Full opinion text
MEMORANDUM OPINION REGGIE B. WALTON, District Judge. Plaintiff Ian Phillip James brings this action under the Employee Retirement Income Security Act of 1974, 29 U.S.C. §§ 1001-1461 (2006) (the “ERISA”), alleging that the defendants wrongfully denied him pension benefits, did not provide an adequate explanation for their decision to deny him these benefits, and failed to produce certain pension plan documents. See Third Amended Compl. (“3d Am. Compl.”) ¶¶ 22-46. Currently before the Court are the parties’ renewed cross-motions for summary judgment. Upon careful consideration of the parties’ motions and the entire record in this case, the Court concludes for the following reasons that the defendants’, motion must be granted in part and denied in part, and that the plaintiffs motion must be denied. I. BACKGROUND A. Facts The following facts are not in dispute and are taken in part from a memorandum opinion previously issued in this case. See James v. Int’l Painters & Allied Trades Indus. Pension Plan, 710 F.Supp.2d 16, 18-21 (D.D.C.2010). The plaintiff was a member of the Glaziers Local Union 963 (the “Union”) starting from at least August 1, 1962. Id. at 18. During his membership with the Union, the plaintiff worked for various employers who contributed to the Glaziers Local 963 Pension Plan (the “Local 963 Plan” or “Plan”). Id. The Local 963 Plan was, from its inception, a trust fund administered by a joint labor-management board of trustees as defined under 29 U.S.C. § 186(c)(5). Id. Effective January 1, 1998, the Local 963 Plan merged with the International Painters and Allied Trades Industry Pension Plan (the “Merged Plan”). Id. The Merged Plan preserved all benefits that had vested under the Local 963 Plan. Id. This case concerns two versions of the Local 963 Plan: one adopted in 1971 and another in 1993. Both versions of the Local 963 Plan contain the following pertinent components. To claim a vested interest in a pension, an employee must have accrued ten years of service credit. 1971 Plan § 3.1; 1993 Plan § 3.1. Employees who incurred “breaks in service” prior to vesting lost all accrued service credit. See 1971 Plan § 2.3 (“An employee will incur a loss of credited service when he fails to work at least 160 hours in any one of two (2) consecutive calendar years.”); 1993 Plan § 4.3 (“If an Employee has five consecutive Breaks in Service before he has earned Vested status, and if the number of consecutive Breaks in Service equals or exceeds his number of years of Vesting, he has a Permanent Break in Service. A Permanent Break m Service has the effect of canceling the Employee’s participation, his previously credited Vesting Service, and his previous Benefit Service.”). Service credits are divided into either past service credit, which is credit awarded for employment with a contributing employer prior to October 1, 1965, or future service credit, which is credit awarded for employment with a contributing employer after October 1, 1965. 1971 Plan §§ 2.1-2.2; 1993 Plan § 4.1. The plaintiff, believing that he had accumulated “14.54 years of covered employment,” which would qualify him as “a vested member of the Glaziers Local 963 union,” submitted an application for retirement benefits to the defendants in February 2005.3d Am. Compl. ¶¶ 5, 7. The defendants denied the plaintiffs application on March 29, 2005, claiming that the records provided to the Merged Plan by the Local 963 Plan at the time of the merger did not list the plaintiff as a vested participant. James, 710 F.Supp.2d at 19. The plaintiff then administratively appealed the defendants’ denial of benefits. Id. On August 23, 2005, the defendants denied the plaintiffs administrative appeal for the same reasons stated in their initial decision, but provided for further review of the plaintiffs application upon receipt of a Social Security Administration (“SSA”) earnings report for the plaintiff. Defs.’ Mot., Ex. 25 (August 23, 2005 Letter from Gary J. Meyers to Ian P. James) at 1. The defendants thereafter received the plaintiffs SSA earnings report, but were unable to determine from that record whether the plaintiff had any additional work in covered employment under the Local 963 Plan that qualified him as a vested Plan participant. Id., Ex. 32 (March 29, 2007 Letter from Gary Myers to Neil Intrater) at 1. However, during their review of the plaintiffs claims, the defendants discovered a Local 963 Plan record from 1973 which indicated that the plaintiff had “accumulated 3.3 years of past service credit before October 1, 1965, and 6.2 years of future service credit,” for a total of 9.5 service credits. Defs.’ Renew. Mem. at 3; see Pl.’s Mot., Ex. 13 (Annual Pension List Fund for Year Ending 12/31/1973 (“1973 Pension Record”)). Based on this newly discovered record, the defendants issued a revised determination on June 27, 2007, awarding the plaintiff $409.68 in monthly pension benefits.3d Am. Compl. ¶ 13. At the plaintiffs request, the defendants subsequently issued the following “breakdown” of their calculation of the $409.68 award: Years of Service Benefit Level Benefit 3.3 years of Past Service Credit $1.50 $ 54.00 6.2 years of Future Service Credit $4.94 $355.68 Total Monthly Benefit $409.68 Defs.’ Mot., Ex. 38 (August 16, 2007 Letter from Gary Meyers to Neil Intrater) at l. After receiving the defendants’ clarification letter, the plaintiff administratively appealed the defendants’ June 27, 2007 $409.68 monthly pension award. Defs.’ Mot., Ex. 39 (August 20, 2007 Letter from Neil Intrater to the International Painters and Allied Traders (“IPAT”) Board of Trustees) at 1. Specifically, the plaintiff appealed the “amount of the award,” claiming that it was improperly “calculated based upon 9.5 credits,” rather than the “14.54 credits” to which he claimed entitlement. Id. In support of his claim that he was entitled to 14.54 service credits, the plaintiff asserted that the defendants failed to credit him for service in covered employment from 1959 to 1972 and 1979 to 1980. Defs.’ Mot., Ex. 4 (March 3, 2008 Letter from Gary Meyers to Neil Intrater) at 2. The defendants denied the plaintiffs administrative appeal by letter dated March 3, 2008. Id. at 2-4. In rejecting the plaintiffs appeal, the defendants again highlighted the 1973 Pension Record that listed the plaintiff as having only 9.5 service credits, noting that the plaintiff failed to produce “any reliable evidence of additional service beyond” what was stated in this record. Id. at 2. Regarding the plaintiffs claimed service between 1959 and 1962, the defendants found that while the plaintiffs SSA earnings report “show[ed] work before 1962 with Local 963 employers, it [did] not show that this work was under a Local 963 Collective Bargaining Agreement,” and that it was “unlikely that the [plaintiff] worked continuously in the Local 963 bargaining unit in Maryland from 1959 to 1962 without union membership.” Id. at 3. They deemed the plaintiffs’ “belated and self-serving claim ... about the nature of his work ... insufficient to overcome the contemporaneous records.” Id. With respect to the claimed service credits in 1965, the defendants explained that “Section 4.1(a) of the [1993 Plan] gives past service credit for any plan year that began before [October 1, 1965],” where the employee “work[ed] under a Local 963 Collective Bargaining Agreement.” Id. at 2. Because the term “plan year” was not defined in the 1993 Plan, the defendants inferred from the 1973 Pension Record that the term designated a “calendar year.” Id. The defendants did not provide a detailed breakdown of how it concluded that the plaintiff was entitled to 3.3 years of past service credit, but they did state that credits earned in “early 1965” were “drop[ped]” from the calculation, and the plaintiff instead received “part[-]year credit” in 1965 for work performed “from October 1, 1965 to December 31, 1965.” Id. Regarding service credit for 1966 to 1969, the defendants estimated the credit to which the plaintiff was entitled “by [computing] the ratio of earnings for years 1967, 1968, and 1969 from contributing employers to the high earnings from contributing employers on the [plaintiffs Social Security] report in 1966.” Id. at 3. The defendants claimed that this calculation, when considered along with the 1973 Pension Record, confirmed that the plaintiff was only entitled to 6.2 future service credits for the time period between 1966 and 1973. Id. As for the disputed service credits in 1979 and 1980, the defendants found “no record of contributory work in this period beyond union membership from December 5, 1979 to April 2, 1980.” Id. While the plaintiff continued to dispute the defendants’ attribution to him of only 9.5 years of service, he ultimately decided that “due to the lack of documentation from the [defendants,” as well as “concernís] about retaliation,” he would “discontinue the litigation.” 3d Am. Compl. ¶ 16. Accordingly, on June 7, 2008, the plaintiff “executed ... acceptance forms for the $409.68 pension.” Id. ¶ 17. However, by a letter dated June 19, 2008, the defendants informed the plaintiff that they were rejecting his acceptance forms and retracting the $409.68 monthly pension award, based on their determination that he was not entitled to that award. Pl.’s Mot., Ex. 8 (June 19, 2008 Letter from Gary Meyers to Ian James) at 1. The letter explained that the defendants did not alter the past or future service credits previously awarded to the plaintiff, but that they did make two modifications: first, the defendants revised the amount that the plaintiff should receive for past service credit from $1.50 to $4.94; and second, they addressed a mathematical error contained in their August 16, 2007 clarification letter by adjusting the total benefit based on a correct computation of the plaintiffs service credit totals multiplied by the monthly award rates. Id. at 1-2. B. Procedural Background The plaintiff instituted this action on November 20, 2007, and subsequently amended his original complaint twice. His third amended complaint, filed July 21, 2008, contains the following seven counts: Count 1 “seeks compensatory damages for the past benefits that have been improperly denied” to the plaintiff, 3d Am. Compl. ¶ 23; Count 2 “seeks a declaratory judgment as to the amount of benefits, both past and future, to which [the plaintiff] is entitled,” and alternatively requests a “declaratory judgment that [the plaintiff] is entitled to the $409.68 in monthly benefits previously awarded by the [defendants,” id. ¶¶ 25-26; Count 3 asserts that the defendants unlawfully retaliated against the plaintiff and one of the plaintiffs coworkers in violation of 29 U.S.C. § 1140, id. ¶¶ 27-34; Count 4 “seeks injunctive relief directing [the defendants] to pay the [p]laintiff the benefits to which [he] is entitled,” and to “discontinue their retaliatory actions,” id. ¶¶ 36-37; Count 5 asserts that the defendants unlawfully failed to provide the plaintiff with “union employment records or relevant documentation and failed to provide [the p]laintiff with an understandable explanation for the denial of benefits” in violation of 29 U.S.C. § 1132(c)(1)(B) and 29 U.S.C. § 1133, id. ¶ 39; Count 6 asserts a claim for “common law breach of contract” against the defendants, id. ¶ 44; and Count 7 requests attorneys’ fees and costs, id. ¶ 46. By memorandum opinion dated April 30, 2010, this Court granted summary judgment to the defendants as to the plaintiffs claims for retaliation, breach of contract, and access to certain employment and union records. James, 710 F.Supp.2d at 29-32. As to the plaintiffs claims for denial of benefits and access to Plan documents, the Court denied the parties’ motions for summary judgment without prejudice, and remanded this case to the defendants for a determination of whether the plaintiffs benefit application fell under the 1971 or 1993 version of the Local 963 Plan. See id. at 26-29. In the event the defendants concluded that the 1971 Plan applied, the Court ordered them to make a “full and fair assessment of [the plaintiffs] claims” using the standards set forth in the 1971 Plan for determining whether the plaintiff has a vested pension under the Local 963 Plan, and provide a “clear communication to the claimant of the specific reasons for benefit denials, if any, under the terms of that version of the plan.” Id. at 27 (quoting Black & Decker Disability Plan v. Nord, 538 U.S. 822, 825, 123 S.Ct. 1965, 155 L.Ed.2d 1034 (2003)) (internal quotation marks omitted). Following the Court’s remand, the defendants determined that the 1971 Plan controlled, but that, even under this version of the plan, there was no basis for altering their previous findings. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 2. The defendants also endeavored to offer a “more coherent explanation” for their determination that the plaintiff was entitled to only 3.3 years of past service credit. Id. They reiterated their view that the 1973 Pension Record, which accorded the plaintiff 3.3 years of past service credit and 6.2 years of future service credit, was the “best available remaining record of service,” and added that this record’s indication that the plaintiff fell short of the 10 years of service required for vesting explained why the plaintiff was not listed as a vested employee in the Union’s Plan records at the time of the Union’s merger with the IPAT. Id. As justification for their reliance on the 1973 Pension Record, the defendants noted that their general practice is “to rely on plan records, particularly if they are consistent with other records, as the best basis for uniform treatment of all employees.” Id. at 3. The defendants further stated that the Local 969 Plan documents, as well as the plaintiffs union membership records showing a Union “initiation date” of August 1962, supported an award of 3.3 past service credits to the plaintiff for covered employment from August 1, 1962, to October 31, 1965. Id. While acknowledging that the plaintiffs SSA earnings report showed work prior to August 1962 with “glass industry employers,” the defendants adhered to their view that this work was not “covered by the collective bargaining agreement” and thus did not count toward the plaintiffs credited service. Id. The defendants additionally noted that the plaintiff, after earning only 9.5 service credits (0.5 credits short of the number needed for vesting) for covered employment from 1962 to 1972, had an “acknowledged break in contributory work from 1973 to 1979.” Id. Because the terms of the 1971 Plan provided that employees with less than 