section 7.05(2))

Yes
No
N/A

19.

Have you included a description of the methods used to reflect
exposure periods of less than 12 months? (See section 7.06)

11.

22

Yes
No
N/A

20.

Have you included a description of any methods used to adjust the
experience study data? (See section 7.07 and 7.08)

Yes
No
N/A
Yes
No
N/A

21.

Have you included any other relevant information? (See section 7.09)

22.

Have you included a table showing the average number of individuals
during the Experience Study Period and the number of individuals
within the population as of the last day of the plan year immediately
preceding the date of this application, for each population within the
Plan (or Aggregated Group) for which the approval to use substitute
mortality tables is requested? (See section 8.01)

Yes
No
N/A

23.

Have you provided information and analysis required if the population
has had a significant change in the number of participants, as described
in section 8.02?

Yes
No
N/A

24.

Have you identified the Demonstration Period for all plans maintained
by the applicant or a member of the applicant’s controlled group other
than a plan for which approval to use substitute mortality tables is
requested or used for all populations or a newly-affiliated plan with
respect to which the transition period has not ended before the first day
of the Requested Effective Plan Year? (See section 9.01(1))

Yes
No
N/A

25.

Have you identified the number of deaths during the Demonstration
Period for all plans maintained by the applicant or a member of the
applicant’s controlled group (other than a plan for which approval to use
substitute mortality tables is requested or used for all populations or a
newly affiliated plan with respect to which the transition period has not
ended before the first day of the Requested Effective Plan Year) for any
population for which there is a lack of credible mortality information
(such that substitute mortality tables may not be used for that
population)? (See section 9.01(2))
Alternatively, have you provided other information for a population that
demonstrates that the number of deaths during the Demonstration
Period would not exceed 100? (See section 9.02)

Yes
No
N/A

26.

Have you provided the mortality ratio for each population for which
approval to use substitute mortality tables is requested? (See section
10.01)

Yes
No
N/A

27.

For each population within the Plan (or Aggregated Group) whose
mortality experience has full credibility, have you provided a full copy of
the Substitute Base Table? (See section 10.02)

Yes
No
N/A

28.

For each population within the Plan (or Aggregated Group) for which
approval to use substitute mortality tables is requested but for which
mortality experience does not have full credibility, have you provided a
full copy of the base substitute mortality table constructed as if the
population’s mortality information had full credibility, the partial
credibility weighting factor, and a full copy of the Substitute Base Table
reflecting credibility adjustments? (See section 10.03)

Yes
No
N/A

29.

Have you included a comparison of hypothetical funding targets
determined using generally applicable mortality tables and the proposed
substitute mortality tables? (See section 11.01)

Yes
No
N/A

30.

Have you included the required sample generational mortality tables as
of the Requested Effective Plan Year, developed from each Substitute
Base Table? (See section 11.02)

23

Yes
No
N/A

31.

Have you included annuity factors for each Substitute Base Table
based on the substitute mortality table for an individual whose year of
birth is 20 years before the base year for the Substitute Base Table?
(See section 11.03)

Signature _______________________

Date

__________

Title or Authority _____________________________________
Typed or printed name of person signing checklist ____________________________________

24