ARPA Update as of October 21, 2022

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

Under the category of better late than never, I bring to you the ARPA update for multiemployer plans through last Friday evening. As regular readers of this blog know, I provide this update on Mondays. However, I, along with more than 5,000 of my closest multiemployer friends, was in Las Vegas for this year’s IFEBP Annual Conference. What an event! I think that it is important for multiemployer plan participants to know that there are many people who are fighting to protect and preserve your plans. I very much appreciated the opportunity to teach the investment class for the CAPPP program. I also had the chance to speak on Tuesday to the general audience.

But, I digress. With regard to the PBGC’s implementation of the ARPA legislation, there is little to update, as we seem to be in a quiet period. There were no new applications filed, no new applications approved or denied, and no applications withdrawn. There are still two plans, Local 557 and Sheet Metal Workers Local Pension Plan, that are awaiting payment of their SFA. I believe that as a result of this inactivity, the PBGC has announced that Priority Group 5 plans, those plans projected to become insolvent before March 11, 2026, will become eligible to file the initial application seeking Special Financial Assistance beginning November 15, 2022.

Given all the activity to date, it can become confusing as to where everything stands in terms of applications filed, approved, and SFA paid. Here is a scorecard of where everything stands as of today.

SFA Application Status
Priority Group123456NoneTotal
Total Applications Expected30241N/A1514218302
Under Review014100015
Expected Future Applications4101514218252
SFA Status as of October 27, 2002

The information above was presented by the PBGC at the Enrolled Actuary Meeting on May 2, 2022. The chart details were presented by Jason Russell, Segal, at the IFEBP Annual Conference in Las Vegas, NV.

The 300+ potential ARPA participants represent about 15% of the active multiemployer pension plan universe.

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