10 years of service credit lost all credit on a break of 2 calendar years with less than 160 hours of credit, the defendants concluded that the plaintiffs admitted break in service cancelled all of his service credit for 1962 to 1972. Id. The parties thereafter renewed their cross-motions for summary judgment. By order dated September 19, 2011, the Court again denied the parties’ cross-motions for summary judgment without prejudice and once again remanded this case back to the defendants. September 19, 2011 Order at 8, James v. Int’l Painters & Allied Trades Indus. Pension Plan, No. 07-2107 (D.D.C.) (“September 19, 2011 Order”). While agreeing “with the defendants’ explanation that the 1971 Plan governs this case,” id. at 2 n. 1, the Court found the defendants’ interpretation of the Plan unreasonable, id. at 7. Namely, the Court found fault with the defendants’ determination that the plaintiff was entitled to 3.3 years of past service credits, as the 1971 Plan plainly does “not contemplate the use of partial years of credited service because it only speaks of awarding credits in one year increments.” Id. at 6. The Court concluded that this interpretation of the 1971 Plan, even under a deferential standard of review, could not stand. Id. Because the “amount of the plaintiffs credited service will have ramifications for his remaining claims,” the Court deemed it imprudent to further analyze the parties’ arguments, and thus remanded this case to the defendants “to afford them another opportunity to calculate the plaintiffs past service credits in a manner that is reasonably supported by the language ... of the 1971 Plan.” Id. at 7-8. In accordance with the Court’s order, the defendants sent the plaintiff a letter that served as a “written calculation and explanation to the plaintiff ... of the amount of past service credits [to which] he is entitled.” Pl.’s Suppl. Mem., Ex. 53 (October 13, 2011 Letter from Kent Cprek to Neil Intrater) at 1. The defendants determined that the plaintiff is entitled to only 3 years of past service credits, id. at 4, based on the following factors. First, the 1971 Plan language provides that covered employees receive a “full year’s credit for every year worked under a bargaining agreement of the union,” which, in the defendants’ view, is “most consistent with credit only for completed full years before October 1, 1965.” Id. (emphasis added). Second, a 1972 amendment to the Plan provided past service credit for “service performed for each Plan Year that begins before October 1, 1965, any part of which the employee was covered by a collective bargaining agreement of the Union”; according to the defendants, this modified language “suggests a change in the meaning of the Plan.” Id. (emphasis added). Third, the defendants stated that the “Plan records indicate both the change in the [P]lan and that the change was not retroactive, so that the amendment did not affect James nor restore his previously cancelled service to allow him to vest.” Id. Finally, the defendants found that the “Merger Agreement with the Local 963 Plan expressly indicates” that the Merged Plan trustees must rely “on the accuracy of information provided by the Local 963 Plan trustees,” and that, “[i]f [such] information was inaccurate, the [Merged] Plan [trustees were] allowed to reduce future benefit accruals for Local 963 Plan employees to account for the increased costs.” Id. They added that the Merged Plan trustees are “not now in a position to find and correct past service records for those who left before the merger or estimate the associated costs.” Id. Following issuance of this letter, and at the parties’ request, the Court reinstated the parties’ previously denied cross-motions for summary judgment, and directed supplemental briefing based on the defendants’ October 13, 2011 determination. In their supplemental memorandum, the defendants reiterate their contentions that (1) the 1971 Plan, rather than the 1993 Plan, applies in this case; (2) even if the 1993 Plan controls, the plaintiff is barred from pursuing any claims based on the 1993 summary plan description; and (3) under the 1971 Plan, the plaintiff is entitled to only 3 years of past service credit. Defs.’ Suppl. Mem. at 2-3. The plaintiff responds, asserting that (1) the 1993 Plan is the controlling version of the Plan, Pl.’s Suppl. Reply at 1; (2) the terms of the 1993 Plan establish that he is entitled to a higher benefit multiplier than what is being offered by the defendants, id. at 3-4; and (3) his testimony and Social Security records demonstrate that he worked in covered employment between 1959 through 1965, and he therefore should be granted at least 6 years of past service credit, id. at 4-5. The plaintiff adds that “the [defendants have continued to ignore the uncontradicted evidence of over 14 years of credits” for covered employment from 1959 through 1972, 1979, and 1980, “and have continued to refuse to award [him] his rightful pension.” Pl.’s Suppl. Mem. at 2. II. STANDARD OF REVIEW This Court previously found that a deferential standard of review applies to the plaintiffs wrongful denial of benefits claim under the ERISA, see James, 710 F.Supp.2d at 23-24, and it discerns no reason to depart from that determination, see September 19, 2011 Order at 6 (“Despite the attempts by the plaintiff to revive his argument that a de novo standard of review should be applied, ... the Court remains unconvinced that this is the appropriate approach to employ.”). This standard of review has been “variously described by the [Supreme] Court as ‘arbitrary and capricious’ or ‘abuse of discretion,’ ” but, regardless of how it is phrased, the standard “is plainly deferential.” Wagener v. SBC Pension Benefit Plan-Non-Bargained Program, 407 F.3d 395, 402 (D.C.Cir.2005) (citing Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 111-115, 109 S.Ct. 948, 108 L.Ed.2d 80 (1989)). The District of Columbia Circuit “has defined the Firestone deferential standard as one of ‘reasonableness.’ ” Id. (quoting Block v. Pitney Bowes, Inc., 952 F.2d 1450, 1454 (D.C.Cir.1992)). Thus, in applying this standard, the “essential inquiry” for this Court is whether the defendants “reasonably construe[d] and appl[ied]” the Local 963 Plan in this case. Block, 952 F.2d at 1454. “If there is more than one action that is ‘reasonable,’ the Court must not overturn a decision found to be reasonable, even if an alternative decision also could have been considered reasonable.” Id. at 1452 (internal quotations omitted). As noted, this matter is currently before the Court on the parties’ renewed cross-motions for summary judgment. Ordinarily, summary judgment is appropriate where “the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(c). But in an ERISA case, “[w]hen the decision to grant or deny benefits is reviewed for abuse of discretion, a motion for summary judgment is merely the conduit to bring the legal question before the district court and the usual tests of summary judgment, such as whether a genuine dispute of material fact exists, do not apply.” Bendixen v. Standard Ins. Co., 185 F.3d 939, 942 (9th Cir.1999), overruled on other grounds in Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 966-69 (9th Cir.2006) (en banc); accord Orndorf v. Paul Revere Life Ins. Co., 404 F.3d 510, 517 (1st Cir.2005) (“[I]n an ERISA case where review is based only on the administrative record before the plan administrator and is an ultimate conclusion as to disability to be drawn from the facts, summary judgment is simply a vehicle for deciding the issue.”). Thus, insofar as the parties’ summary judgment motions concern the defendants’ denial of benefits to the plaintiff, the motions are merely procedural vehicles for the Court’s determination of whether the defendants’ actions were reasonable. III. ANALYSIS The Court must first evaluate the defendants’ determination that the 1971 version of the Local 963 Plan governs this case. Next, the Court will address the plaintiffs wrongful denial of benefits claim under the ERISA, looking at both the reasonableness of the defendants’ interpretation of the applicable Local 963 Plan as well as the adequacy of the explanation for their denial of benefits to the plaintiff. Finally, the Court will consider the plaintiffs claim based on the defendants’ alleged failure to produce Plan documents. A. The Controlling Version of the Local 963 Plan As explained above, the Court previously remanded this case to the defendants for a determination of which version of the Local 963 Plan applied to the plaintiffs claim for benefits, after which the defendants issued a letter on July 9, 2010, concluding that the 1971 Plan controlled. The Court then issued its September 19, 2011 Order, in which it stated in a footnote that it “agree[d] with the defendants’ explanation that the 1971 Plan governs this case.” September 19, 2011 Order at 2 n.l. The plaintiff resists this conclusion in his supplemental memorandum, reiterating his position that the 1993 Plan governs. Pl.’s Suppl. Reply at 1-3. Because the Court did not previously provide a detailed explanation of why it accepted the defendants’ view that the 1971 Plan applies, it will do so now. Section 11.4 of the 1993 Plan provides as follows: The terms and conditions of the Plan as restated herein shall amend and supersede, effective October 1, 1976, the terms and conditions of the Glaziers Local 963 Pension Plan, as in effect prior to October 1, 1976; provided, however, that the provisions of such prior plan shall continue to govern the rights of all Employees who were covered thereunder and who do not become Active Employees on or after October 1, 1976, except as otherwise stated herein. 1993 Plan § 11.4 (emphasis added). As for who constitutes an “Active Employee” under the 1993 Plan, Section 1.2 states: “Active Employee” means, as of the date in question, an Employee or former Employee who is other than a Retired Employee, and who has not incurred a one-year Break in Service, or if he has incurred a one-year Break in Service, has had contributions made to the Plan on his behalf subsequent to his most recent one-year Break in Service,[] provided however, that an employee who has not had contributions made to the Plan on his behalf on or before October 1, 1976, shall not be considered to be an Active Employee. 1993 Plan § 1.2 (emphasis added). Incorporated within the definition of the term “Active Employee” is the term “Employee,” which the 1993 Plan defines as “any person who is covered by a collective bargaining agreement between his Employer and the Union ... and for whom the Employer is required to contribute to this Plan pursuant to the collective bargaining agreement.” 1993 Plan § 1.11. According to the defendants, Section 11.4 of the 1993 Plan “preserves the [1971 P]lan for any Participants in the Plan before October 1, 1976[,] who did not have contributions paid to the Local 963 [Plan] for their work after October 1, 1976.” Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 2. Because the plaintiff was covered under the 1971 Plan, and because the defendants found “no evidence of any contributions to the Local 963 Plan for work by [the plaintiff] after October 1, 1976,” the defendants concluded that the 1971 Plan, not the 1993 Plan, applied to the plaintiff. Id. In challenging the defendants’ determination that the 1971 Plan controls, the plaintiff first contends that any attempt to distinguish between the 1971 and 1993 Plans is misguided because they are not separate plans, but amended descriptions of the same plan. See Pl.’s Renew. Mot. at 5-7; Pl.’s Suppl. Reply at 2. This argument misses the mark. While it is true that the 1971 and 1993 Plans are merely different versions of the same pension plan, it is equally clear that the 1993 Plan precludes the applicability of the 1993 Plan amendments to “[e]mployees who were covered [by the 1971 Plan] and who do not become Active Employees on or after October 1, 1976.” 1993 Plan § 11.4. Thus, based on the 1993 Plan’s plain language, the defendants reasonably concluded that the 1993 Plan “preserves the [1971 P]lan for any Participants in the Plan before October 1, 1976[,] who did not have contributions paid to the Local 963 [Plan] for their work after October 1, 1976.” Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 2. The plaintiff also raises a more substantial objection to the defendants’ conclusion that the 1971 Plan controls—namely, that he was an “Active Employee” after October 1, 1976, thereby making the 1993 amendments applicable to him pursuant to Section 11.4 of the 1993 Plan. PL’s Renew. Mot. at 7-9; see 1993 Plan § 11.4 (providing that the 1993 Plan shall apply to employees who were covered by the 1971 Plan and who “bec[a]me Active Employees on or after October 1, 1976”). According to the plaintiff, the undisputed evidence shows that he worked in 1979 and 1980 for Beltway Glass Company (“Beltway”), a union employer who made contributions to the Local 963 Plan on his behalf. PL’s Renew. Mot. at 8-9. And the plaintiff contends that such contributions made him an “Active Employee” after October 1, 1965, see 1993 Plan § 1.2, thus triggering the applicability of the 1993 Plan, see 1993 Plan § 11.4. The defendants acknowledge that Beltway had collective bargaining agreements with the Union in 1979 and 1980, and they do not dispute that Beltway made contributions to the Local 963 Plan on behalf of its employees in 1979 and 1980. See Defs.’ Suppl. Decl. ¶ 5. However, the defendants point out that the plaintiff was “an owner of Beltway Glass Company.” Id. The plaintiffs status as an owner, the defendants assert, establishes “that he was not covered by the collective bargaining agreement” between Beltway and the Union in 1979 and 1980. Id. The defendants thus adhere to their conclusion that the plaintiff has no proof of work after October 1, 1976, with an employer who made contributions to the Local 963 Plan on his behalf, and that the 1971 Plan consequently controls. Defs.’ Renew. Opp’n at 6-9; Defs.’ Suppl. Reply at 4-6. The Court finds that the defendants’ conclusion rests on a reasonable interpretation of the Local 963 Plan and the record in this case. For the 1993 Plan to apply to the plaintiff, he had to be an “Active Employee” on or after October 1, 1976 (i.e., his employer had to make contributions to the Local 963 Plan on his behalf on or after October 1, 1976). See 1993 Plan §§ 11.4, 1.2. The only union employment claimed by the plaintiff after October 1, 1976, is with Beltway in 1979 and 1980. See PL’s Reply, Ex. 41 (Supplemental Affidavit of Ian James) at 1-2 (detailing the plaintiffs employment from 1959 to 1980). To be sure, the record reveals that Beltway had a collective bargaining agreement with the Union in 1979 and 1980, see Defs.’ Suppl. Decl., Ex. 1 (Agreement Between Beltway and the Union, effective October 1, 1978 to September 30, 1981), and that Beltway made contributions to the Local 963 Plan in 1979 and 1980, see PL’s Renew. Reply, Ex. 52 (Cash Receipts and Hours spreadsheet) at 4-6 (reflecting pension payments from Beltway to the Union in 1979 and 1980). But, as the defendants point out, the plaintiff admittedly was not an employee of Beltway—he was one of its owners. See, e.g., Deposition of Ian Philip James [ECF No. 17-1] at 128:5-29:2 (acknowledging that the plaintiff was “an owner of a partnership called Beltway Glass”); Defs.’ Suppl. Deck, Ex. 1 (Agreement Between Beltway and the Union, effective October 1, 1978 to September 30, 1981) at 24 (signed by Ian Philip James on behalf of Beltway). Based on the plaintiffs status as an owner of Beltway in 1979 and 1980, the defendants reasonably determined that he was not an “Active Employee” of Beltway during these years. The defendants’ conclusion is supported by the 1993 Plan language in two respects. First, the plaintiff was not an “Employee” within the meaning of the 1993 Plan, which is a necessary component of qualifying as an “Active Employee.” The 1993 Plan defines “Employee” as “any person who is covered by a collective bargaining agreement between his Employer and the Union ... and for whom the Employer is required to contribute to this Plan pursuant to the collective bargaining agreement.” 1993 Plan § 1.11. And the collective bargaining agreement between Beltway and the Union prohibited “owners” and “employers having a proprietary interest in the business” from performing any work under the agreement, Defs.’ Suppl. Deck, Ex. 1 (Agreement Between Beltway and the Union, effective October 1, 1978 to September 30, 1981) at 6, thus indicating that owners, such as the plaintiff, were not covered by that agreement. In view of their finding that the plaintiff was not covered by the collective bargaining agreement between Beltway and the Union, it was reasonable for the defendants to conclude that the plaintiff was not an “Employee” in 1979 and 1980, and that he consequently was not an “Active Employee” during those years. See Defs.’ Suppl. Reply at 6. Second, because the plaintiff was not covered by the collective bargaining agreement, Beltway’s contributions to the Local 963 Plan in 1979 and 1980 for bargaining unit work were not “contributions made to the Plan on [the plaintiffs] behalf,” 1993 Plan § 1.2 (emphasis added), a prerequisite for the plaintiff to qualify as an “Active Employee.” Accordingly, the defendants reasonably determined that (1) the evidence of Beltway’s contributions to the Local 963 Plan in 1979 and 1980 did not prove that the plaintiff was an “Active Employee” after October 1, 1976, and (2) in light of the absence of evidence showing contributory work by the plaintiff after October 1, 1976, the 1971 Plan governs this case. Summary judgment as to the applicability of the 1971 Plan is therefore granted to the defendants. B. The Plaintiffs Claim for Wrongful Denial of Benefits Under the ERISA, a participant in a covered plan may sue “to recover benefits due to him under the terms of the plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.” 29 U.S.C. § 1132(a)(1)(B). Counts 1 and 2 of the third amended complaint seek such benefits and declaratory relief under this provision of the ERISA. See 3d Am. Compl. ¶¶ 22-26. In assessing the plaintiffs claim for wrongful denial of benefits, it is first necessary to understand several pertinent provisions of the 1971 Plan. To claim a vested interest in a pension under the 1971 Plan, an employee must have accrued at least 10 years of service credit. 1971 Plan § 3.1. Service credits are divided into either past service credit, which is credit awarded for employment with a contributing employer prior to October 1, 1965, or future service credit, which is credit awarded for employment with a contributing employer after October 1, 1965. Id. §§ 2.1-2.2. Past service credits are calculated in terms of whole years with no allowance for partial credit, see September 19, 2011 Order at 6 (determining that 1971 Plan clearly “does not contemplate the use of partial years of credited service because it only speaks of awarding credits in one year increments”), whereas partial credit is awarded for future service, 1971 Plan § 2.2 (granting “tenths of credit” for future service based on certain ranges of hours worked in covered employment). If, prior to completing 10 years of credited service (i.e., prior to vesting), an employee worked fewer than 160 hours for two consecutive calendar years, that employee, absent two exceptions, loses all credited service. 1971 Plan § 2.3 (providing that “[a] loss of credited service will cause the cancellation of all credited service accrued to date, both past and future,” except under certain conditions involving disability and military service, which are not applicable in this case). The plaintiff acknowledges a break in service from 1973 to 1978. See Pl.’s Reply, Ex. 41 (Supplemental Affidavit of Ian James) at 1-2 (detailing all contributory service from 1959 to 1980, and listing no employment for 1973 through 1978); Deposition of Ian Philip James [ECF No. 17-1] at 128:17-19 (acknowledging non-union employment with Beltway from 1973 through 1978); Pl.’s Suppl. Mem. at 5 (contending that the undisputed evidence demonstrates that the plaintiff is entitled to 14.54 years of service credits for service in “1959 through 1972, and 1979 and 1980”). Thus, unless he vested prior to 1973, the plaintiff admittedly incurred a two-year break in service that canceled all of his service credit. See 1971 Plan § 2.3. In denying the plaintiff benefits, the defendants determined that he incurred a complete loss of service credit because he did not accrue 10 years of service prior to 1973. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 4. According to the defendants, the plaintiff is entitled to 3 years of past service credit for work he performed from August 1962 to October 1965, PL’s Suppl. Mem., Ex. 53 (October 13, 2011 Letter from Kent Cprek to Neil Intrater) at 4-5, and 6.2 years of future service credit for work he performed from October 1965 to April 1972, Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 4. With a total of only 9.2 service credits prior to 1973, it is the defendants’ position that the plaintiff did not vest for the receipt of benefits before incurring his five-year break in service from 1973 to 1978, thus resulting in the termination of all service credit. Defs.’ Suppl. Reply at 2. The plaintiff, on the other hand, contends that he is a vested employee because he is entitled to 14.54 years of service credit. PL’s Renew. Mot. at 11. Specifically, he claims that he worked from 1959 through 1972, and again in 1979 and 1980 in covered employment (i.e., employment covered by collective bargaining agreements with the Union). Id. at 3. The Court will consider the plaintiffs disputed service credit in chronological order. 