Full opinion text
Substituted Ruling on Plaintiffs’ Motion for Partial Summary Judgment [Doc. # 77]; SBC/SNET Defendants’ Motion for Judgment on the Pleadings or in the Alternative for Summary Judgment [Doc. # 73]; Motion for Summary Judgment by Defendants Cingular Wireless LLC, Cin-gular Wireless Bargained Pension Plan and Cingular Wireless Bargained Pension Plan Trust [Doc. #80] ARTERTON, District Judge. At issue in this case is the proper interpretation of the plan amendments in the pension plans of defendant SBC Communications Inc.’s (“SBC”) subsidiary, the Southern New England Telephone Company (“SBC/SNET”) and defendant Cingular Wireless LLC (“Cingular”). For the reasons discussed below, plaintiffs’ motion for partial summary judgment is GRANTED in part and DENIED in part. The SBC/ SNET defendant’s motion is GRANTED. Cingular’s motion is DENIED. I. Background Plaintiffs are current and former employees of SBC/SNET and Cingular, who claim they are entitled' to certain cash balance pension benefits under the terms of their pension plans. All plaintiffs began their employment with SNET, and became employees of SBC in 1998 upon its purchase of SNET. In 2001, SBC transferred some plaintiffs to Cingular, which is a joint venture between SBC and BellSouth Corporation. Since 1995, SBC/SNET has had in place a so-called “cash balance” pension plan for its employees, in which pension benefits are reflected in a hypothetical account balance (“Cash Balance Plan Account” or “CBPA”) for each employee that increases each year as the employer adds service and interest credits. Although such plans resemble defined contribution plans in form, they are in fact defined benefit plans, and are governed by ERISA’s defined benefit plan rules. Thus, for example, the SBC/SNET plan defines “accrued benefit” not as the balance of an individual’s account, but rather as follows: A Participant’s CBPA [Cash Balance Plan Account] is a hypothetical account. A Participant’s actual accrued benefit under the Plan is a monthly benefit, commencing at his Normal Retirement Age, which is the actuarial equivalent of the participant’s CBPA. Effective beginning September 18, 1998, such accrued benefit shall be computed by adding interest thereon projected to the Normal Retirement Age. The rate of interest shall be the Negotiated Interest Crediting Rate. Converting such amount into a lifetime pension shall be determined by multiplying the Participant’s projected CBPA by the appropriate factor in Appendix A using the later of the Participant’s age at Normal Retirement Age or the Participant’s actual age, and dividing the resulting amount by 12. SBC/SNET Plan ¶ 5.2. . In 2001, SBC/SNET and its union, Local 1298 of the Communications Workers of America (“CWA”), entered into negotiations over the terms of the cash balance pension plan for employees who chose to retire early. Many union members had been dissatisfied with the cash balance plan, and the union’s aim during the 2001 pension negotiations was to “try and make up for the losses of the detrimental effects of the cash balance conversion as it related to the members who stayed with SNET.” Declaration of Glenn P. Kalata, Sr. [Doc. # 123, Ex. 44] at ¶ 3. The Memorandum of Understanding, signed on February 6, 2001, provided as follows: For any regular bargained-for' employee who retires during the period July 1, 2001 through December 31, 2004 ■ and who (a) has completed 30 or more years of Benefits NCS [Net Credited Service], or (b) is age 55 or older with 20 or more years of Benefits NCS, and who is under age 65 when the pension distribution is effective, the monthly pension attributable to the CBP [Cash Balance Pension] account will be determined as though the participant was age 65. .If the employee is under age 65 and elects distribution of the CBP benefit as a single life annuity, the monthly pension benefit will be equal to the CBP account divided by 119.04. Memorandum of Understanding (“MOU”) [Doc. # 123, Ex. 32]. In 2001, approximately 64 SBC/SNET employees sought to retire early, and an outside actuary, Mellon HR Solutions, calculated their pension benefits by projecting the value of their cash balance accounts forward with interest credits to age 65, then applying the age 65 annuity factor of 119.04. These employees retired in reliance on the actuary’s calculation, but before they received their retirement benefits, SBC rejected Mellon’s benefits calculation, asserting that it overstated the pension benefits to which the employees were due under the 2001 MOU. In SBC/ SNET’s view, the MOU did not require the cash balance account to be projected forward with interest credits to age 65, only that the amount in the cash balance account would be multiplied by 119.04 (the age 65 annuity factor). The 2001 retirees ultimately settled with SNET, and the 2001 retirees who elected to collect their retirement benefits as an annuity received 60% of the additional sums they would have been entitled to under the benefit calculations furnished by Mellon. SNET settled with Mellon for half of that extra cost. The SBC/SNET Plan After settling with the 2001 retirees, SBC amended the SNET Pension Plan on May 17, 2002. Under the SBC/SNET Plan, employees have the option of receiving their pension benefit as either a lump sum distribution or a lifetime annuity. As amended to reflect the Memorandum of Understanding, the applicable provisions of the SBC/SNET plan include the following: 7.3 Cash Balance Plan Account Distribution Options Employees who terminate employment on or after March 31, 1995, for any reason and who are eligible for a service pension or a service disability pension or a deferred vested pension will be eligible to elect to receive a distribution of the vested CBPA, unless the amount to which they are entitled under the Early Out Offer or the Enhanced Pension benefit is greater, in which case the CBPA would not be payable.... (a) Normal Form of Payment The normal form of payment of the vested CBPA shall be a joint and surviv- or annuity for a married Employee, and a single life annuity for an unmarried Employee. (b) Amount if Payable as a Single Life Annuity The monthly payment amount of the CBPA, if payable as a single life annuity, shall be determined by multiplying the Employee’s accrued monthly CBPA benefit at his Normal Retirement Age by the applicable factor in Table 6.7 in Appendix A using the Employee’s age at the time of commencement of the pension benefit. The Employee’s accrued monthly benefit is determined by multiplying the Employee’s CBPA by the applicable factor in Table 6.6 in Appendix A using the Employee’s age at the time of the commencement of the pension benefit. Effective January 1, 2000, the Employee’s accrued monthly CBPA benefit is determined by: 1. projecting the Employee’s CBPA from termination of employment to Normal Retirement Age using the Negotiated Interest Crediting Rate, and 2. dividing the amount from (1) immediately above by the applicable factor in table 6.1 in Appendix A using the Employee’s age at Normal Retirement Age, and 3.multiplying the amount from (2) immediately above by the applicable factor in Table 6.7 in Appendix A using the Employee’s age at the time of commencement of the pension benefit. For any Regular Employee who (a) retires during the period July 1, 2001, through December 31, 2004, (b) either has 30 or more Years of Service or is age 55 or older with 20 or more years