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

Welcome to the start of Christmas week. I wish for all you and your families a joyous holiday season and an incredible 2026!

So, are we witnessing the winding down of the ARPA pension legislation as far as new applications are concerned? As I’ve reported numerous times, the legislation stated that all initial applications have to be submitted by December 31, 2025. Applications that have been withdrawn and needing to be revised can be resubmitted through December 31, 2026. Yet, I haven’t seen anything recently on the PBGC’s website. There remain dozens of waitlist candidates at this time.

Regarding last week’s activity, these four pension plans were permitted to file an initial application seeking Special Financial Assistance (SFA), including 1) Bricklayers and Stonemasons Local Union #2 Pension Plan, 2) Communications Workers Local 1109 Pension Plan, 3) Local 1430 I.B.E.W. Pension Plan, and 4) District Council 37 Local 389 Home Care Employees Pension Fund. These four relatively small non-priority plans (<10k participants combined) are seeking $85.8 million in SFA.

In other ARPA news, Alaska United Food and Commercial Workers Pension Fund received approval for their SFA revised application. This non-priority plan will receive $109.1 million in SFA for 6,106 members of their pension plan. Fortunately, there were no applications denied due to eligibility issues, no plans were asked to refund a portion of their SFA due to census errors, and no new applicants were added to the waitlist. However, multiple plans locked in their valuation dates (all 9/30/25) and it appears that all waitlist pension plans have a committed valuation date.

As highlighted above, there remain 78 waiting list applicants hoping to get approval from the PBGC to submit an SFA application. I just don’t see that happening before year-end, especially given the fact that the PBGC’s e-Filing portal remains temporarily closed. Again, Happy Holidays!