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

With the December 31, 2026 deadline for applications seeking Special Financial Assistance (SFA) to be submitted looming, it appears that the PBGC is picking up the pace to get through the eligible applications by then, as 7 applications were submitted during the past week, including 2 revised requests. There are now 49 applications before the PBGC, including three from Priority Group 1 and 46 from the waitlist, with most of those funds falling into the category of Mass Withdrawal casualties.

I’m pleased to report that there were no applications withdrawn or denied. There were also no multiemployer pension funds seeking to be added to the waitlist. Lastly, there were no applications approved for SFA during the previous week.

As we’ve discussed previously, the PBGC has been permitting Mass Withdrawal applicants located in the Second Circuit (NY, CT, and VT) to submit their applications seeking SFA. However, United Food and Commercial Workers Union Local 1262 Retail (Non-Food) Industry Pension Plan, a Mt. Laurel, NJ-based plan, submitted its application on October 9th. Might this be just be confusion about where the fund is truly domiciled, or does this action open new opportunities for non-Second Circuit plans?

U.S. interest rates remain at nearly two decade highs providing plan sponsors with a great opportunity to use the SFA to defease future benefit payments through a cash flow matching (CFM) strategy. Higher rates reduce the amount of assets needed in present value terms to meet those future benefits. Let us help you work through the right strategy.