It is the end of January 2022 and we still don’t have the PBGC’s Final Final Rules, but that doesn’t mean that we aren’t making some progress. According to the latest update from the PBGC’s website, there are now 24 pension plans that have filed applications to receive the Special Financial Assistance (SFA), including a second plan, Ironworkers Local 17 Pension Fund, that has been filed as an “MPRA eligibility suspension” claimant. In addition to the filing activity, we now know that five applications have been approved and two of those have actually received payment. Terrific!
I’ve expressed my concern that we have all this activity going on without final rules from the PBGC pertaining to implementation, but I’m told that there will be no changes to the law that necessitate a “clawback” of the SFA. That is great news. We can only hope that any amendments to the current interpretation leads to the ability of these plans to secure more of the promised benefits. With only 24 plans having filed to date, there is much more to come. We’ll keep you updated.