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

We are pleased to provide you with this very brief update on the implementation of the ARPA legislation. I know that kids in our local school district were off for the week inclusive of the President’s Day holiday, but it seems like many others may have been too. There were no new applications filed last week seeking Special Financial Assistance (SFA). There were also no applications approved or denied. In fact, the only activity according to the PBGC’s weekly update was the withdrawal of one application. IBEW Local No. 237 Pension Plan, A MPRA Suspension plan, withdrew its application on February 19th. This plan had been seeking roughly $30 million for its 430 plan participants. The initial application was filed on December 29, 2022, well after most, if not all of the Priority Group 2 plans had filed their initial applications, and in many cases, supplemental applications seeking additional funding support.

As the chart above highlights, Priority Group 6 members have been slow to file their applications despite the window having been opened on February 11th. We estimate that 16 eligible plans have still yet to file, while another 6 withdrawn applications need to be resubmitted. Again, it isn’t obvious to me what transpires once the non-Priority Group plans can begin filing. The possibility of nearly 220 plans filing in short order may truly overwhelm the PBGC’s ability to respond within the mandated 120 days following receipt of an application. On your mark, get set…