08.10.26
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What About Those Mass Withdrawal Applicants?

By: Russ Kamp, CEO, Ryan ALM, Inc.

As regular readers of this blog know, I report weekly on the PBGC’s effort to implement the ARPA pension legislation. In those frequent updates I’ve reported that there are currently 81 pension funds that were placed on the waiting list and described as having been impacted by mass withdrawal prior to 2020. One of those pension funds, Retirement Plan of Local 1102 Retirement Fund is the first SFA candidate invited to submit an application. I’ve asked, is this a unique situation or are the others likely to follow?

After much reading on the subject, Local 1102 is unique as the first plan from the pre-2020 mass-withdrawal group to be invited to submit a full SFA application, but I believe that it won’t be the last. The critical development behind Local 1102’s advancement to being under review, is the litigation involving Bakery Drivers Local 550 and the Supreme Court’s May 18, 2026, decision not to review the Second Circuit ruling from April 2025.

The PBGC’s original position related to the “mass withdrawal” plans was clear: “a multiemployer plan that terminated by mass withdrawal before the 2020 plan year generally could not qualify for SFA because the funding-status rules used to establish “critical and declining” status no longer applied after termination.” The PBGC made its position quite clear in its 2022 final rules.

However, that interpretation was challenged by the Bakery Drivers Local 550 and Industry Pension Fund after initially being denied the opportunity to submit its application in January 2023. The Second Circuit ruled against PBGC in April 2025. The case involved a plan that terminated by mass withdrawal in 2016 but subsequently resumed activity and asserted that it was again in critical-and-declining status. The Second Circuit concluded that PBGC’s treatment of the prior termination was wrong.

Not surprisingly, the PBGC then asked the Supreme Court to hear the case. On May 18, 2026, the Supreme Court denied “certiorari*”, leaving the Second Circuit decision standing. That timing is significant when viewed alongside what happened next. As I mentioned in my July 24 ARPA update, the PBGC invited the Retirement Plan of Local 1102 Retirement Fund to submit an application, which I mentioned was the first of the 81 plans on the waiting list categorized as “Plan Terminated by Mass Withdrawal before 2020 Plan Year” to be invited to submit a grant application.

This may not be the opening of the flood gates, as I asked in that same blog post. The Local 550 decision does not necessarily mean that every plan terminated by mass withdrawal before 2020 is now eligible, as there can still be plan-specific questions about whether a multiemployer pension fund satisfies one of ARPA’s statutory eligibility tests. For instance, the Local 550 litigation involved the additional claim that the fund claimed it had effectively been “restored” after its 2016 termination.

Given that reality, the PBGC still has room to evaluate each applicant’s particular situation. That said, the PBGC’s says it will provide every eligible plan an opportunity to file, subject to its ability to process applications within the statutory 120-day review period. When capacity opens, the PBGC contacts plans at the top of the waiting list and permits them to file.

The pace of grant application submissions could still be slow because PBGC meters applications based upon its capacity to complete the 120-day review. As mentioned in my weekly update as of August 7, 2026, there are currently 14 pension funds under “review”. I would be very surprised if Local 1102 proved to be the only one of the 81 plans invited to apply.

I don’t know how much these additional plans may ultimately receive, but I do know that many American workers will now receive the benefits that they were initially promised. That is only fair.

* If a court denies Certiorari, it usually does not mean it agrees with the lower court’s ruling, it simply declines to review the case.

08.10.26
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ARPA Update as of August 7, 2026

By: Russ Kamp, CEO, Ryan ALM, Inc.

So, how was your weekend? Ours was a bit crazy, as we welcomed two new granddaughters into the family. Both girls – not twins – were born on Friday, August 7th, 3 1/2 hours and three rooms apart at the same hospital! My wife and I are now blessed with 13 grandkids! It was quite the weekend.

Regarding ARPA, I’m pleased to report that the PBGC continues to invite more plans to submit applications for the SFA grant, including Bakery Drivers Local 550 and Industry Pension Fund, that was denied the opportunity to submit an application due to ineligibility initially in January 2023 and then again September 2025. They have now been able to file again due to the Supreme Court declining to review the Second Circuit Courts ruling. Will the third time prove to be the charm?

