ARPA Update as of November 21, 2025

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

Welcome to Thanksgiving week. I don’t think that I’m alone when I say that Thanksgiving is my absolute favorite holiday. I hope that you and your family enjoy a truly special day. I’m thankful that we’ll have all of our kids and grandkids together and also very happy not to have to watch the Giants that day!

With regard to ARPA and the PBGC’s implementation of this critically important legislation, after a week of “rest”, there was some activity posted by the PBGC through the weekly update on their website. Not as much activity as one would expect, given the significant waiting list (81 funds) of pension plans to submit an initial application.

Happy to report that there was an application approved. It is the first one in more than one month (10/16/25). Emeryville, CA-based, Distributors Association Warehousemen’s Pension Trust, will receive $32.7 million in SFA for 3,358 plan participants. Their revised application was approved on November 20th.

In other ARPA news, Cumberland, Maryland Teamsters Construction and Miscellaneous Pension Plan, has submitted a revised application. They are hoping to get approval for $8.4 million in SFA for 101 members. In addition, there were no pension funds asked to repay a portion of the SFA due to census errors, which has been the case for the last couple of months. There were also no applications denied due to eligibility issues.

I’ve discussed quite often the growing list of funds that have asked to be added to the waitlist. These non-priority funds appear to be running out of time to have their initial application reviewed. Two more funds were added in the last week. By my estimate, there remain 79 pension systems yet to file the initial application. As a reminder, the legislation specifically reads that initial applications must be filed with the PBGC by December 31, 2025. Unfortunately, the PBGC’s e-Filing portal remains temporarily closed.

It Couldn’t Be Any Easier!

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

I participated this morning in a portfolio review for one of our Cash Flow Matching (CFM) clients. As usual, it couldn’t be any easier for us and the client. Following the Chair’s announcement that it was Ryan ALM’s turn, I stated that all benefits and expenses remain SECURED on a net of contributions basis through 2048 and gross of contributions through 2056. Any questions? That’s it!

There is no guessing as to the future. There is no hand-wringing or pondering regarding the Fed, and what they might do at their next meeting in December. No worries about equity valuations, the impact of AI, the increase in the use of PIKs in private credit portfolios, etc. We built this portfolio in the third quarter of 2024, and it continues to do exactly what it was designed to do. The combination of maturing principal and interest is providing the necessary asset cash flows to meet monthly distributions (liability cash flows of benefits and expenses) like clock-work. How comforting!

The only potential fly in the ointment is a default of an investment grade bond. But according to S&P, that happens at a 0.18% annual clip or roughly 2 / 1,000 bonds (last 40-years). Fortunately for us and our client this has not happened within their portfolio. So, as long as the monthly cash on hand remains greater than the required distribution, we are meeting the requirements of our mandate.

There is no anxiety associated with our management of pension assets. Only an element of certainty rarely found within pension management. How many of your other managers can provide a summary as concise as ours? How many of your managers have built a strategy where the performance for the length of the mandate (5-, 10-, or more years) is known on the day the portfolio is constructed? When we talk about CFM as a “sleep-well-at-night” strategy, this is precisely what we are talking about. Why wouldn’t you want some of this in your fund?

As a reminder, through CFM the liquidity is enhanced, the benefits (promises) SECURED, the investing horizon extended for the non-CFM assets, and certainty established for that portion of the portfolio. Seems like a no brainer.

I’m Confused??

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

I’ve had the great pleasure of speaking at a number of conferences and events this year. Thank you to those of you who provided me with these opportunities. Regular readers of this blog know that I’ve been discussing the concept of uncertainty and specifically how human beings really despise this state of being.

In the prior two weeks I’ve spoken at both NCPERS in Fort Lauderdale, FL, and at the IFEBP in Honolulu, HI, where I had the opportunity to discuss Cash Flow Matching (CFM) as part of a broader ALM conversation. In both cases I asked the audience, one primarily public fund sponsors (NCPERS) and the other multiemployer, if they could point to any part of their DB pension plan that brought certainty. Not surprisingly, not one hand was raised.

I then commented that if humans, including plan sponsors of DB pension plans, hated uncertainty, why were they continuing to live with the uncertainty imbedded in their current asset allocation structures? These asset allocations place plan sponsors and the plan’s participants on the performance rollercoaster driven by the whims of the markets, which shouldn’t be comfortable for anyone.