1. Past Service Credit for Work Performed from 1959 through 1962 The 1971 Plan awards employees one year of past service credit for each year prior to October 1,1965, during which they were “employed under collectively bargained agreements of the Union.” 1971 Plan § 2.1. Regarding the plaintiffs claimed work from 1959 through 1962, the parties’ dispute concerns whether the plaintiffs work was covered by Union collective bargaining agreements. The plaintiff claims that between 1959 and 1962 he worked for employers who had collective bargaining agreements with the Union. Pl.’s Reply, Ex. 41 (Supplemental Affidavit of Ian James) at 1. As support for his position, the plaintiff relies on his own affidavit and deposition testimony, as well as his SSA earnings report. Pl.’s Suppl. Mem. at 6-8. He also relies on a copy of his SSA earnings report that contains notations by one of the defendants’ employees, purportedly identifying those employers who had collective bargaining agreements with the Union. See Pl.’s Renew. Mot., Ex. 44 (April 12, 2007 Fax from Tim Edney to Patricia Convey re Ian James with Annotated SSA Earnings Report Attached) at 2-8; see also Defs.’ Renew. Opp’n at 8 n.3 (acknowledging that “the ‘yes’ notations [on the SSA earnings report] were made by Tim Edney, a retired officer of the [IPAT] District Council 51,” and explaining that “[t]he Plan asked him to identify employers who had Local 963 Plan agreements.”). The defendants declined to credit the plaintiff for any work he performed prior to August 1, 1962. Defs.’ Renew. Opp’n at 4. While acknowledging that the SSA earnings report “shows work before 1962 with Local 963 employers,” the defendants determined that this record sheds no light on whether the plaintiffs pre-1962 work was covered “under a Local 963 [c]ollective [b]argaining [a]greement” as required by the 1971 Plan. Defs.’ Mot., Ex. 4 (March 3, 2008 Letter from Gary Meyers to Neil Intrater) at 3. The defendants added that the plaintiffs Union membership records show that he was not initiated into the Union until August 1, 1962, and reveal no payment of union dues by the plaintiff prior to this date; these records, in the defendants’ view, demonstrate that the plaintiff was not working under a Union collective bargaining agreement until August 1,1962. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3; see Defs.’ Mot., Ex. 10 (Official Membership Book of Brotherhood of Painters, Decorators, and Paperhangers) at 1 (listing the plaintiffs “Date of [Union] Initiation” as “8-1-62”). As for the plaintiffs’ testimony regarding his work under collective bargaining agreements from 1959 to 1962, the defendants found that “[t]he belated and self-serving claim of the [plaintiff] about the nature of his work at this point is insufficient to overcome the contemporaneous records.” Defs.’ Mot., Ex. 4 (March 3, 2008 Letter from Gary Meyers to Neil Intrater) at 3. The “contemporaneous records” to which the defendants referred are the Union membership records, as well as the previously discussed 1973 Pension Record, which indicates that the plaintiff accumulated 3.3 years of past service credit, see supra at 3; PL’s Mot., Ex. 13 (1973 Pension Record). The defendants determined that the 1973 Pension Record’s attribution of 3.3 past service credits to the plaintiff is consistent with past service starting from the plaintiffs Union initiation date of August 1, 1962, and ending on October 31, 1965. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3. For these reasons, the defendants found it “unlikely that [the plaintiffs work from 1959 to 1962] was covered by the collective bargaining agreement.” Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3. The Court deems the defendants’ determination reasonable. They recognized that the plaintiff worked for employers with Union collective bargaining agreements from 1959 to 1962, but found no reliable evidence that the plaintiffs work during this period was covered by those agreements such that past service credit should be awarded. The defendants further concluded that the Union membership records and 1973 Pension Record indicate that the plaintiffs work was not covered by the agreements, an inference the Court views as reasonable. The only evidence supporting the plaintiffs claimed work history under collective bargaining agreements with the Union was the plaintiffs own testimony, which the defendants deemed “belated,” “self-serving,” and outweighed by “the contemporaneous records.” Defs.’ Mot., Ex. 4 (March 3, 2008 Letter from Gary Meyers to Neil Intrater) at 3. Because the standard of review here is deferential, the Court may not “substitute [its] own weighing of the evidence for that of the administrator.” Willcox v. Liberty Life Assur. Co. of Boston, 552 F.3d 693, 702 (8th Cir.2009) (internal quotation marks and citation omitted). And although “[a] plan administrator abuses its discretion when it ignores relevant evidence,” id. at 701, or, worse yet, when it “focuse[s] on slivers of information that could be read to support a denial of [benefits] and ignore[s]—without explanation-—a wealth of evidence that directly contradict[] its basis for denying [benefits],” Metro. Life Ins. Co. v. Conger, 474 F.3d 258, 265 (6th Cir.2007) (emphasis in original), the defendants did not engage in such conduct here. They instead weighed all the evidence presented to them and offered a rational explanation of why, in their view, the plaintiff had not sufficiently proven that his work from 1959 to 1962 was performed under a collective bargaining agreement with the Union. The plaintiff asserts that from 1959 to 1961 he worked as a “journeyman ... for union employers and was covered under collective bargaining agreements with the [U]nion,” and that, during this time period, he “paid union dues,” his “union employers paid union contributions for him,” and he “received periodic union membership cards.” Pl.’s Renew. Mot. at 15. Although seemingly acknowledging that while working as a journeyman he was not formally initiated into the Union, the plaintiff contends that “even under an abuse of discretion standard, benefits cannot be denied to an employee simply because he has not yet been initiated into the union.” Id. at 16. He cites Kennedy v. Electricians Pension Plan, IBEW No. 995, 954 F.2d 1116 (5th Cir.1992), as support for his position. In Kennedy, a plan administrator denied past service credit to an employee for his work as an apprentice electrician because the work preceded his union initiation date. Id. at 1122-23. The Fifth Circuit found that the plan administrator’s reading of the plan requiring this result was unreasonable: The relevant language from the Plan ... does not support Appellants’ position that the Plan requires initiation into the Union for entitlement to past service credits. The language plainly states that employees who were active members of the “Collective Bargaining Unit” in October 1970 will receive past service credit for every year of continuous and unbroken service in the collective bargaining unit. As we read the Plan, Kennedy’s continuous membership in the collective bargaining unit between October 1950 and October 1970, entitled him to Plan coverage. There is simply no language in the Plan to support the Trustees’ interpretation. Initiation into the Union is not specified as a prerequisite for such credit. Moreover, the language that requires submission of proof of other items (i.e., dependency and successive employment) further demonstrates that the past service credits are not hinged to initiation in the union. It is undisputed that apprentices were members of the collective bargaining unit, and the facts show that Kennedy’s membership in the collective bargaining unit (through his employment with participating employers) was continuous and unbroken. For these reasons, we conclude that a fair reading of Section 4.01(b) would entitle Kennedy to past service credits. Id. (footnote omitted). The plaintiffs reliance on Kennedy is unavailing for several reasons. First, while it is true that the 1971 Plan, like the plan in Kennedy, does not make union initiation a prerequisite for past service credit, the 1971 Plan does limit past service credit to years during which an employee was “employed under collectively bargained agreements of the Union.” 