There are currently 14 funds in the queue to have their applications reviewed by the PBGC. These 14 funds are seeking $569 million in SFA for >25k American workers and retirees.

There is little to report outside of the two additions to the waitlist, as no applications were approved, denied, or withdrawn. Furthermore, neither of the two additions under review came from the waitlist. There remains only one application under review from the roughly 80 mass withdrawal candidates. I’ll provide more on this subject in a separate blog post.

U.S. interest rates continue to rise as Middle East uncertainty roils oil markets fueling inflation concerns. We recently completed an analysis for a pension plan that asked us to defease 30-years of liabilities. The YTM on that portfolio was 6.03% – incredible! That’s 6% for the life of the program no matter what happens to oil, inflation, interest rates, equity markets, etc.

08.06.26
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Is Your Asset Allocation Responsive?

By: Russ Kamp, CEO, Ryan ALM, Inc.

We are happy to share with you Ron Ryan’s latest thoughts related to asset allocation and how it should be responsive and not strategic. We at Ryan ALM, Inc. have witnessed many investing cycles during our decades in the pension industry. We have seen well-funded defined benefit pension plans witness their funded status/ratio deteriorate quickly as markets retrenched. As Ron highlights in his latest thoughtful piece, public pension plans have made terrific strides to improve funding from roughly 71% to a recent high of 88.7% according to Milliman.

Given the improved funding, are U.S.-based pension plans de-risking? Unfortunately, no. They continue to operate with an objective to maximize the return on the assets and not with the more appropriate objective to SECURE the promises made to their members. The former objective continues these plans on a rollercoaster of returns. Regrettably, a return focus only guarantees volatility: volatility of returns leading to volatility of contributions and ultimately the funded status of the plan. It makes little sense.

Adopting an objective that is focused on securing the pension promises creates an element of certainty within the management of pensions not often found, if at all. By securing the promises, one dramatically improves the liquidity needed to meet those monthly obligations. It also creates a longer investing horizon for the assets not used to meet the plan’s liquidity.

We believe that Cash Flow Matching (CFM) is the only strategy that creates the necessary liquidity with certainty, as the asset cash flows of principal and interest are matched to the liability cash flows of benefits and expenses. There is no sweeping of the dividends and capital distributions, which should be reinvested in the products with higher potential returns and NOT used for distributions to beneficiaries.

As your plan’s funded status improves, respond by allocating more of the plan’s assets to CFM. Don’t let your winnings ride. Take risk form the plan’s asset allocation in a responsive way to positive changes in the plan’s funded status. Markets have been producing outsized positive returns, but standard deviations measure both upside and downside possibilities. Is your plan’s sponsor able to withstand a major market correction similar to what we’ve seen previously (2000-’02 and 2007-’09)? Will the likely increase in contributions be crushing?

Who knows what is going to happen with interest rates, inflation, the price of oil, equity markets, etc. Bringing some certainty to pension management should be everyone’s objective. If done correctly, everyone will be able to sleep well at night knowing that your future promises have been secured no matter what transpires in markets that remain out of our control.

08.04.26
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Really, WSJ?

By: Russ Kamp, CEO, Ryan ALM, Inc.

The WSJ’s editorial board recently published an article based on a new report from Equable Institute highlighting AI’s positive contribution to public pension plans (public workers) and the taxpayers that fund the pensions. This assessment is based on the fact that the AI “market boom” specifically and NASDAQ’s performance generally have continued to generate outsized returns despite so much global uncertainty.

The market’s strong performance has boosted the funded ratios of government pension funds, which Equable estimates hit 85% nationwide this year—the highest level since 2007. Equable estimates that roughly 8% to 10% of government pension funds are benefiting from their investments in about 50 publicly traded AI-related companies. Their analysis doesn’t include investments in privately managed funds that own stakes in private AI companies like OpenAI and Anthropic. 

Equable highlighted the fact that while AI is yielding positive returns for pension funds, the magnitude of the outperformance also bears a warning. They claim that nearly 32% of every $ going into a pension plan is paid by the employers (aka taxpayer), and that should the AI bubble burst, it could lead to significantly higher taxpayer contributions. The WSJ stated that some AI company valuations may be stretched in the current boom and could be in for a correction. They also mentioned that government policies that seek to slow AI including robot taxes and data-center moratoriums—could stifle the boom. 

