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

This post is being produced on my flight to Chicago, where I will be speaking at the NCPERS conference on Wednesday. Importantly, I will once again be talking about cash flow matching (CFM), but in the context of a successful implementation of the strategy for a defined benefit pension plan. As many recipients of the Special Financial Assistance (SFA) have found, CFM SECURES the promised benefits, while providing the necessary monthly liquidity to meet ongoing benefits (and expenses) chronologically. I hope that you have a great week.

This past week saw revised applications submitted by Building Trades Pension Fund of Western Pennsylvania and Iron Workers’ Pension Trust Fund for Colorado. They are seeking a combined $55.7 million in SFA for their 5,573 participants.

Non-priority group member, Building Trades Pension Fund of Western Pennsylvania, withdrew its revised application. They’d been seeking $39.7 million in SFA for the 3,907 members of their plan.

Happy to report that there were no pension funds denied the opportunity to file an SFA application and none required to refund a portion of the SFA due to census errors. I think that it is safe to assume that we’ve seen the last of the census problems that plagued initial application filers.

You may recall that I mentioned Retirement Plan of Local 1102 Retirement Fund as being the first of the “Mass Withdrawal” plans to be allowed to submit an application. I now have a better understanding of the likely direction that the PBGC will be taking thanks to Rich Hudson, First Actuarial. According to Rich, the PBGC will only allow multiemployer plans located in the Second Circuit (VT, CT, and NY) to submit applications since it was the Second Circuit that ruled that the Plans Terminated by Mass Withdrawal before 2020 Plan Year were eligible to seek SFA provided that met the other requirements. It appears that plans located in the other Circuits – there are 13 U.S. federal Courts of Appeal, including the D.C. Circuit and the Federal Circuit – will not get the opportunity to file before the ARPA legislation concludes at the end of 2026. I’m sure that there will be more on this issue to discuss.