of Service, and (c) is under age 65 when the pension distribution is effective, the monthly pension attributable to the CBP account will be determined as though the Participant was age 65. If the Employee is under age 65 and elects distribution of the CBP benefit as a single life annuity, the monthly pension will be equal to the CBP account divided by 119.04. : (e) Lump Sum Distribution Options for Regular Employees At the time of termination of employment, an Employee (other than a Temporary Employee or a Job Bank Employee) may elect to receive 25%, 50% or 100% of the vested CBPA to be payable in a lump sum distribution. Availability of lump sum distribution options after election to defer receipt of pension benefits upon retirement or termination shall be determined in accordance with the following provisions: (1) The 25% or 50% lump sum distribution options shall not be available to any Employee who elects to defer receipt of pension benefits upon his retirement or other termination of employment. (2) A Participant who terminated employment prior to September 18, 1998, and who elects to commence receipt of benefits before January 1, 2000, shall not be permitted to elect a 100% lump sum. (3) A Participant who terminated employment prior to September 18, 1998, and who has not commenced receipt of benefits as of December 31, 1999, shall be permitted to elect a 100% lump sum effective January 1, 2000. The lump sum distribution of an Employee’s CBPA as of the commencement date shall be the greater of: (i) the Employee’s CBPA; and (ii) the present value of the Employee’s accrued benefit as described in 5.2 For any Employee who terminates Employment on or after October 21, 1997, the present value of the Employee’s accrued benefit calculated pursuant to this paragraph (ii) shall be the present value of the annuity calculated as of Normal Retirement Age (or current age, if later) using the Applicable Interest Rate and the Applicable Mortality Table. The SBC/SNET employees did not receive a copy of the plan, and instead received a Summary Plan Description (“SPD”). The SPD summarized the early retirement benefit as follows: Enhanced CBPA Annuity. Effective July 1, 2001, notwithstanding any other provision of this Plan, any regular bargaining unit employee who: • Retires during the period beginning July 1, 2001, and ending Dec. 31, 2004, • Is under the age of 65 when the pension distribution is effective and either(a) has completed 30 or more years of Credited Service or (b) is the age of 55 or older with 20 or more years of Credited Service, and • Elects an annuity form of payment will receive the greater of: • The monthly pension attributable to the CBPA determined as though the participant was the age of 65, or • The monthly pension attributable to the CBPA determined under the otherwise applicable provisions of the Plan. SBC Summary Plan Description, SNET Pension Plan [Doc. # , Ex. 35] at 29. Cingular Plan Although Cingular was not a party to the collective bargaining that led to the MOU, Cingular assumed the obligations of SBC/SNET under the collectively bargained cash balance plan for several employees who transferred employment from SBC/SNET to Cingular in 2001. SBC/ SNET transferred assets and liabilities to Cingular’s Plan to provide for each transferring employee’s pension benefit. Cin-gular states that it sought to incorporate SBC/SNET’s benefit provisions for the transferred employees, and used Mellon as a resource in establishing its pension systems for those transferred employees. See [Doc. #82, Vol. VII] at CIN 2140. Neither Mellon nor SBC/SNET notified Cingular of the disputed early retirement benefit calculations resulting in the settlement with the 2001 SBC/SNET retirees. The Cingular Plan issued on November 1, 2001 provides as follows: 3.1 Determination of Accrued Benefit. (a) General Rule. Except as provided in subsections (b) or (c) hereof, a Participant’s Accrued Benefit as of any Date of Determination is a monthly Life Annuity benefit, commencing at his Normal Retirement Age, that is equal to (1) or (2) as follows: (1) Before Normal Retirement Age. For a Date of Determination prior to the date on which the Participant attains Normal Retirement Age, the quotient of (i) the amount determined by beginning with such participant’s Cash Balance Account as of such Date of Determination, and projecting such account balance forward to his Normal Retirement Age by adding Interest Credits (using the Interest Crediting Rate in effect on the Date of Determination), but not Service Credits, to such Cash Balance Account for the period ending on the date he attains Normal Retirement Age; divided by (ii) the product of (A) 9.92; multiplied by (B) 12 .... (b) Transferred Employees. Notwithstanding subsection (a) hereof, the Accrued Benefit of a Transferred Employee as of any Date of Determination shall never be less than the sum of his Frozen Core Pension Benefit, plus (1) or (2) as follows: (1) Before Normal Retirement Age. For a Date of Determination prior to the date on which the Participant attains Normal Retirement Age, the quotient of (I) his Frozen Enhanced Cash Balance Account; divided by (ii) the product of (A) 9.92; multiplied by (B) 12 .... (c) Transferred Employees Terminating Prior to January 1, 2005. Notwithstanding subsections (a) or (b) hereof, the Accrued Benefit of a Transferred Employee who terminates employment with all Affiliates prior to January 1, 2005, shall never be less than the monthly benefit, commencing at his Normal retirement Age, that is the Actuarial Equivalent of the single sum amount determined pursuant to Section 6.2(b)(2)(E). Section 6.2(b)(2)(E) provides: with regard to a Transferred Employee who terminates employment with all Affiliates pri- or to January 1, 2005, the sum of (i) the Actuarial Equivalent of such Transferred Employee’s Frozen Core Pension Benefit, determined using the Transferred Employee’s age on July 1, 2001, and using 5.78% as the Applicable Interest Rate, plus (ii) such Transferred Employee’s Frozen Enhanced Cash Balance Account. Cingular Wireless Bargained Pension Plan, CWA District 1 Program, Effective November 1, 2001 [Doc. #, Ex. 36] at 20, 29. The Cingular SPD included the following provisions: Accrued Beneftt Your Accrued Benefit under the Program is a monthly benefit that will begin once you reach Normal Retirement Age and will continue for the remainder of your life (such a lifetime benefit is referred to as a “Life Annuity”). If your Accrued Benefit is paid in a different form or prior to your Normal Retirement Age, certain adjustments may apply. These adjustments are described in greater detail in later sections of the Summary Plan Description. If you have not yet reached age 65, your Accrued Benefit is Equal to the monthly annuity that your Cash Balance Account could purchase if it continues to earn Interest Credits (but not Service Credits) until you reach age 65. The annuity value of your Cash Balance Account (once it has been projected to age 65) is determined by dividing the projected amount by 119.04. The Cingular SPD includes the following example: Example ... on January 1, 2003, you are age 50 and have a Cash Balance Account of $50,000. Your Accrued Benefit is determined by taking the following steps: Step 1: Your Cash Balance Account is projected to age 65 using the applicable monthly rate of Interest Credits. See “Interest Credits” above for more information. $50,000 