1971 Plan § 2.1. The defendants here did not deny past service credit to the plaintiff solely based on the timing of his Union initiation. Rather, they determined that the plaintiff failed to present reliable evidence that he worked under Union collective bargaining agreements prior to his documented Union initiation date of August 1, 1962, and, in the absence of such evidence, they deemed it unlikely that the plaintiffs work was covered prior to his Union initiation. Second, whereas the plaintiff in Kennedy indisputably was an “active member of the ‘Collective Bargaining Unit’ ” based on his status as an apprentice electrician, 954 F.2d at 1122-23 (noting that it was “undisputed that apprentices were members of the collective bargaining unit”), it is not so clear here that the plaintiffs status as a journeyman necessarily meant he was “employed under collectively bargained agreements of the Union” within the meaning of Section 2.1 of the 1971 Plan. Here again, the only support for the plaintiffs position is his own testimony, which the defendants discredited due to other evidence they considered more convincing, a determination which this Court is not at liberty to weigh. See Willcox, 552 F.3d at 702. For the foregoing reasons, the Court concludes that the defendants reasonably denied the plaintiff past service credit for his claimed work from 1959 to 1962. 2. Past Service Credit for Work Performed from 1962 through 1965 Before addressing the defendants’ calculation of the plaintiffs past service credits from 1962 through 1965, two initial matters of Plan interpretation must be addressed. The first issue is whether the plaintiff should be granted either a full year of past service credit or no credit at all for work he performed before October 1, 1965, that did not span a full year. As previously discussed, the defendants originally accorded the plaintiff 3.3 past service credits for work from August 1, 1962, to October 31, 1965. See Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3. However, at the plaintiffs urging, the Court determined that the defendants’ attribution of 3.3 credits rested on an unreasonable interpretation of the 1971 Plan, which plainly does not permit partial credit for past service, and accordingly remanded the case to the defendants for a revised calculation of the plaintiffs past service credits. September 19, 2011 Order at 6-8. On remand by this Court, the defendants concluded that the plaintiff was entitled to only 3 years of past service credits. Pl.’s Suppl. Mem., Ex. 53 (October 13, 2011 Letter from Kent Cprek to Neil Intrater) at 4-5. Although the plaintiff challenges this conclusion by contending that the 1971 Plan provides for a full year of past service credit for any part of a year worked under a collective bargaining agreement prior to October 1, 1965, PL’s Suppl. Reply at 5, the Court has already determined that 1971 Plan provision concerning past service credit is ambiguous, and that, under one reasonable reading of that provision, “an employee is required to work for a full year in order to receive one year of past service credit.” September 19, 2011 Order at 5 (emphasis added). Because the defendants have essentially adopted this reasonable interpretation of the 1971 Plan’s past service credit provision, the plaintiffs challenge to it must be rejected. The second issue of Plan interpretation concerns the calculation of service credit for work performed in October 1965. The 1971 Plan grants one year of past service credit for each “fiscal year” before October I, 1965, that an employee worked under a Union collective bargaining agreement, 1971 § 2. 1, and a “fiscal year” is defined as “the period from November 1, through October SI,” id. § 1.9 (emphasis added). But the 1971 Plan also provides future service credit for work performed after October 1, 1965. Id. § 2.2. This language suggests that certain employees are entitled to both past and future service credit for work performed in October 1965. For example, if an employee worked from November 1, 1964, to October 31, 1966, that employee would be entitled to past service credit for November 1, 1964, to October 31, 1965, and future service for October 1, 1965, to October 31, 1966, thus granting the employee double credit for October 1965. The defendants found that the 1971 Plan required such an award of double credit for the plaintiffs work in October 1965. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3; see also Defs.’ Renew. Mem. at 18 (stating that “[t]he Trustees found that work in October 1965 counts toward past and future service ... This somewhat odd result is commanded by the 1971 Plan document.” (emphasis in original)). The plaintiff does not directly respond to this contention, but the Court agrees with the defendants that the 1971 Plan’s terms compel the conclusion they reached. The Court’s focus thus turns to the reasonableness of the defendants’ past service credit calculation. The defendants awarded 3 years of past service credit to the plaintiff for work starting on his August 1, 1962 Union initiation date and ending on October 31, 1965, the “fiscal year” end-date. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3; Pl.’s Suppl. Mem., Ex. 53 (October 13, 2011 Letter from Kent Cprek to Neil Intrater) at 4-5. The plaintiff was therefore credited for work starting in November 1, 1962, and ending on October 31, 1965. This calculation is supported by the Union membership records, which show an August 1, 1962 initiation date, and the 1973 Pension Record, which lists the plaintiff as having 3.3 past service credits. Consistent with the defendants’ reasonable interpretation of the 1971 Plan’s ambiguous past service credit provision, 0.3 credits were omitted from the 3.3 figure found in the 1973 Pension Record because partial credit is not granted for past service and employees had to work a full year to earn 1 past service credit. Because an award of 3 years past service credit is supported by the record evidence and because the Court discerns no error in the defendants’ resolution of the 1971 Plan’s ambiguous provisions, the Court deems the defendants’ past service credit calculation reasonable. The plaintiff critiques the defendants’ reliance on the 1973 Pension Record, asserting that the document is “patently incorrect” because it grants partial credit for past service, even though the 1971 Plan plainly does not permit partial