If that correction becomes reality, taxpayers would be stuck paying much bigger pension bills, which could force worker layoffs as happened after the 2008-09 Great Financial Crisis. They claim that it would be better for governments to move workers to 401(k)-style plans that reduce the risk for taxpayers and give public workers a direct stake in the success of AI and other companies. 

So let me get this straight: the WSJ editorial board is concerned that a potential AI correction might just happen because of stretched valuations leading to greater taxpayer funded contributions, so to minimize that potential risk, it would be better to shutter public pension plans and force public sector workers into DC-like programs. If they are concerned that valuations are stretched perhaps leading to a correction, why would they want public workers to have a direct stake in the “success” of AI and other companies?

I’m sorry, have the folks at the Journal not seen the median account balances for those in DC-styled plans? Do they understand that asking workers – public or private – to fund, manage, and then disburse a “retirement” benefit with little disposable income, no investment acumen, and no crystal ball to help with longevity issues is just silly? Do they not also realize that the public sector workers (roughly 20 million) pay taxes, too. They also buy things which leads to economic activity and job growth. Do we really want our Senior population sitting on the economic sidelines because they can no longer afford to participate? We’ve already messed up retirement for a good portion of the private sector. Enough is enough!

08.03.26
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ARPA Update as of July 31, 2026

By: Russ Kamp, CEO, Ryan ALM, Inc.

Welcome to August!

The PBGC remains busy implementing the ARPA pension legislation. Last week saw two funds submit revised applications for Special Financial Assistance (SFA), one receive approval of its revised application, and another fund withdraw their application.

Ironworkers’ Local 340 Retirement Income Plan, an Oak Brook, IL construction union, will receive $47.8 million in SFA plus interest for its 819 members. While Local 340 was celebrating, Local 1430 I.B.E.W. Pension Plan and International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Local No. 79 Pension Fund were resubmitting their SFA applications. Collectively, they are hoping to secure $19.6 million in SFA for the 837 plan participants.

Seattle, WA-based Pension Plan of the Automotive Machinists Pension Trust will once again go back to the drawing board, as they’ve withdrawn an already revised application seeking SFA in the amount of $139.1 million for nearly 7,500 members.

As has been the case, no SFA recipients were asked to rebate a portion of their grant due to census errors. There has not been a request to do so since September 2025. In addition, no additional “Mss Withdrawal” applicants submitted an SFA application this week. Eighty plans remain as potential SFA recipients with only one fund currently going through the process.

Despite the slight pullback in U.S. interest rates due to a “pause” in the Middle East conflict, activity last week drove rates to highs not achieved since before the GFC. These elevated rates will help plan sponsors reduce significantly the cost to fund future benefits.

07.31.26
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Why wait?

By: Russ Kamp, CEO, Ryan ALM, Inc.

Due to great uncertainty brought on by the conflict in the Middle East and the war’s potential impact on the price of oil ($85.63 at 10:01 EST) that could drive inflation higher, U.S. long-dated Treasury yields continue to rise. In fact, the U.S. 30-year Treasury yield has not been this high (5.26%) since July 6, 2007, when the yield was at 5.28%. Where yields go from here is anyone’s guess, but I will share that oil, as represented by WTI, has risen 24.9% since June 30, 2026. Given the exposure that oil or oil-derived inputs have in more than 6,000 products, the significant rise in the recent price could impact inflation for quite some time, even if oil soon began to flow more freely.

We recently saw the average 30-year BBB+ bond trading at 110 bps above the prevailing 30-year Treasury. If that relationship is maintained, pension plans could potentially cover most of their desired return on asset (ROA) annual target (average public pension plan has a 6.75% ROA) through bonds. Should inflation spike once again, there is no telling how high U.S. interest rates could rise. Despite domestic equity’s apparent immunity to market fundamentals and geopolitical risks, there will come a time when higher U.S. yields become too attractive to ignore leading to the potential for rebalancing out of equities into fixed income. That action will likely lead to lower equity prices and falling bond yields.