x 1.00565 x 1.00327 $93,463.75 Note that the monthly Interest Credit rate is 0.656% for the 16 months from January 2003 through April 2005 and that it decreases to 0.327% for the remaining 164 months until January 2018 (when you reach age 65). Step 2: The amount determined in Step 1 is divided by 119.04. $93,463.75 /119.04 = $785.15. Your Accrued Benefit under the Program is $785.15 per month commencing when you reach age 65. Further, the Cingular SPD explains the consequences of early retirement as follows: If You Want To Receive Your Benefits Early If you choose to receive payments prior to age 65, your Accrued Benefit will be adjusted by a certain percentage. The “Early Retirement Factor Table” on pages 30-32 shows the amount you multiply your Accrued Benefit by to determine the amount of your monthly payments commencing prior to age 65. The earlier you retire, the smaller your monthly payments will be. Unreduced Early Benefits If you elect to begin your benefit payments prior to January 1, 2005, and you have 20 or more years of Net Credited Service and have attained age 55, your Accrued Benefit will not be reduced for early commencement. Additionally, if you elect to begin your benefit payments prior to January 1, 2005, and you have 30 or more years of Net Credited Service, your Accrued Benefit will not be reduced for early commencement at any age. Any payments beginning on or after January 1, 2005 will be subject to the Early Retirement Factors if they commence prior to age 65. Early Retirement of Cingular Plaintiffs In the fall of 2002, plaintiffs Parry, Bsul-lak, Demaria, Hosfelt, and Mahoney requested estimates from Cingular of the early retirement pension benefits they were eligible for under the Cingular Plan. Fidelity Advisory Services (“Fidelity”), Cingular’s pension administrator, provided the estimates, using the same calculation as Mellon had with regard to the 2001 SBC/SNET retirees, that is, projecting the CBPA forward with interest credits to age 65, then dividing that figure by 119.04, the age 65 annuity factor. Fidelity also informed these plaintiffs that lump-sum distributions were available in addition to annuities. After receiving the estimates from Fidelity, these five plaintiffs retired effective January 2003. Shortly thereafter, Cingular learned of the pension estimates and determined that they overstated the amount due to these plaintiffs. Lew Walker, Vice President for Human Resources Operations and Labor at Cingular, wrote to the five retirees and explained that: The pension calculation contained two errors. First, a programming error occurred that resulted in an overstatement of the annuity amount. The cash balance amount was projected forward with interest credits and should not have been. Second, the calculation showed an overstated lump sum. The lump sum available under the Plan is your current Cash Balance Account. See, e.g. Letter from Lew Walker to George E. Bsullak, Feb. 21, 2003 [Doc. # 82] at CIN 301. Cingular offered these retirees the same settlement that had been offered to the 2001 SBC/SNET retirees, providing that Cingular would increase their annuity by 60% of difference between the annuity amount estimated by Fidelity and the annuity amount Cingular believed to be correct. See, e.g. id. The retirees were also given the options of: re-employment; accepting a lump sum payment equal to the value of the cash balance account, with interest accruing at a rate of 7% between the date of termination and the date of payment; or accepting certain other payment options based on what Cingular believed to be the correct annuity amount. All of the retired Plaintiffs had elected lump-sum distributions, and rejected the settlement offer. On April 16, 2003, counsel for plaintiffs wrote to Cingular that he had reviewed all of the pertinent documents with his actuary, and asserted that the original estimate provided to the retirees by Fidelity was correct. Attached was an opinion by actuary Claude Poulin, which provided in relevant part: Paragraph 3 of the Pension section of the Memorandum of Understanding reads as follows: ... [“]the monthly pension attributable to the CBP account will be determined as though the participant was age 65. If employee is under age 65 and elects distribution of the CBP benefit as a single life annuity, the monthly pension benefit will be equal to the CBP account divided by 119.04.” (Emphasis added). In my opinion, the calculations which base the monthly pensions on the cash balance (CBP) accounts at the participant’s attainment of age 65 are the proper ones. Any other interpretation would make the emphasized section above redundant since, in the last sentence of the cited paragraph, the number 119.04 is actually the age 65 conversion factor found in the SNET Pension Plan. Moreover, under IRS Notice 96-8, the accrued benefit payable as an annuity under a cash balance plan must include the interest credits up to age 65, the plan’s normal retirement age. Letter from Claude Poulin to Thomas Moukawsher, April 15, 2003 [Doc. # 82] at CIN 269-70. Thus, by Mr. Poulin’s interpretation, the retirees were entitled to the benefits they would have received had they collected their benefits at their normal retirement age, instead of receiving the distributions at the time of their early termination of employment. Mr. Poulin found that the lump sum calculations originally provided to the retirees, which did not reduce the future interest credits to present value, were correct. Cingular processed this letter as a claim for benefits, and in a letter decision issued on April 25, 2003, Mary Allen, Cingular’s Director of Retirement Planning and Administration, rejected the plaintiffs’ pension calculations. In particular, Ms. Allen stated: In reviewing your claim, we considered all the information in your April 16 letter and attachment and also reviewed the provisions of the MOU and IRS Notice 96-8. We disagree with your assertions concerning the application of paragraph 3 of the MOU and also believe that you failed to consider the final sentence of paragraph 3 of the MOU as well as other provisions of the MOU. The phrase from paragraph 3 that Mr. Poulin emphasized in his letter means simply that the monthly pension benefit of employees calculated under paragraph 3 of the MOU will not be subject to reduction under the Plan’s early retirement commencement factors that normally apply to participants who retire prior to age 65. The last sentence of paragraph 3, which you and Mr. Pou-lin did not address, supports this and provides the clear direction on how to calculate the monthly benefit for,an employee eligible for the benefit under paragraph 3: “If the employee is under age 65 and elects distribution of the CBP benefit as a single life annuity, the monthly pension benefit will be equal to the CBP account divided by 119.04.” The methodology stated in that final sentence was used in calculating the correct annuity amounts communicated to your Clients .... Finally, both you and Mr. Poulin assert that your Clients are entitled to the incorrect lump sums originally communicated to your Clients. We also disagree with this. Paragraph 5 of the MOU, which you did not address, specifies the lump sums available to employees such as your Clients. The lump sum you have requested is not available. Letter from Mary Allen to Thomas Mou-kawsher, April 25, 2003 [Doc. # 82] at CIN 259-260.