Both the 2009 Amendments and the debits to the Excess COLA Account violated the Rules. TVA’s arguments ignore critical language in the Rules and persuasive authority from the Sixth Circuit. The material facts are undisputed, and Plaintiffs are entitled to judgment as a matter of law. First, the TVARS Board violated Rules § 13 by not giving “at least 30 days’ notice of the proposed amendment” to plan participants. TVARS waited to give notice until after it took the final vote. At that point, the 2009 Amendments were no longer merely “proposed,” and plan participants did not have a chance to petition the Board. Second, the 2009 Amendments reduced benefits in violation of Rules § 13 in two separate ways. The COLAs at issue were already “covered by accumulated reserves held therefor,” the Excess COLA Account. The interest rate credited to existing balances in the Annuity Savings Account was a “nonforfeitable” or vested benefit. Third, the TVARS Board violated Rules §§ 9.B.6 an...