Michigan › Manufacturing › 25,000 or more participants
Form 5500 statement · plan year 1 Jan 2024 to 31 Dec 2024
Dow Employees' Pension Plan
Sponsored by The Dow Chemical Company, Midland, MI
Form 5500 information is as filed by the plan administrator with the Department of Labor and may be amended. Figures reflect the plan year shown, not current balances. Form 5500 contains no individual account balances. Look up the original filing at EFAST2.
Dow Employees' Pension Plan is a cash balance pension plan sponsored by The Dow Chemical Company of Midland, Michigan. For the plan year ending 31 Dec 2024 it reported 31,955 participants, 6,414 of them active, and net assets of $10.7B.
Net assets came to $334,598 per participant, well above the $88,040 median for defined benefit plans with 25,000 or more participants and well above the $67,961 median for defined benefit plans in manufacturing. The figure is an average across everyone in the plan, including former employees with small balances; Form 5500 holds no individual account data.
Schedule C lists 15 service provider organisations paid $5,000 or more, with reported compensation of $17.0M: $531 per participant, well above the same-size median of $143. Administrative expenses charged to the plan were $38.8M. Schedule C does not capture every cost: fees netted from fund returns and fees the employer pays directly are outside it.
Across the filings on record, net assets went from $6.17B in 2009 to $10.7B in 2024 (up 73%), and participants from 47,223 to 31,955 (down 32%).
The independent accountant's opinion on the financial statements was unmodified (unqualified), from an audit whose scope was limited under ERISA section 103(a)(3)(C) to exclude investment information certified by a bank or insurer.
Compared with similar plans
| Measure | This plan | Same size | Same industry | All US DB plans |
|---|---|---|---|---|
| Net assets per participant | $334,598 | $88,040 | $67,961 | $86,221 |
| Employer contributions per active participant | — | $6,524 | $6,915 | $10,244 |
| Schedule C compensation per participant | $531 | $143 | $299 | $344 |
| Schedule C compensation, share of net assets | 0.16% | 0.26% | 0.47% | 0.42% |
| Administrative expenses per participant | $1,213 | $306 | $498 | $527 |
Peer columns are medians for plan year 2024 across defined benefit plans with 100 or more participants: 25,000 or more participants (215 plans), manufacturing (1,532) and all US plans (5,308). Fee medians cover plans that report an amount.
Trend by plan year
| Plan year | Participants | Net assets | Per participant | Employer contributions | Participant contributions | Schedule C compensation |
|---|---|---|---|---|---|---|
| 2024 | 31,955 | $10.7B | $334,598 | — | — | $17.0M |
| 2023 | 32,244 | $11.4B | $354,494 | — | — | $15.6M |
| 2022 | 47,861 | $12.9B | $269,120 | — | — | $13.6M |
| 2021 | 52,535 | $16.5B | $314,539 | — | — | $16.7M |
| 2020 | 52,946 | $15.4B | $290,587 | $455M | — | $8.6M |
| 2019 | 60,342 | $14.5B | $240,333 | — | $4.1M | $10.8M |
| 2018 | 61,089 | $13.0B | $213,300 | $800M | $3.6M | $7.4M |
| 2017 | 61,151 | $13.5B | $221,504 | $450M | — | $10.5M |
| 2016 | 61,223 | $12.1B | $197,861 | $14.5M | — | $14.0M |
| 2015 | 53,099 | $10.5B | $198,165 | $304M | — | $8.1M |
| 2014 | 48,670 | $9.52B | $195,672 | $603M | — | $8.3M |
| 2013 | 48,586 | $8.77B | $180,543 | $386M | $0 | $7.9M |
| 2012 | 48,490 | $7.97B | $164,394 | $251M | — | $12.9M |
| 2011 | 47,517 | $7.28B | $153,172 | $466M | — | $26.1M |
| 2010 | 47,201 | $7.07B | $149,873 | $556M | — | $23.2M |
| 2009 | 47,223 | $6.17B | $130,596 | — | $2.2M | $19.1M |
Years in which the plan filed the full Form 5500 with 100 or more participants, from 2009. Plan year is the year in which the plan year began.