- ' On May 1, 2003 plaintiffs’ counsel filed an appeal of this decision with Cingular’s Administrative Committee, and in a decision issued on August 12, 2003, the Administrative Committee upheld the denial of plaintiffs’ claims for benefits. In particular, the Committee reasoned that paragraph 3 on page 126 of the MÓU only applies to those employees who meet the age and service requirements for the Special Retirement Provision and who elect the annuity form of payment. By its terms, it only applies to ‘the monthly pension attributable to the CBP account.’ .... [Further,] all of the sentences of paragraph 3, particularly the last sentence, must be read together in calculating an annuity for an employee under the Special Retirement Provision. The Committee concluded that the next to the last sentence provides general instruction for calculating the benefit and the final sentence states specifically how the benefit is to be calculated. Letter from Monty Hill, Secretary — Administrative Committee, to Thomas Mou-kawsher, August 28, 2003 [Doc. #82] at CIN 198. The Committee also considered the CWA union’s view of -the agreement they had reached in 2001, and concluded that (1) the union had affirmed the Committee’s benefits calculation in a CWA member spreadsheet that was designed as a pension calculator tool for employees; (2) a summary of the MOU prepared by the union for employees emphasized that the negotiated early retirement benefit applied only to the annuity form of payment; (3) the CWA wrote to SBC and Cingular, stating its belief that the companies “misinterpreted” the provisions of the MOU document, resulting in “inflated” monthly annuity amounts. See id. at CIN 198-199. Among the Committee’s other considerations were that the higher benefits calculations “had only been provided at the time of retirement and that prior to that time, correct estimates were provided;” “the language of the SPD supported the revised, corrected retirement calculations;” and “as part of the asset transfer to the Plan [at the time Cingular was formed and SBC/ SNET employees transferred employment], SBC and the SNET Plan did not transfer assets to cover the overstated annuities or the overstated lump sums as the liability evaluation was based on the correct calculation methods contained in the MOU.” Id. at CIN 200-201. On January 26, 2004, six months after receiving this decision, the five Cingular retirees filed suit, along with nine current Cingular employees and sixteen others who were subject to the SBC/SNET Plan. The nine current Cingular employees subsequently submitted an administrative claim, and appealed the denial of that claim to the Administrative Committee, thereby exhausting their administrative remedies. In the course of administratively appealing their claim, counsel for the nine current Cingular employees argued for the first time that Cingular’s benefits calculation was in conflict with the Cingu-lar Plan and the SPD, not simply with the MOU. Rejecting this new argument, the Administrative Committee “noted that there are inconsistencies between the Plan, the SPD and the MOU. However, in resolving these inconsistencies, the Committee concluded that the clear language of the MOU reflects the language negotiated and agreed on by SBC and the CWA and, therefore the MOU must prevail.” Letter from Monty Hill, Secretary, Administrative Committee, to Thomas G. Moukawsher, July 15, 2004 [Doc. # 82] at CIN 3231. The Committee also found that “any unilateral modification of the MOU by Cingu-lar would violate federal law.” See id. Early Retirement of SBC/SNET Plaintiffs The SBC/SNET plaintiffs submitted their claim for benefits to the SNET Claims Administrator on April 1, 2004. In claim denial letters issued to the SBC/ SNET plaintiffs on April 23 and 26, 2004, the SBC Plan Administrator found that “[njeither the plan document nor the MOU state that participants are eligible for interest credits until age 65. In addition, the Plan’s legal counsel has opined that the benefit calculation procedures were in accordance with applicable law.” See Claim Denial Letters [Doc. # 75, Ex. B] at SBC 1623-24, 2108-09, 2171-72, 2237-28, 2294-95, 2353-54, 2412-14, 2472-73, 2526-27, 2584-85, 2645-46, 2710-11, 2768-69, 2840-41, 2898-99, 2953-54. The SBC/SNET plaintiffs appealed to the Benefit Plan Committee on April 28, 2004, challenging SBC’s interpretation of the Plan language and arguing that SBC’s interpretation of the early retirement benefit as applying only to the annuity form of payment, not to other benefit forms, was contrary to law. In particular, plaintiffs argued that because ERISA requires that alternative benefit forms must be at least the actuarial equivalent of the normal retirement annuity, “[t]he Age-65 Treatment Provision cannot be applied SBC’s way because SBC’s application would enhance the annuity payable under the Plan by applying the age-65 conversion factor but would not enhance the alternative lump sum benefit available.” Request for Review Letter from Thomas. G. Moukawsher to SBC Benefit Plan Committee, April 28, 2004 [Doc. # 75, Ex. B] at SBC 1663-64. Plaintiffs also argued that SBC’s interpretation would place “impermissible conditions on claimants’ receipt of benefits,” causing an illegal forfeiture under ERISA. See id. at SBC 1664. The SBC Benefit Plan Committee denied plaintiffs’ appeal on June 17, 2004, concluding without further explanation that “neither the Plan’s language nor the intent of the bargainers required such interest credits,” and that plaintiffs’ legal arguments “were without merit.” Letters from Christine Holland, Secretary, Benefit Plan Committee, to Thomas Moukawsher, June 17, 2004 [Doc. # 75, Ex C]. II. Discussion . A. SBC/SNET Plan 1. Standard of Review “A denial of benefits challenged under Section 1132(a)(1)(B) is to be reviewed under a de novo standard unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989). “Where the plan reserves such discretionary authority, denials are subject to the more deferential arbitrary and capricious standard.” Kinstler v. First Reliance Standard Life Ins. Co., 181 F.3d 243, 249 (2d Cir.1999). “The plan administrator bears the burden of proving that the arbitrary and capricious standard of review applies, since ‘the 'party claiming deferential review should prove the predicate that justifies it.’ ” Id. (quotation omitted). Both the SBC/SNET Plan and the SPD provided to the employees explicitly give the plan administrator full discretion to interpret the plan. Section 9.6(d) of the Plan provides: The Committee and each Claims Administrator and each subcommittee to whom claim determination or review authority has.been delegated shall have full and exclusive authority and discretion to grant and deny claims under the Plan, including the power to interpret the Plan and determine eligibility of any individual to participate in and receive benefits .under the Plan. , SBC/SNET Plan [Doc. #75, Ex. A] at SBC 540. The SBC/SNET SPD similarly informs employees that the plan administrator retains full discretion to interpret the plan. Plaintiffs argue first, however, that because the Committee interpreted the MOU rather than the SBC/SNET Plan when it denied plaintiffs’ administrative claim, and because the MOU does not contain a reservation of discretion in the plan administrator, the de novo standard of review applies. As to the SBC/SNET defendants, this argument must fail, because the MOU merely amended the existing