Tag Archives: arpa

06.25.24
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ARPA Update as of June 21, 2024

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

I suspect (can only hope) that you woke up yesterday morning just itching to see what news I was going to share as it related to ARPA and the PBGC’s implementation of that critical legislation. Sorry to have disappointed you. Like most everyone else, my day just got away from me.

However, I do have some exciting news to share which might just make up for the disappointment of having to wait one day to get the weekly update. As we’ve been writing, the PBGC was running up against many application review and determination deadlines this month. As a result, they have announced that five funds had their applications approved for Special Financial Assistance (SFA). Terrific!

The five funds are the Retail, Wholesale and Department Store International Union and Industry Pension Plan, the Bakery and Confectionery Union and Industry International Pension Fund, United Food and Commercial Workers Unions and Employers Midwest Pension Plan, GCIU-Employer Retirement Benefit Plan, and the Pacific Coast Shipyards Pension Plan. These funds represent three Priority Group 6 members and two that came through the non-priority waitlist. In total, they will receive nearly $5.8 billion in SFA for just over 200k in plan participants. The Kansas Construction Trades Open End Pension Trust Fund is the last application that needs action in June. There are four that have July deadlines.

There were no new applications submitted to the PBGC, as the portal remains temporarily closed, no applications denied or withdrawn, and none of the plans that have received SFA were forced to return a portion of the proceeds as a result of overpayment identified through a death audit of the plan’s population.

Fortunately, the US interest rate environment and current economic conditions remain favorable for those potential SFA recipients to SECURE promised benefits far into the future without subjecting the grant proceeds to unnecessary risk associated with a non-cash flow matching assignment. Remember that the sequencing of returns is a critical variable when contemplating an asset allocation framework. If your SFA portfolio suffers significant losses in the early years, you negatively impact the coverage period. We’ll be happy to model your plan’s liabilities for free. Don’t hesitate to reach out to us if we can be a resource for you.

06.10.24
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ARPA Update as of June 7, 2024

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

We are pleased to provide you with another ARPA update. The PBGC approved the applications for two New Jersey funds seeking Special Financial Assistance (SFA). CWA/ITU Negotiated Pension Plan and the Pension Plan of Local 102, both non-priority funds, will receive $545.6 million and $12.5 million, respectively, in order to ensure that their 24,796 participants will receive the promised benefits.

Unfortunately, there isn’t much else to report, as there were no new applications submitted, and the queue remains at 18. There were no applications rejected or withdrawn and no pension systems were added to the waitlist, with 32 of 114 having had some activity (submissions, withdrawals, and approvals) to date. Central States remains the only plan to pay back excess SFA proceeds.

The 18 plans that are currently under review carry some heft, as they are collectively seeking >$13 billion in SFA for nearly 370K participants. Seven of those plans have application “deadlines” in June. As a reminder, the PBGC has 120 days to act on an application once it has been submitted. Fortunately, US interest rates remain elevated providing plan sponsors with the opportunity to use cash flow matching to secure the SFA assets and significantly reduce the risk associated with a traditional asset allocation. Sponsors would be wise to use the legacy assets to assume a more traditional asset allocation since those assets now have the benefit of an extended investing horizon.

We hope that you have a wonderful week.

06.03.24
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ARPA Update as of May 31, 2024

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

Welcome to June and the latest update on the PBGC’s effort to implement the ARPA pension legislation. There isn’t much to report, but I’m happy to mention that two plans received approval of the SFA applications.

Maryland Race Track Employees Pension Plan and the Radio, Television and Recording Arts Pension Plan were granted approval for SFA totaling $89.6 million. Both plans were categorized as non-priority funds. In the case of the Maryland Race Trace Employees, they are galloping toward receiving $26.7 million for the 1,407 plan participants, while the Radio, Television and Recording Arts will no longer have to perform for their benefits as they will get $62.8 million for the plan’s 516 participants or roughly $121 K per participant.

The only other reported activity had the Carpenters Pension Trust Fund – Detroit & Vicinity pulling its application that was seeking $595.5 for more than 22,000 members of the plan. This non-priority plan from Troy, MI, pulled its initial application. There were no new applications filed or rejected. No plans were added to the waitlist and no pension funds returned excess SFA assets.

June looks to be shaping up as a busy month for the PBGC, as there are nine funds that have approval dates this month, including the Bakery and Confectionery Union and Industry International Pension Fund, that is seeking nearly $3.2 billion in SFA. In total, the nine funds are hoping to gather more than $6 billion in grants for 233,845 participants. Six of the nine funds are waiting to get approval from the PBGC on revised applications. Good luck.

05.28.24
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ARPA Update as of May 24, 2024

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

I hope that you enjoyed a long, restful weekend. Our thoughts and prayers are with all of the US service men and women who gave the ultimate sacrifice to enable the rest of us to continue to enjoy our freedom.

With respect to the ARPA legislation and the PBGC’s yeoman effort to implement, there was some activity last week. In fact, there were three plans that filed applications and one that received approval. Local Union No. 226 International Brotherhood of Electrical Workers Open End Pension Trust Fund, Local 1783 I.B.E.W. Pension Plan, and the Pressroom Unions’ Pension Plan each filed its initial application45 last week seeking SFA. The three plans are non-priority group members and in total they have asked for $127.4 million for just over 3,400 plan participants.

