ARPA Update as of August 28, 2026

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

Good morning! I hope that you enjoyed the last weekend in August. If you live around NJ, you likely had a top-10 weather day for 2026. It was spectacular.

Regarding ARPA and the PBGC’s implementation of this critical pension legislation, the proverbial floodgates have opened, as a plethora of new applications are being reviewed. For much of 2026, the PBGC had between 8-10 applications under review at any point in time. There are currently 32 funds, including many new applications that fall within the Second Circuit related to plans that suffered a mass withdrawal prior to 2020, that are seeking Special Financial Assistance. If those applications are approved, another $1.4+ billion will go to support 63.4k plan participants.

However, there is one wrinkle for which I need to get more info. California Winery Workers’ Pension Plan, Fresno, CA, which is NOT located in NY, CT, or VT, submitted an application on 8/21/26. This is the first non-Second Circuit mass withdrawal plan to submit an application for SFA. We were led to believe that only plans from the three states within the Second Circuit would be permitted to file for SFA. Will this development prove to be a one-off?

In other ARPA news, Retail Bakers’ Pension Trust Fund of St. Louis, a non-priority plan, had its revised application approved. They will receive $6.5 million for the 566 members.

Pleased to report that no applications were denied or withdrawn during the previous week, and one fund, Defined Benefit Plan for the Operative Plasterers’ and Cement Masons’ International Association Local Union 394 Pension Trust Fund, was added to the waitlist, as another mass withdrawal casualty prior to 2020.

Clearly, we have some homework to do to understand the circumstances surrounding the application submitted by the Winery Workers. In the meantime, it is great to see that fourteen Second Circuit plans are now in the queue to potentially receive SFA.

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