had reached age 55, in order to make them eligible for benefits (Katz Aff. Ex. 45), establishes that Pan Am in fact interpreted its Plan as requiring employees to have reached the age of 55 to receive subsidized benefits, regardless of how their employment ended. If the Plan provided the subsidized benefit to employees involuntarily terminated before age 55, there would have been no need to re-hire laid-off employees after that age to qualify them for benefits. Pan Am’s generosity in accommodating laid-off employees to allow them to receive higher benefits was completely gratuitous, and could not have resulted in an obligation on Pan Am’s part to employ this practice with every employee, or in a modification of the Plan’s terms. See Perreca v. Gluck, 295 F.3d 215, 224-25 (2d Cir.2002) (<HOLDING>). Thus, PBGC’s interpretation of the Plan’s
recognizing that pension plan administrators have the ability to fashion their own plan formulas holding that employer may not orally modify a pension plan and citing 29 usc  1102a1 which provides that all plan terms must be in writing holding that plan participants in a defined benefit pension plan have no claim to the plans surplus assets holding that plan language giving plan administrator power to determine which employees are eligible to participate in the plan and providing all parties dealing with the plan an interpretation of plan provisions on request indicates deferential standard of review of trustee eligibility decisions holding that the defendant withheld pension benefits in breach of the plan