SBC/SNET Plan, and its terms in fact had been incorporated into the SBC/SNET Plan at the time the plaintiffs brought their claims for benefits. See SBC/SNET Plan [Doc. # 75, Ex. A] at § 7.3. Moreover, both the plan administrator’s initial denial letter and the Benefit Plan Committee’s final decision clearly reference the Plan itself, which they conclude is consistent with the MOU terms. See Claim Denial Letters [Doc. # 75, Ex. B] at SBC 1623-24 et al.; Letters from Christine Holland, Secretary, benefit Plan Committee, to Thomas Mou-kawsher, June 17, 2004 [Doc. # 75, Ex. C]. Plaintiffs, relying on Rabin v. Chesebrough-Pond’s Inc., 1991 U.S. Dist. LEXIS 21754, * 49 (D. Conn. June 26, 1991), also argue that de novo review is appropriate because the terms of the plan are mandatory and unambiguous. In Rabin, the district court found that although the plan contained provisions “granting some discretion to the committee of outside directors designated to administer the plans, the change in control provisions are mandatory in nature; decisions involving their application are therefore subject to de novo review.” Id. Here, the SBC/SNET plan is unambiguous in granting the plan administrator full discretion to interpret the plan. In light of the clear weight of Supreme Court and Second Circuit authority requiring an arbitrary and capricious standard of review where there is a such a reservation of discretion, this Court declines to read Rabin to broadly carve out the exception plaintiffs seek. Such an exception for mandatory plan terms would overtake the well-established rule, and mandatory plan terms can be appropriately accounted for even applying the deferential standard. In addition, plaintiffs argue that the Court should not defer to plan administrators in this case because their interpretation of plan documents was affected by a conflict of interest. According to plaintiffs, “the circumstances of this case prove without further evidence that the companies’ large financial stake in the matter has ‘some connection’ to the denial of the employees’ administrative claims.” See Memorandum in Support of Plaintiffs’ Motion for Partial Summary Judgment [Doc. # 123] at 23. “[T]he existence of such an alleged conflict does not operate to change the standard of review, but rather becomes ‘a facto[r] in determining whether there is an abuse of discretion.’ ” Pagan v. NYNEX Pension Plan, 52 F.3d 438, 442 (2d Cir.1995) (quoting Bruch, 489 U.S. at 115, 109 S.Ct. 948) (internal quotation omitted). Thus, the Second Circuit instructs that it is appropriate to review the Committee’s decision under the arbitrary and capricious standard, “irrespective of whether the ... Committee was operating under a possible or actual conflict of interest.” Id. (citing Heidgerd v. Olin Corp., 906 F.2d 903, 908 (2d Cir.1990)). Even if an actual conflict of interest is shown, the test for determining whether the administrator’s interpretation of the plan is arbitrary and capricious requires the following two inquiries: First, whether the determination made by the administrator is reasonable, in light of possible competing interpretations of the plan; second, whether the evidence shows that the administrator was in fact influenced by such conflict. If the court finds that the administrator was in fact influenced by the conflict of interest, the deference otherwise accorded the administrator’s decision drops away and the court interprets the plan de novo. Sullivan v. LTV Aerospace & Def. Co., 82 F.3d 1251, 1255-56 (2d Cir.1996). Because the SBC/SNET plan documents contain a reservation of discretion giving the Plan Administrator full authority to interpret the Plan, and because a conflict of interest is not a basis for de novo review, but is a factor to be considered in determining whether the decision was arbitrary and capricious, the Court will apply the more deferential standard to the decision of the SBC/SNET plan administrators. Under this standard, a court “may overturn a decision to deny benefits only if it was without reason, unsupported by substantial evidence or erroneous as a matter of law. This scope of review is narrow, thus [a court is] not free to substitute its own judgment for that of the [Plan Administrator] as if we were considering the issue of eligibility anew.” Pagan v. NYNEX Pension Plan, 52 F.3d 438, 442 (2d Cir.1995) (citations and internal quotation marks omitted); see also Bowman Transp., Inc. v. Arkansas-Best Freight Sys., 419 U.S. 281, 285, 95 S.Ct. 438, 42 L.Ed.2d 447 (1974) (“A reviewing court must consider whether the decision was based on a consideration of the relevant factors and whether there has been a clear error of judgment.”) (quotation omitted). 2. Analysis a. Early Retirement Annuity SBC/SNET’s decision to deny plaintiffs’ claim for benefits was based on its construction of the text of the relevant plan documents. Plaintiffs dispute the plan administrator’s interpretation and assert that the plain meaning of the MOU, reflected in the provision that “the monthly pension attributable to the CBP account will be determined as though the participant was age 65,” is a promise that “employees will get the pensions they would get at age 65 at an earlier age.” Plaintiffs’ Memorandum in Support of Their Motion for Partial Summary Judgment [Doc. # 78] at 29. While plaintiffs construction is reasonable, it is not the obvious or the only interpretation. SBC/SNET’s view, that this provision means only that they will treat the monthly pension attributable to the employee’s existing CBP account in the manner they would if' the employee were age 65, is as consistent as plaintiffs’ view that the provision requires a projection of what the CBP account would be when the employee in fact reaches age 65. In reaching their decision, the SBC/ SNET Committee also considered the sentence that followed in the MOU, and which is incorporated as well into Section 7.3(b) of the SBC/SNET Plan, namely: If an employee is under age 65 and elects distribution of the CBP benefit as a single life annuity, the monthly pension benefit will be equal to the CBP account divided by 119.04. It is SBC/SNET’s position that this provision demonstrates how to carry out .the general intent of the preceding sentence. Plaintiffs respond by arguing first that neither the SNET Plan nor the SPD contains the second sentence. Although Section 7.3 of the SBC/SNET Plan includes both relevant sentences from the MOU, plaintiffs focus on Supplement 18, which was added to the plan to memorialize the MOU and SBC/SNET’s settlement with the 2001 retirees, and provides only that the early retirement benefit is the greater of “(1) the monthly pension attributable to the CBPA determined as through the Participant was age 65, or (2) the monthly pension attributable to the CBPA under the otherwise applicable provisions of the Plan.” See SBC/SNET Plan, Supplement 18, June 1, 2003. [Doc. # 123, Ex. 34] at 143. Plaintiffs argue that Supplement 18 of the SBC/SNET controls because it applies “[notwithstanding any other provision of this Plan.” See id. at 143: The SPD uses identical language to describe the early retirement benefit. See SBC/ SNET SPD [Doc. # 123, Ex. 35] at 29. Even though standing alone, the descriptions of the early retirement benefit in Supplement 18 and the SPD are ambiguous, the Committee’s ultimate interpretation of the Plan is not inconsistent with the SPD or Supplement 18. In the absence of