past service credit. Pl.’s Renew. Mot. at 9-10. To be sure, the past service credit calculations in the 1973 Pension Record appear to reflect file defendants’ prior, mistaken belief that the 1971 Plan allows partial years for past service, insofar as the record lists past service credits as decimal numbers rather than whole numbers. See Pl.’s Mot., Ex. 13 (1973 Pension Record). But that does not render the record utterly worthless. On the contrary, the 1973 Pension Record is one of the few contemporaneous records available in this case, and while its past service credit figures may rest on an erroneous interpretation of the 1971 Plan, there is no indication that the data contained therein is factually inaccurate, or that the document is inauthentic. Furthermore, the record’s attribution of 3.3 years of past service credit to the plaintiff is corroborated by the record in this case, as it reflects service starting on the plaintiffs documented Union initiation date of August 1, 1962, and ending on October 31, 1965, the “fiscal year” end-date under the 1971 Plan. See Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 3 (explaining that “[t]he time from August 1, 1962 ... to October 31, 1965 ... would be three (3 years) and three months, or 3 and 3/12 years. This would be 3.25 years in decimal terms that would round up to 3.3 years for records kept in 1/10 years.”). The Court also views as reasonable the defendants’ explanation of why they generally rely on such plan records in making benefits determinations. See id. (stating that “[t]he Trustees’ inclination is to rely on plan records, particularly if they are consistent with other records, as the best basis for uniform treatment of all employees. Absent some indication that the Local 963 Plan record is clearly erroneous, the Trustees are not inclined to try to re-create the distant past based on [the plaintiffs] claims alone.”). Because the Court agrees that the 1973 Pension Record does not appear to be “clearly erroneous,” id, it cannot fault the defendants for relying upon it. 3. Future Service Credit for Work Performed from 1965 through 1972 Having found that the defendants reasonably attributed 3 years of past service credit to the plaintiff, the Court next examines the defendants’ award of future service credit. Relying on the 1973 Pension Record and the plaintiffs SSA earnings report, the defendants awarded the plaintiff 6.2 years of future service credit. Defs.’ Mot., Ex. 4 (March 3, 2008 Letter from Gary Meyers to Neil Intrater) at 3; Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 4. This award covers work from October 1, 1965, to some unspecified date in April 1972. Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 4. The plaintiff does not appear to raise any specific challenge to the defendants’ future service credit award of 6.2 years. In their July 9, 2010 benefits determination letter, the defendants stated that they understood the plaintiff “not [to] contest the future service calculation of 6.2 years of (contributory) service, except to claim an additional 1.58 years of future service credit. This credit is partially in 1972, but more importantly in 1979 and 1980.” Id. For 1972, the plaintiff sought a “full year of credit.” Id.; see also Defs.’ Mot., Ex. 35 (April 18, 2007 Fax from Neil Intrater to Gary Meyers) at 4 (claiming entitlement to “1.00” credit for work in 1972 with “F & M Shaeffer/Beltway Glass”). The defendants declined to grant such credit because the 1973 Pension Record “already show[s] 0.8 years of credit for 1972,” and, in any event, “0.2 years credit would not create vested rights.” Defs.’ Renew. Mem., Ex. 45 (July 9, 2010 Letter from Gary J. Meyers to Neil Intrater Re: Ian James Benefit Appeal) at 4. As previously stated, the Court does not view the defendants’ reliance on the 1973 Pension Record as unreasonable, and it therefore finds no error in their determination that the plaintiff was entitled to 0.8 years of credit for 1972 rather than 1.0 credit. The Court also agrees with the defendants’ conclusion that, even if the plaintiff were granted an additional 0.2 service credits, he would still fall short of the 10 service credits required for vesting. In sum, the defendants reasonably concluded that the plaintiff was entitled to 3 past service credits for years 1962 through 1965 and 6.2 future service credits for years 1965 through 1972, for a total of 9.2 service credits. It follows that the plaintiff does not have a vested pension under the 1971 Plan since he did not accrue 10 years of service credit prior to his acknowledged break in service from 1973 to 1978. Under the plain language of the 1971 Plan, the plaintiff lost all service credit, both past and future, upon this break in service. See 1971 Plan § 2.3. Summary judgment as to the plaintiffs wrongful denial of benefits claim will accordingly be granted in the defendants’ favor. 4. The Adequacy of the Defendants’ Explanation for Denial of Benefits The plaintiff asserts that the defendants have failed to provide him with an “understandable explanation for the denial of benefits” in violation of 29 U.S.C. § 1133. 3d Am. Compl. ¶ 39. This section of the ERISA directs that “every employee benefit plan” must (1) provide adequate notice in writing to any participant or beneficiary whose claim for benefits under the plan has been denied, setting forth the specific reasons for such denial, written in a manner calculated to be understood by the participant, and (2) afford a reasonable opportunity to any participant whose claim for benefits has been denied for a full and fair review by the appropriate named fiduciary of the decision denying the claim. 29 U.S.C. § 1133. The Department of Labor’s regulations adopted to implement this statutory directive requires plan administrators to provide written notification to a claimant of “any adverse benefit determination” setting forth in a manner calculated to be understood by the claimant ... (i) [t]he specific reason or reasons for the adverse determination; (ii) [Reference to the specific plan provisions on which the determination is based; (iii) [a] description of any additional material or information necessary for the claimant to perfect the claim and an explanation of why such material or information is necessary. 29 C.F.R. § 2560.503—1(g)(1). The District of Columbia Circuit has established the following standards for evaluating alleged violations of Section 1133: Along with our sister circuits, we have adopted the “substantial compliance” test to determine whether denial notices comply with section 1133 and the regulation. See Heller v. Fortis Benefits Ins. Co, 142 F.3d 487, 493 (D.C.Cir.1998). Technical noncompliance will be excused as long as the notice substantially complies with the statute and regulation. See id. In assessing whether a notice substantially complies, we consider not just the notice itself, but all communications between the insurance company and the claimant. See id. Courts make the substantial compliance determination on a case-by-case basis, assessing the information provided by the insurer in the context of the beneficiary’s claim. Heller is typical: [Ajlthough the initial letter from [the insurer] informing [the claimant] of the denial of her disability benefits did not conform to the requirements o