Happy to report that the UFCW Regional Pension Fund received approval for its application. The non-priority fund will receive $54.5 million, including interest, for its 4,605 participants. This bring the # of approved applications to 73 and a total of $52.2 million in final SFA amount approved including interest and FA loan repayments. There was no other activity report including applications denied, excess SFA repaid, plans added to the waitlist or plans on the waitlist setting a lock-in date for valuation purposes.

There is the possibility that 128 additional plans may receive SFA before the legislation expires. This total includes those under review, those plans that have withdrawn and not refiled, and finally, those plans on the waitlist that have yet to file the initial application.

05.13.24
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ARPA Update as of May 10, 2024

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

Another Monday brings the weekly update on the PBGC’s effort to implement the pension rescue under ARPA. As noted previously, activity has definitely slowed in recent weeks, and the week ending May 10, 2024 is no exception. I can report that the only activity on the PBGC’s ARPA spreadsheet is a withdrawal of a previously revised application. Employers’ – Warehousemen’s Pension Plan, a non-priority plan out of Los Angeles, was seeking $40 million in Special Financial Assistance (SFA) for just over 1,800 plan participants. The latest version of the application had been filed on March 4, 2024.

Unfortunately, there were no additional applications submitted or approved. At the same time, there were no additional applications withdrawn or denied. Lastly, no plans that might have received excess SFA have returned those excess assets at this tie outside of Central States. There remain 129 plans to still have their applications for SFA reviewed and approved.

Glen Eagle Trading reported the following in a recent email, that In 2023, a survey found that 78% of Americans live paycheck-to-paycheck, up six percentage points from the previous year. Unfortunately, in yet another survey 29% of Americans don’t earn enough to cover basic living costs. The ability to fund a retirement is getting to be more challenging than ever, which is why DB pension systems need to be be protected and preserved. The ARPA pension legislation is going a long way to securing pensions for millions of American workers who were on the verge of losing most, if not everything, that they had earned and counted on for their “golden years”.

05.06.24
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ARPA Update as of May 3, 2024

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

Welcome to May! The PBGC has now been implementing the ARPA legislation since July 2021. Great strides have been made since Local 138 Pension Trust Fund received the first approval for the SFA grant ($112.6 million) on December 21, 2021. The grant proceeds were ultimately awarded on January 14, 2022. There have been another 71 funds to receive approval for their SFA applications ($53.8 billion in SFA) with another 129 currently awaiting action on their applications. Thats a huge effort to-date and a greater one to come.

That said, there must have been a big celebration at the PBGC for Cinco de Mayo this past weekend, as there were no new applications received, denied, approved, withdrawn, or excess proceeds repaid during the previous week. Furthermore, there were no pension systems looking to be added to the waitlist, which currently has 108 systems seeking approval from the original 114 on the list. Of course I’m being facetious about the PBGC’s celebration as they have already accomplished a lot, but there remains a ton to do before the legislation reaches its termination date.

I am attending and speaking at the IFEBP’s legislative conference in Washington DC beginning today, and I hope to gather some intel on anything related to ARPA’s pension reform and future actions. I’ll report back on any interesting tidbits. Have a great week.

04.08.24
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ARPA Update as of April 5, 2024

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

Welcome to ECLIPSE DAY. Good luck found me in Dallas today for the TexPERS conference, as it is in the path of totality (complete darkness). Bad luck has it heavily overcast today following a Sunday that had beautiful blue skies. Oh, well. Perhaps we’ll get lucky.

APRA’s implementation by the PBGC has slowed, and we don’t have earthquakes (NJ residents are still shaking their heads), eclipses, or any other natural event to blame. That is not to say that nothing has been done, as there was one new application received during the week. Printing Local 72 Industry Pension Plan, a Priority Group 5 member, submitted its revised application seeking $37 million in SFA for the 787 plan participants. Beyond that, I suspect that they are busy reviewing the 19 applications that have been submitted that are currently waiting on approval. Only 5 of those applications are the initial version.

As we’ve discussed in previous updates, census data used to determine SFA grant payments has had to be checked and rechecked following the announcement that Central States received more SFA grant $ than they were eligible to receive since some of the participants were no longer alive. That revelation and the corrective measures taken to ensure that SFA monies are only being allocated for eligible participants has really slowed an already cumbersome review. Despite some of these impediments, it is great that 72 plans have gotten the SFA awards totaling nearly $54 billion.

We might not have great visibility as it pertains to the eclipse, but with US interest rates tending higher, inflation remaining more “sticky” than hoped, and a Fed that may just not cut in 2024, visibility is clearer that cash flow matching the SFA is the way to secure the benefits and expenses well into the future. As a reminder, as rates rise, the cost to defease those promised benefits falls. Higher rates aren’t only good for savers. They are particularly good for SFA recipients and all plan sponsors of DB plans.