conflicting plan provisions, the “notwithstanding” language in Supplement 18 need not be invoked. Moreover, this is not a case in which the terms of the Plan conflict with those of a plan summary relied on by employees, and it is therefore possible and preferable to construe the plan documents consistently as a whole. Compare Heidgerd v. Olin Corp., 906 F.2d 903, 908 (2d Cir.1990) (holding that where “the terms of a plan and those of a plan summary conflict, it is the plan summary that controls” because the summary is the employee’s primary source of information) with Fay v. Oxford Health Plan, 287 F.3d 96, 104 (2d Cir.2002) (stating general rule that it is appropriate to “review the Plan as a whole, giving terms their plain meanings.”); Perreca v. Gluck, 295 F.3d 215, 224 (2d Cir. 2002)(It is a “cardinal principle of contract construction[ ] that a document should be read to give effect to all its provisions and to render them consistent with each other.”). ■ Plaintiffs also contend that SBC/SNET’s construction of the provision makes the second sentence “superfluous and misleading — superfluous because the words no longer have any meaning independent of the words that immediately follow them— misleading because reading the language this way suggests that the only difference between the benefits of an employee retiring at age 65 and the benefits of an employee retiring at age 52 is that the older employee’s annuity is calculated using a more favorable conversion factor,” when “the larger difference in benefits between the two ages is the extra interest credits the older employee earns, not the use of the age-65 conversion factor.” Plaintiffs’ Memorandum of Law in Support of their Motion for Partial Summary Judgment [Doc. # 78] at 29-30. Plaintiffs thus insist that the only reasonable construction would require the Plan Administrator to project forward the employee’s CBP balance with interest credits to age 65, and then apply the age 65 conversion factor to that amount. Plaintiffs’ construction, however, requires ignoring the calculation provision altogether, because by its plain terms, the provision that “the monthly pension benefit will be equal to the CBP account divided by 119.04” would not permit the projection of interest credits forward to age 65. Nor can it be said that the early retirement provision is meaningless. While SBC/SNET’s construction would not provide early retirees with unreduced benefits, the use of the early retirement conversion factor has the effect of partially subsidizing the early retirement benefits. The Committee’s view that the calculation provision explained how to give effect to the general mandate to determine the monthly pension attributable to an employee’s CBP “as though the participant was age 65” is reasonable, and does not render any part of the plan superfluous. The MOU provisions were incorporated into Section 7.3(b) of the SBC/SNET Plan, the section providing for the “Amount if Payable as a Single Life Annuity.” See swpra at 5-6. This subsection is not a model of clarity, and offers three separate possible calculations for the monthly payment amount of the CBPA. As the SPD and Supplement 18 make clear, employees eligible for early retirement were entitled to receive the greater of the bargained-for early retirement benefit or “the monthly pension attributable to the CBPA determined under the otherwise applicable provisions of the Plan.” The first two sentences of subsection 7.3(b) provide that in order to calculate the monthly payment amount of the CBPA, the plan administrator should first calculate the accrued monthly benefit by multiplying the employee’s CBPA by the applicable conversion factor in Table 6.6 of the plan (which converts the Cash Balance Plan Account to Annual Annuity at age 65 or later); and then multiply that amount (the accrued monthly CBPA benefit at Normal Retirement Age) by the appropriate early commencement reduction factor found in Table 6.7 in Appendix A using the Employee’s age at the time of. the commencement of the pension benefit. Section 7.3(b)’s ' calculation effective as of January 1, 2000, however, calculates the accrued monthly benefit by (a) projecting the employee’s CBPA from termination of employment to Normal Retirement Age with interest credits; (b) dividing that amount by the applicable annuity conversion factor found in Table 6.1, which is based on the employee’s current age; (c) multiplying that amount by the applicable early retirement reduction factor found in Table 6.7 of the SNET Pension Plan, using the employee’s age at the time of commencement of the benefit. Finally, Section 7.3 incorporates the terms of the MOU, as discussed above, which the SBC/SNET Committee construed as requiring the employee’s cash balance account to be converted into a monthly benefit by dividing the balance by the age 65 conversion factor of 119.04. Thus, under the otherwise applicable provisions of the plan, employees who commence receipt of their retirement benefits prior to reaching age 65 would have their accrued benefit discounted by an early commencement factor. Such a result would be consistent with ERISA, which provides that early retirement benefits must be “not less than the benefit to which he would have been entitled at the normal retirement age, actuarially reduced under regulations prescribed by the Secretary of the Treasury.” 29 U.S.C. § 1056. SBC/ SNET notes, and plaintiffs do not dispute, that the result of its calculation is always greater than the amount the employees would be entitled to under the otherwise applicable provisions of Section 7.3(b). Because this amount exceeds the minimum required by ERISA, the Committee’s construction complies with federal law. b. Lump Sum Benefits SBC/SNET determined that the early retirement provision applied only to the annuity form of payment, not other forms such as lump sums. Plaintiffs acknowledge that the SNET Plan and the SPD provide that the early retirement benefit applies only to the annuity form of payment, as the MOU was incorporated into Section 7.3(b) of the Plan, which clearly sets forth the “Amount if Payable as a Single life Annuity,” and the SPD likewise describes the MOU provision as an “Enhanced CBPA Annuity.” Plaintiffs argue, however, that the MOU should be interpreted as allowing unreduced early retirement benefits as a lump sum. In plaintiffs’ view, in order to give effect to the early retirement provision and provide unreduced early retirement benefits, the lump sum calculation should project the CBPA balance forward with interest credits to age 65 but should not discount back to present value. Plaintiffs look to paragraph 5 of the MOU, which provides that the lump sum must be “[t]he employee’s CBP account balance” if that is higher than the other possible calculations of the lump sum. Plaintiffs read paragraph 5 in conjunction with paragraph 3 of the MOU (which sets forth the early retirement benefit), and argue that the CBP account balance should be calculated “as though the participant was age 65” by projecting interest credits forward, and that there is no need to reduce that value back to present value because that would “undo the benefits granted in paragraph 3.” Plaintiffs’ Mem. at 4. This interpretation must fail, for several reasons. First, the early retirement benefit expressed in paragraph 3 of the MOU expressly applies to the “monthly pension attributable to the CBP account,” not to