Statement for the year
- Net assets, beginning of year$11,430,302,826
- Employer contributions—
- Participant contributions—
- Rollovers and other contributions—
- Total contributions$0
- Total income, including investment results−$36,975,719
- Benefits paid$663,816,582
- Administrative expenses$38,757,966
- Total expenses$702,574,548
- Net income−$739,550,267
- Net transfers$1,326,966
- Net assets, end of year$10,692,079,525
Participants
- Active participants6,414
- Retired or separated, receiving benefits13,241
- Retired or separated, entitled to future benefits10,786
- Total participants, end of year31,955
Fees and service providers
| Organisation | Services reported | Direct | Indirect |
|---|---|---|---|
| Willis Towers Watson | Actuarial; Plan Administrator; Consulting (pension) | $5,767,278 | $0 |
| Neuberger Berman Investment Adviser | Investment management | $2,085,684 | $0 |
| The Northern Trust Company | Trustee (bank, trust company, or similar financial institution); Trustee (directed) | $1,811,899 | $0 |
| Nisa Investment Advisors LLC | Investment management | $1,664,566 | $0 |
| The Dow Chemical Company | Plan Administrator | $1,052,221 | $0 |
| Adenza, Inc. | Consulting (general); Other services | $758,452 | $0 |
| Covington & Burling LLP | Legal | $639,644 | $0 |
| Goldman Sachs Asset Management, LP | Investment management | $627,262 | $0 |
| Ramirez Asset Management | Investment management | $442,754 | $0 |
| Bloomberg Finance L.P. | Direct payment from the plan; Other fees | $406,175 | $0 |
| BDO USA, P.C. | Accounting (including auditing) | $388,211 | $0 |
| McUbe Investment Technologies LLC | Recordkeeping and information management | $338,463 | $0 |
Schedule C, Part I line 2: providers that received $5,000 or more, with the form's own service codes. 3 smaller rows are not shown. Individuals named on Schedule C (plan employees, individual trustees) are never shown and their compensation is excluded. Eligible indirect compensation disclosed by formula carries no dollar amount. See how to read Schedule C fees.
Administrative expenses on Schedule H
- Other administrative expenses$26,482,715
- Actuarial fees$5,767,278
- Investment advisory and management fees$5,082,691
- Recordkeeping fees$542,428
- Trustee and custodial fees$476,679
- Valuation and appraisal fees$406,175
- Total administrative expenses$38,757,966
Investment structure
Assets at year end by Schedule H category. The form shows the kind of vehicle holding the money, not the funds on the menu.
- Master trust investment accounts$4.78B · 43.1%
- Partnership/joint venture interests$2.98B · 26.9%
- Corporate debt instruments$1.18B · 10.6%
- U.S. Government securities$693M · 6.3%
- Cash (interest and non-interest bearing)$508M · 4.6%
- Common/collective trusts$352M · 3.2%
- Corporate stocks$212M · 1.9%
- Receivables$202M · 1.8%
- Real estate$95.0M · 0.9%
- Registered investment companies (mutual funds)$75.6M · 0.7%
Audit and compliance answers, as filed
- Accountant's opinionUnmodified (unqualified)
- Audit scope limited under ERISA section 103(a)(3)(C)Yes
- Accounting firmBDO USA, P.C.
- Participant contributions reported as transmitted lateNo
- Covered by a fidelity bondYes, $15,000,000
- Blackout period during the year—
These are the plan administrator's own answers on Schedule H, Part IV. A reported late transmittal is the filer's disclosure of a timing lapse, usually corrected through the Department of Labor's voluntary program; the amount is the total involved, not a loss.