As an example of how that math works, when I entered this industry on October 13, 1981, the 10-year Treasury was yielding 14.9%. It would have only cost you $17.82 to defease a $1,000 30-year liability. On August 4, 2020, when the 10-year Treasury yield dipped to 0.52%, it would have cost you an extraordinary $860.40 to defease the same $1,000 30-year liability. As of April 5, 2024, the 10-year Treasury is yielding 4.41% and the cost to defease that 30-year liability is much more manageable at $301.00. You should be cheering for a higher for longer scenario.

04.01.24
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ARPA Update as of March 29, 2024

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

Good morning, and welcome to a new month/quarter. Still feels like winter in the northeast! But there has been a thaw with regard to activity at the PBGC as they implement the ARPA legislation.

Happy to report that the Pension Plan of the Moving Picture Machine Operators Union Local 306 and the New England Teamsters Pension Plan both submitted applications seeking SFA. The Machine Operators, a priority group 5 member, is seeking $19.4 million for its 542 participants, while the NE Teamsters are hoping to capture more than $5.4 billion in SFA for just over 72k plan members. If the NE Teamsters are successful, they will have received the second largest grant to date only trailing the Central States Teamsters whopping $35.8 billion. To date, there have been 5 awards of greater than $1 billion. Currently, there are four plans seeking >$1 billion that are under review including the NE Teamsters.

In other news, the United Food and Commercial Workers Union Local 152 Retail Meat Pension Plan, had its application approved for an SFA grant of $279.3 million which will support the benefits for 10,252 members. There were no applications denied or withdrawn during the previous week. In addition, there were no pension funds added to the waitlist that continues to have 86 potential applications waiting to submit an application from the initial 113 members.

The upcoming week will provide some insight into the continuing strength of the US labor market with the ADP and US employment releases as well as the weekly initial claims data. However, it doesn’t appear that market participants are waiting to see what those data sets reveal as US Treasury bonds and notes are seeing a big move up in yields today. This movement hurts total return focused fixed income products, but it provides those pension plans with more attractive yields for cash flow matching assignments. Higher yields mean lower cost to defease future benefit payments. Very nice!

03.25.24
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ARPA Update as of March 22, 2024

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

“March Madness” is upon us. How’s your bracket doing? I still have my champion in the running, but not much more than that.

The past week was very quiet with regard to the ARPA legislation and activity associated with its implementation. We did have one fund submit an application for Special Financial Assistance (SFA). United Food and Commercial Workers Union and Participating Food Industry Employers Tri-State Pension Plan, a Priority Group 6 member, submitted a revised application on March 16th. This fund is seeking SFA in the amount of $638.3 million for the fund’s 29,233 members. The PBGC will now have until July 14, 2024 to act on the application.

Besides the filing by the UFCW, there was little to show last week, as there were no applications approved, denied, or withdrawn. Furthermore, unlike the prior week, there were no additions to the waitlist which continues to have 113 funds listed of which 27 have been invited to submit an application. To-date, 71 funds have received SFA in the amount of $53.6 billion. These proceeds include the grant, interest, and any FA loan repayments.

Like the picking of the NCAA tournament bracket, for which there are no perfect submissions remaining, the capital markets are highly uncertain. Yes, the US equity market has enjoyed a robust 5-6 months period, but how predictive is that for the next six months or longer? Those yet to receive the SFA should seriously consider an investment strategy that takes the uncertainty of the markets out of the equation. I am specifically referring to the use of investment grade bonds to defease the promised benefit payments as far into the future that the SFA allocation will cover. Once the matching of asset cash flows to the plan’s liability cash flows is done, that relationship is locked in no matter what transpires in the capital markets. Any risk taken by recipients of these assets should be done in the legacy portfolio where a longer investing horizon has been created. Fortunately, US interest rates remain elevated significantly from when the ARPA program began in 2021. The timing couldn’t have been better.

03.18.24
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Overpayment of SFA to be Refunded

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

As those who regularly follow the Ryan ALM Inc. blog know, we report each week on the status of the PBGC’s effort to implement the ARPA legislation for multiemployer plans. In those updates, we have been reporting that the apparent slowdown in the processing of the special financial assistance (SFA) applications had to do with incorrect population surveys funds that have filed applications and in some circumstances have received SFA payouts.

We are finally starting to get some clarity on the situation in terms of who is involved and what is required of the funds that have received excess SFA grant money. In the most notable example, Central States, Southeast & Southwest Areas Pension Plan (CS) which received $35.8 billion in SFA in December 2022, has been informed that an excess SFA payment of $127 million was granted. This was the result of including 3,479 deceased participants in the eligible population. As a result, CS is required to repay the excess grant proceeds.

According to the Department of Labor, there are no consequences for those plans that have received excess grant money provided that they return those funds. According to a ai-cio.com article, “the DOL noted that this mistake was not made by the pension plan.” Unfortunately, the PBGC did not use the Social Security Administration’s death master file (DMF), a database that pension plans can’t access, when initially auditing SFA applications. They have since begun to use the DMF as of November 2023. “While these excess payment amounts may represent only a small fraction of total SFA payments, they would not otherwise have been paid and, as such, must be refunded to the United States government,” the PBGC said in a statement.