So, I ask once more: if folks hate uncertainty and they have the chance to bring a level of certainty into the management of pension plans through CFM, why haven’t they done so? Do they still believe that managing a pension plan is all about generating the ROA? Do they believe that their plan is sustainable (perpetual), so the swings in funded status don’t matter? Do they not worry about where liquidity is going to be derived despite the significant push into alternatives that are sapping plans of liquidity? These are just a few questions for which answers must be furnished. Without an appropriate answer the practice must stop.

A carefully constructed (optimized) CFM program established with IG bonds will SECURE the promises, enhance and provide the necessary liquidity (chronologically), extend the investing horizon for the non-bond assets that can now just grow, and in the process provide the plan sponsor and their members with a “sleep-well-at-night” strategy that is far more certain than anything that they are currently using. We recognize that change isn’t easy, but it is sure better than riding the proverbial performance rollercoaster with the accompanying unknown climbs and dramatic falls.

ARPA Update as of November 14, 2025

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

I hope that last week was great for you. I didn’t recognize anyone from the PBGC at the IFEBP in Honolulu last week, but I suspect that there must have been a few attendees. Why? Well, for the first time that I can recall since I began producing these weekly updates, there is nothing to report in terms of the PBGC’s implementation of the ARPA pension legislation. NOTHING!

Now, I’m sure that a lot is going on behind the scenes, especially given the announcement that Janet Dhillon has been confirmed as the 17th Director of the Pension Benefit Guaranty Corporation, but in the weekly update produced as of Friday, November 14th, there were no applications submitted, as the PBGC’s e-Filing portal remains temporarily closed. No pension plans received approval for SFA nor were any denied. There were no withdrawals of previously submitted applications. Lastly, there were no multiemployer plans asking to be added to the growing waitlist.

As we get closer to the legislation’s deadline for new applications to be submitted, we are down to about 6-7 weeks until December 31, 2025. Having a week in which nothing concrete was reported reduces the odds that most of those plans yet to file will actually be given that opportunity.

The graph above reflects the activity through November 7th. Despite the lack of activity last week, the PBGC deserves high praise for their handling of this critical legislation that has helped som many American workers and pensioners. Lastly, at the IFEBP was asked to touch on ARPA/SFA and how best to incorporate ALM strategies to mitigate risk. I’ve had the privilege to speak on this topic numerous times. In summation, the allocation of Special Financial Assistance (SFA) to multiemployer plans is truly of gift. That allocation is not likely to ever be repeated. As such, plans should take every precaution to ensure the maximum coverage of benefits (and expenses) while minimizing the risk through their investments. Call on us (ryanalm.com) if we can help you think through the use of Cash Flow Matching to SECURE those promises.

The Times They Are A-Changin’

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

Thank you, Bob Dylan, for the lyric that is just perfect for this blog post. I have just returned from the IFEBP conference in Honolulu, HI. What a great conference, and not just because it was in Hawaii (my first time there). If it wasn’t the location, then what made this one so special? For years I would attend this conference and many others in our industry and never hear the word liability mentioned, as in the pension promise, among any of the presentations.

So pleased that during the last few years, as U.S. interest rates have risen and defined benefit pension funding has improved, not only are liabilities being discussed, but more importantly, asset allocation strategies focused on pension liabilities are being presented much more often. During this latest IFEBP conference there were multiple sessions on ALM or asset allocation that touched on paying heed to the pension plan’s liabilities, including:

“Asset Allocation for Today’s Markets”

“My Pension Plan is Well-Funded – Now What?”

“Asset Liability Matching Investment to Manage the Risk of Unfunded Liabilities”

“Decumulation Strategies for Public Employer Defined Contribution Plans” (they highlighted the fact that these strategies should be employed in DB plans, too)

“Applying Asset Liability Management Strategies to Your Investments” (my session delivered twice)

“Entering the Green Zone and Staying There”

These presentations all touched on the importance of risk management strategies, while encouraging pension plan sponsors to stop riding the performance rollercoaster. Given today’s highly uncertain times and equity valuations that appear stretched under almost any metric, these sessions were incredibly timely and necessary. Chasing a performance objective only ensures volatility. That approach doesn’t guarantee success. On the other hand, securing the pension promise through an ALM strategy at a reasonable cost and with prudent risk does redefine the pension objective appropriately.

I know that human beings are reluctant to embrace change, but we despise uncertainty to a far greater extent. Now is the time to bring an element of certainty to the management of pension assets. By the way, that was the title of my recent presentation to public funds at the NCPERS conference in Fort Lauderdale. Again, understanding pension liabilities and managing to them is not new, but it has certainly been under a bigger and brighter spotlight recently. That is great news!