So, I ask, why wait? Why wait to take risk from your current asset allocation before the markets act? Why not SECURE your benefit promises through cash flow matching (CFM) well into the future and reduce the volatility related to returns, contributions, and funded status? Why not take advantage of very attractive bond yields? As a reminder, core, active fixed income strategies are highly interest rate sensitive. Rising yields negatively impact bond prices, as seen in the performance of the Aggregate Bond Index, which is up only 0.1% annually for the 5-years ending June 30, 2026. However, a CFM strategy, which secures benefits that are future values, eliminates interest rate risk, as future values are not interest rate sensitive.

Public pension plans have done a good job of improving their funded ratios since bottoming after the Great Financial Crisis but remain only one market crash away from repeating this vicious cycle. Get off the performance rollercoaster. Secure your promises chronologically for some period into the future (your plan’s funded status should dictate the allocation). You and your participants will sleep much better knowing that the promises made will be kept.

07.30.26
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Milliman Provides Public Pension Funding Update

By: Russ Kamp, CEO, Ryan ALM, Inc.

Milliman released the latest results of its monthly Public Pension Funding Index (PPFI). As a reminder, Milliman analyzes and reports on data from the nation’s 100 largest public DB pension plans.

For June, Milliman’s PPFI constituents produced an estimated aggregate return of -0.1%, which when incorporated with the anticipated benefit accruals reduced the collective funded status by $30 billion. As a result of the -0.1% return, assets for the index declined during the month from $6.129 trillion as of May 31 to $6.116 trillion. Concurrently, the PPFI plan liabilities rose to $6.894 trillion during the period, resulting in a funded ratio of 88.7% as of June 30, a -0.4% decline from 89.1% as of May 31.

“While June’s slight investment decline caused the PPFI funded ratio to slip from the indexes all-time high, public pension plans have enjoyed strong returns so far in 2026, with plan assets up 6.2% from January 1 to June 30,” said Ryan Falls, co-author of the Milliman PPFI. Falls also reported that “half of the 100 largest public pensions continue to have funded ratios eclipsing 90%, unchanged from the end of May, while only 10 plans are less than 60% funded”. Despite recent improvement in the overall funded status/ratio of public pension defined benefit plans, they are still significantly below levels achieved in 2000 prior to two costly equity market corrections.

You can access the monthly report below.

View the Milliman 100 Public Pension Funding Index.

07.29.26
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There Is No “One Size Fits All” Asset Allocation

By: Russ Kamp, CEO, Ryan ALM, Inc.

I recently attended a public pension conference in which the following question was asked by the moderator: Should public pension funds once again adopt a 60%/40% asset allocation framework? As a reminder, there may be an average exposure that results from a review of all public fund data, but there is NO such thing as an appropriate or standard asset allocation. Given that every defined benefit plan has its own unique liabilities, funded status/funded ratio, different workforces, ability to contribute, etc., how could there be a standard exposure to any asset class, let alone a standard 60% equity/40% fixed income allocation.

I’m sure that this question originates through the belief that the pension objective is to achieve a return on asset (ROA) assumption, as if there is some magic combination of assets and weightings that will enable the pension plan to achieve the return target. However, as regular readers of this blog know, we, at Ryan ALM, think that the primary objective when managing a DB pension plan is NOT a return objective but it is to SECURE the promised benefits at a reasonable cost and with prudent risk.

Pursuing a return objective guarantees volatility – volatility of returns, contributions, and funded status. It does not guarantee success! Regarding the volatility of returns, the annual standard deviation for a pension plan’s asset allocation is roughly 12%-15%. Refocusing on the plan’s unique liabilities secures, through cash flow matching (CFM), the monthly promises (benefit payments) from the first month out as far as the allocation will cover. Through this process the necessary liquidity is provided each month, while also providing the additional benefit of extending the investing horizon for the remainder of the assets that are no longer needed as a source of liquidity. We refer to these residual assets as the alpha or growth assets that now can grow unencumbered.

These growth assets can be invested almost anyway that you want. You can decide to just buy the S&P 500 index at low fees or construct a more intricate asset allocation with exposures and weightings of your choice. Again, there is no one size fits all solution. We do suggest that the better the funded ratio/status of your plan, the greater the allocation to the CFM strategy. If your plan is less well funded today, start with a more modest CFM allocation, and expand it as funding levels improve. In any case, you are bringing an element of certainty to what has been historically a very uncertain process.