Plan characteristics
1ABenefits are primarily pay related1BBenefits are primarily flat dollar (includes dollars per year of service)1CCash balance or similar plan1ECode section 401(h) arrangement3FPlan sponsor(s) received services of leased employees3HPlan sponsor(s) is (are) a member(s) of a controlled group
Codes entered on Form 5500 line 8a, with the labels from the official instructions. Business code 325100: Basic Chemical Mfg.
Other plans of The Dow Chemical Company
| Plan | Participants | Net assets |
|---|---|---|
| The Dow Chemical Company Employees' Savings Plan | 31,053 | $11.5B |
| Dow Employees' Pension Plan (Personal Pension Account) | 11,463 | $401M |
Similar plans in Michigan
| Plan | Sponsor | Participants | Net assets | Per participant |
|---|---|---|---|---|
| Ford Motor Company General Retirement Plan | Ford Motor Company | 54,619 | $12.1B | $221,718 |
| Union Carbide Employees' Pension Plan | Union Carbide Corporation C/o the Dow Chemical Company | 31,806 | $2.13B | $66,818 |
| Fca US LLC UAW Pension Agreement | Fca US LLC | 98,708 | $10.3B | $103,895 |
| General Motors Salaried Retirement Program | General Motors LLC | 24,871 | $3.46B | $139,203 |
| Ford Motor Company UAW Retirement Plan | Ford Motor Company | 138,666 | $17.8B | $128,605 |
| Whirlpool Tammy Employees Pension Plan | Whirlpool Corporation | 24,197 | $1.75B | $72,162 |
Defined benefit plans in manufacturing closest in size.
Questions and answers
How big is Dow Employees' Pension Plan?
31,955 participants at the end of the plan year ending 31 Dec 2024, of whom 6,414 were active employees, with net assets of $10,692,079,525. Among defined benefit plans that places it in the 25,000 or more participants band, which held 215 plans in plan year 2024.
What does The Dow Chemical Company contribute per participant?
This filing has no Schedule H financial statement, so employer contributions are not reported here.
What fees does the plan pay and how do they compare?
Schedule C reports $16,955,533 in compensation to service provider organisations, $531 per participant or 0.16% of net assets. The same-size median among plans reporting any Schedule C compensation was $143 per participant. Administrative expenses on Schedule H were $38,757,966. Investment costs deducted inside mutual funds and other pooled vehicles are not itemised on Form 5500, so these figures are a floor rather than a full cost.
Who runs the plan?
The sponsor is The Dow Chemical Company. Recordkeeping or administration: Willis Towers Watson, The Dow Chemical Company and McUbe Investment Technologies LLC. Investment advisory or management: Neuberger Berman Investment Adviser, Nisa Investment Advisors LLC and Goldman Sachs Asset Management, LP. Trustee or custodian: The Northern Trust Company. The financial statements were audited by BDO USA, P.C.. Form 5500 also names the plan administrator's signer and other individuals; this site publishes organisations only.
Was the audit opinion unqualified?
The filing reports an unmodified (unqualified) opinion from a limited-scope audit, in which the accountant did not audit investment information certified by a bank or insurance company. Unmodified (formerly "unqualified") is the standard clean opinion.
How current is this, and does it show my balance?
This is the Form 5500 for the plan year 1 Jan 2024 to 31 Dec 2024, received by the Department of Labor on 8 Oct 2025. Filings are due seven months after the plan year ends, or nine and a half with an extension, so the public record always runs a year or more behind. It contains plan-level totals only: no individual balances, contributions or names of participants exist in the data.
Provenance
Source: U.S. Department of Labor, Employee Benefits Security Administration, Form 5500 research files (Form 5500, Schedule H, Schedule C) for plan years 2009 to 2025, public domain, with filings received through 24 Aug 2026. This page shows the latest filing on record for EIN 38-1285128, plan 001, received 8 Oct 2025; an amended filing replaces it at the next build. Medians and percentiles are computed by this site; see the methodology. Report an error through corrections.