the amount of the CBP account itself. Thus, the inclusion of this provision in the plan documents to benefits taken in the annuity form of payment is reasonable, particularly given paragraph 3’s inclusion of the sentence beginning “[i]f employee is under age 65 and elects distribution of the CBP benefit as a single life annuity ...which, as discussed above, is reasonably viewed as an expression of how to carry out the general intent of the preceding enhanced early retirement benefit provision. Moreover, receipt of a lump sum payment that projected interest credits forward to age 65, but did not discount back to present value would give plaintiffs more than what they could expect from the annuity, which is nowhere provided for in the MOU or in any of the plan documents. Plaintiffs also argue that the plan language violates ERISA “by forcing employees to choose between an unreduced early retirement annuity and the only other option SNET says is available, the less valuable current balance of their cash balance accounts.” PI. Mem. at 10. The SNET Plan provides: The lump sum distribution of an Employee’s CBPA as of the commencement date shall be the greater of (i) the Employee’s CBPA; and (ii) the present value of the Employee’s accrued benefit as described in 5.2 .... For any Employee who terminates employment on or after October 21, 1997, the present value of the Employee’s accrued benefit calculated pursuant to this paragraph (ii) shall be the present value of the annuity calculated as of the Normal Retirement Age (or current age, if later) using the Applicable Interest Rate and the Applicable Mortality Table. SNET Plan, ¶ 7.3(e). Pursuant to this provision, SBC/SNET calculates the lump sum by (1) projecting the CBPA with interest credits to age 65; (2) converting the resulting amount into a monthly single life annuity at age 65 (by dividing the CBPA plus interest by 119.04, the age 65 annuity factor); and (3) converting that resulting amount into a lump sum value at the benefit commencement date using the present value factors set forth in Internal revenue Code 417(e)(3). This so-called “whip-saw” calculation is required under ERISA, because, as the Second Circuit explained in Esden v. Bank of Boston, 229 F.3d 154 (2d Cir.2000): [T]he rules governing distributions from defined benefit plans are framed in terms of the normal retirement benefit — typically, a single-life annuity payable at normal retirement age. Any distribution in optional form (such as a lump sum) must be no less than the actuarial equivalent of such benefit. For a cash balance plan this calculation involves projecting the cash balance forward and then discounting back to present value. The projection rates may be defined by the plan; but the discount rate is prescribed by statute. If the plan’s projection rate exceeds the statutory discount rate, then the present value of the accrued benefit will exceed the participant’s account balance. Unless this higher figure is paid out, the IRS takes the view that an impermissible forfeiture has occurred in violation of ERISA § 203(a) and I.R.C. § 411(a)(2). Id. at 159 (citing Notice 96-8, 1996-1 C.B. 359-61). Because the lump sum payment under the SBC/SNET plan will never be less than the amount resulting from the “whipsaw” calculation, it complies with ERISA. While the resulting lump-sum amount for an employee retiring early may be less than the comparable annuity benefit enhanced under the provisions of the Plan, there is nothing in ERISA or in the Internal Revenue Code that prohibits such a discrepancy. ERISA § 204(c)(3), or 29 U.S.C. § 1054(c)(3), provides: [I]n the case of any defined benefit plan, if an employee’s accrued benefit is to be determined as an amount other than an annual benefit commencing at normal retirement age, or if the accrued benefit derived from contributions made by an employee is to be determined with respect to a benefit other than an annual benefit if the form of a single life annuity (without ancillary benefits) commencing at normal retirement age, the employee’s accrued benefit, or the accrued benefits derived from contributions made by an employee, as the case may be, shall be the actuarial equivalent of such benefit or amount determined under paragraph (1) or (2). The term “accrued benefit,” in turn, is defined as “the individual’s accrued benefit determined under the plan and except as provided in section 204(c)(3), expressed in the form of an annual benefit commencing at normal retirement age.” ERISA § 3(23)(A). As the Second Circuit in Esden clarified: “What these provisions mean in less technical language is that: (1) the accrued benefit under a defined benefit plan must be valued in terms of the annuity that it will yield at normal retirement age; and (2) if the benefit is paid at any other time (e.g., on termination rather than retirement) or in any other form (e.g., a lump sum distribution, instead of annuity) it must be worth at least as much as that annuity.” Esden, 229 F.3d at 163. Accordingly, this Court agrees with defendants’ position that the lump sum benefit must be the equivalent of the normal retirement benefit, that is, the accrued benefit expressed as an annuity beginning at normal retirement age, but need not be the equivalent of the enhanced early retirement annuity. Plaintiffs argue that the logic that employees need not receive a lump sum benefit equal to the subsidized early retirement annuity is flawed because “[i]t ignores that Section 204(c)(3) says that employees must get lump sum benefits that are equal in value to their annuities when their accrued benefits are ‘determined as an ... annual benefit commencing at normal retirement age’ not that they must get lump sum benefits that are equal in value to their annuities only when their accrued benefits are ‘taken as an annual benefit commencing at normal retirement age.’ ” PI. Mem. at 43. The Court disagrees. The operative phrase in Section 204(c)(3) is that the employee’s benefit “shall be the actuarial equivalent of such benefit” (emphasis added). “Such benefit” in this paragraph refers to the “annual benefit commencing at normal retirement age,” not to any alternative benefit offered under the plan. Plaintiffs also argue that defendants misconstrue the meaning of an “accrued benefit” under ERISA. ERISA defines an accrued benefit as “the individual’s accrued benefit under the plan ... expressed in the form of an annual benefit commencing at normal retirement age.” (emphasis added) According to plaintiffs, this definition does not provide that the accrued benefit ‘‘is ” an annual benefit commencing at normal retirement age. While the use of the phrase “expressed in the form of’ acknowledges that the accrued benefit may take forms other than an annuity commencing at normal retirement age, it does not require that the other forms be anything other than equal to the value of the “annuity commencing at normal retirement age.” In addition, plaintiffs rely on Amato v. Western Union International, Inc., 773 F.2d 1402 (2d Cir.1985), in which the Second Circuit concluded that a plan amendment “eliminating plaintiffs’ unreduced early retirement benefits appears to violate ERISA § 204(g) and I.R.C. § 411(d)(6), which prohibit a decrease in a participant’s ‘accrued benefit.’ ” Id. at 1414. In Amato, however, the issue was whether a plan amendment could lawfully reduce early retirement benefits that employees had theretofore been eligible to receive. The Second Circuit thus did not consider the issue in this case, and offered no opinion on whether subsidized early retirement benefits may be offered in annuity form but not offered as a lump sum payment. This Court is further persuaded that ERISA plans are permitted to subsidize early retirement benefits when taken as an annuity but not when taken in other forms, because Treasury Regulations clearly authorize such an approach. For example, Treas. Reg. § 1.411 (a) — 11(a)(2) provides: Accrued benefit. For purposes of this section, an accrued benefit is valued taking into consideration the particular optional form in which the benefit is to be distributed. The value of an accrued benefit is the present value of the benefit in the distribution form determined under the plan. For example, a plan that provides a subsidized early retirement annuity benefit may specify that the optional single sum distribution form of benefit available at early retirement age is the present value of the subsidized early retirement annuity benefit. In this case, the subsidized early retirement annuity benefit must be used to apply the valuation requirements of this section and the resulting amount of the single sum distribution. However, if a plan that provides a subsidized early retirement annuity benefit specifies that the single sum distribution benefit available at early retirement age is the present value of the normal retirement annuity benefit, then the normal retirement annuity benefit is used to apply the valuation requirements of this section and the resulting amount of the single sum distribution available at early retirement age. See also T.D. 8219, 53 Fed.Reg. 31837 (1988), preamble to Treas. Reg. § 1.401(a)-ll (“A plan may have more than one optional form of benefit under which benefits may be paid. There is no requirement that each form of benefit be the actuarial equivalent of all other benefit forms ... [A] plan may provide for a retirement subsidy or an early retirement benefit that applies to the payment of a specific optional form. Whether these subsidies must be valued when calculating the amount of the single sum distribution depends on the plan provisions.”); T.D. 9099, 68 Fed.Reg. 70141 (2003), preamble to Treas. Reg. § 1.417(a)(3)-l (“If a plan provides a subsidy for one optional form of benefit (i.e., the payments under an optional form of benefit have an actuarial present value that is greater than the actuarial present value of the accrued benefit), there is no requirement to extend a similar subsidy (or any subsidy) to every other optional form of benefit. Thus, for example, a participant might be entitled to receive a single-sum distribution upon early retirement that does not reflect any early retirement subsidy in lieu of a QJSA that reflects a substantial early retirement subsidy.”). Thus, the Treasury Regulations make clear that while a plan may choose to subsidize early retirement benefits taken in both an annuity and lump sum form, it is not required to do so, and if the subsidized early retirement benefits apply only to the annuity form, then the normal annuity retirement benefit may be used to determine the lump sum amount. Plaintiffs seek to distinguish the IRS regulations by arguing that “subsidized” early retirement benefits, which are addressed by the regulations, are not the same as the “unreduced” early retirement benefits that they seek. Such parsing of language is both irrelevant, given this Court’s conclusion that SBC/SNET reasonably construed the early retirement annuity benefit to provide a partially subsidized early retirement benefit, and unavailing. Defendants argue and the Court agrees that the distinction plaintiffs seek “would be illogical since it would result in different rules applying to a plan simply because of the extent of its subsidy.” Treasury regulations, moreover, use the terms “unreduced” and “subsidized” interchangeably. See Tres. Reg. § 1.411(a) — T (“Example (1) Plan A ... provides for a full unreduced accrued benefit without any actuarial reduction for any employee at age 55 with 30 years of service. Even though the actuarial value of the early retirement benefit could exceed the value of the benefit at the normal retirement age, the normal retirement benefit would not include the greater value of the early retirement benefit because actual subsidies are ignored.”). c. Conflict of Interest The Second Circuit instructs that courts must engage in a two step inquiry when a conflict of interest is alleged: first, whether the determination made by the administrator is reasonable, and second, whether the evidence demonstrates that the administrator was in fact influenced by such conflict. Sullivan v. LTV Aerospace & Def. Co., 82 F.3d 1251, 1255-56 (2d Cir.1996). For the reasons discussed above, the Court concludes that the SBC/ SNET plan administrator’s determination was reasonable and supported by existing law. The evidence before the administrative committee demonstrating the intent of the bargaining parties in reaching the MOU also supports the administrator’s conclusion. Plaintiffs’ evidence that the administrators were in fact influenced by a conflict rests on the undisputed fact that the Committee members were employed by SBC subsidiaries. Plaintiffs thus argue that they had a financial stake in the matter at hand. Defendants assert, however, that the Committee had no financial incentive to deny SBC/SNET plaintiffs’ claims because the compensation of Committee members is not tied to their benefits determinations, and the benefits are paid from a fund established for the payment of benefits, which is separate from the assets of SBC and SNET. See Affidavit of Duane B. Helm, Vice President-Compensation of SBC Operations, Inc., August 16, 2004 [Doc. # 75, Ex. G] at ¶ 4. Under the circumstances of this case, and in light of the reasonable foundation for the Committee’s decision, plaintiffs have not demonstrated that the Committee members’ employment by SBC in fact influenced their decision. Plaintiffs have submitted extrinsic evidence, that was not before the Committee, indicating that the employees understood that they were to receive unreduced early retirement benefits, and that the intent of union officials was to try to match the benefits achieved at Verizon and other telecommunications companies providing unreduced early retirement benefits. Plaintiffs also note that the union is divided on the intent of the bargained agreement. “The decision whether to consider evidence from outside the administrative record is within the discretion of the district court. Nonetheless, the presumption is that judicial review ‘is limited to the record in front of the claims administrator unless the district court finds good cause to consider additional evidence.’ ” Muller v. First Unum Life Ins. Co., 341 F.3d 119, 125 (2d Cir.2003) (quoting DeFelice v. Am. Int’l Life Assurance Co. of N.Y., 112 F.3d 61, 66 (2d Cir.1997)). Because the Committee’s decision here is subject only to an arbitrary and capricious review, and in the absence of evidence that the Committee was in fact influenced by a conflict of interest, it is inappropriate to look outside of the administrative record. B. Cingular Plan 1. Standard of Review The standard of review to be applied in reviewing the claims of the Cingular plaintiffs presents a different set of questions. While the Cingular Plan provides that “The Administ