So, please remember that every DB plan is unique. Don’t let anyone tell you that your fund needs to have X% in asset class A or Y% in asset class B. Securing the benefits should be the most important decision. How you build the alpha portfolio will be a function of so many other factors related specifically to your plan and its governance.

07.26.26
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ARPA Update as of July 24, 2026

By: Russ Kamp, CEO, Ryan ALM, Inc.

I hope that you are enjoying a wonderful summer weekend. I’m currently writing this post from an Amtrak train on my way to the Opal Public Fund Forum in Newport, RI. What a beautiful day for a train ride.

There is some very exciting news to report in this week’s update following several ho hum weeks with little to disclose. I’m pleased to report that a “Plan Terminated by Mass Withdrawal before 2020 Plan Year” has been invited to submit an application seeking Special Financial Assistance (SFA). As a reminder, there are 80 such plans on the “waitlist”. Could this be the crack in the dam that opens the flood gates?

Retirement Plan of Local 1102 Retirement Fund, the first mass withdrawal applicant, is seeking just over $3.7 million for 220 plan participants. I’ll be following this story closely and reporting as information becomes available. In addition to 1102, four other pension funds were permitted to submit revised applications, including America’s Family Benefit Retirement Plan, a Priority Group 1 member. They are one of just three members from that cohort that have not yet received SFA. They are hoping to secure $186.7 million for its 3,109 members.

The other three plans resubmitting applications are UFCW, Local 23 and Giant Eagle Pension Plan, Plasterers Local #1 Pension Plan, and Colorado Cement Masons Pension Trust Fund, who collectively are trying to secure $37.1 million for just under 7.5k plan members.

There is little to report this week beside the activity associate with the resubmission of four applications and the one initial application, as there were no applications approved, denied, or withdrawn.

U.S. interest rates (based on the Treasury yield curve) continued to rise last week as inflationary concerns escalated primarily due to uncertainty in the Middle East and its impact on the price of oil. Given the higher rates, new and future SFA recipients will be able secure those future benefits at a reduced cost. We’re pleased to provide you with a free analysis on just what those cost savings could be and how far into the future those benefits could be secured.

07.22.26
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A “Joe Friday” Moment

By: Russ Kamp, CEO, Ryan ALM, Inc.

Jack Webb, who portrayed Joe Friday in the 1950s crime drama “Dragnet”, was famous for saying in season two “all we want are the facts, ma’am.” The catchphrase eventually morphed into a shorter phrase with the help of comedian, Stan Freberg, who released his parody “St. George and the Dragonet” in which he stated, “just the facts, Ma’am”. That phrase has been carried forward in Dragnet remakes. But, I digress.

Today, I present to you a Joe Friday moment. Here are the facts: Oil prices have risen by 27% since July 6th. U.S. Treasury yields are rising across the yield curve, and the 30-year Treasury yield is within 6 bps of this cycle’s high of 5.2%. The 10-year Treasury yield is currently 4.66% as of 10:24 am on 7/22/26. Investment grade corporate bond spreads have finally started to widen although slowly. According to Morgan Stanley, the “average” yield on a BBB+ corporate is 6.23% or roughly 1.1% higher than the yield on the comparable 30-year Treasury bond. Inflation, which moderated in June, is likely to spike higher given the current direction of activity in the Middle East and its impact on shipping lanes.

These are the facts. They suggest to me, and hopefully you, that the current U.S. interest rate environment is ripe for de-risking activities through cash flow matching (CFM). Why continue to live with the uncertainty surrounding oil, inflation, rates, etc., when you can SECURE your fund’s promises in the near-term?

I wish that I had a crystal ball to help me forecast the future but alas I don’t, and I suspect that you don’t either. Given the lack of clarity related to future events, I suggest that we live in the moment. We have an environment in which the cost of those future promises (benefit payments) can be cut dramatically. An environment that brings an element of certainty to a very uncertain process. An environment in which U.S. interest rates are providing plan sponsors with a significant portion of the annual return on investment target.

We’ve seen this scenario before. At the start of the 2000s, we had pension plans extremely well-funded and contribution expenses well-controlled. That opportunity went unheeded. The result of that inaction proved to be disastrous as we saw DB pension funding get pounded by two major equity market corrections. Are you confident that another major correction isn’t around the corner?

Like Joe Friday, I rely on the facts, which I’ve now presented to you. Ignore them at your peril.