You Don’t Say!

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

Morgan Stanley has published the results from their Taft-Hartley survey, in which they have to provided “insights into how Taft-Hartley plans are managing priorities and navigating challenges to strengthen their plans”. I sincerely appreciate MS’s effort and the output that they published. According to MS, T-H plans have as their top priority (67% of respondents) delivering promised benefits without increasing employer’s contributions. That seems quite appropriate. What doesn’t seem to jive with that statement is the fact that only 29% that improving or maintaining the plan’s funded status was important. Sorry to burst your bubble plan trustees, but you aren’t going to be able to accomplish your top priority without stabilizing the funded status/ratio by getting off the performance rollercoaster.

Interestingly, T-H trustees were concerned about market volatility (84%) and achieving desired investment performance while managing risk (69%). Well, again, traditional asset allocation structures guarantee volatility and NOT success. If you want to deliver promised benefits without increasing contributions, you must adopt a new approach to asset allocation and risk management. Doing the same old, same old won’t work.

I agree that the primary objective in managing a DB plan, T-H, public, or private, is to SECURE the promised benefits at a reasonable cost and with prudent risk. It is not a return game. Adopting a new asset allocation in which the assets are divided among two buckets – liquidity and growth, will ensure that the promises (monthly benefits) are met every month chronologically as far into the future that the assets will cover delivering the promised benefits. However, just adopting this bifurcated asset allocation won’t get you off the rollercoaster of returns and reduce market volatility. One needs to adopt an asset/liability focus in which asset cash flows (bond interest and principal) will be matched against liability cash flows of benefits and expenses.

This approach will significantly reduce the volatility associated with markets as your pension plan’s assets and liabilities will now move in lockstep for that portion of the portfolio. As the funded status improves, you can port more assets from the growth portfolio to the liquidity bucket. It will also buys time for the remaining growth assets to help wade through choppy markets. According to the study, 47% of respondents that had an allocation to alternatives had between 20% and 40%. This allocation clearly impacts the liquidity available to the plan’s sponsor to meet those promises. If allocations remain at these levels, it is imperative to adopt this allocation framework.

Furthermore, given today’s equity valuations and abundant uncertainty surrounding interest rates, inflation, geopolitical risk, etc., having a portion of the pension assets in a risk mitigating strategy is critically important. Thanks, again, to MS for conducting this survey and for bubbling up these concerns.

PBGC Increases Premium Rates – Why?

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

The demise of the defined benefit (DB) plan, most notably within the private sector, is harming the American worker and significantly reducing the odds of a dignified retirement. The Federal government should be doing everything that it can to protect the remaining pensions, including keeping fees low to ensure that these critically important retirement vehicles continue to operate. But unfortunately that doesn’t seem to be the case in this particular situation.

I have been very impressed with and supportive of the PBGC’s effort implementing the ARPA pension legislation, but I question the need to raise premium rates for 2026, which the PBGC has just announced. Why? As of fiscal year-end 2024, the PBGC’s single employer insurance program had a $54.1 BILLION surplus, as assets totaled $146.1 billion and liabilities stood at $92.0 billion. Despite these significant excess resources, the PBGC is increasing rates for the “flat rate premium per participant” in single-employer plans to $111 per participant in 2026 from $106. This 4.7% increase was described in a Chief Investment Officer article as modest! That increase doesn’t seem modest anyway you look at it, but certainly not when one remembers that $54 billion surplus. What is the justification? The rate per $1,000 in “unvested benefits”, not subject to indexing, was frozen by Congress in Section 349 of the SECURE 2.0 Act of 2022 and therefore remains $52. Seems like we need more legislation to freeze the flat-rate premium.

Despite the significant improvement in the multiemployer pension program due to the Special Financial Assistance (SFA) related to ARPA pension reform, that insurance pool is still underwater. As a result, multiemployer plans that only pay a per-participant premium will see the per-participant rate for flat rate premiums rise to $40 from $39 next year. That amounts to an increase of 2.6%. So, the program that is underwater sees a premium increase of 2.6%, while the insurance pool with the massive surplus gets an outsized 4.7% increase? I guess one must work for the government to understand that decision.

Again, we need to do much more to protect DB pensions for all American workers. Asking untrained individuals to fund, manage, and then disburse a “retirement benefit” with little to no disposable income, low investment knowledge, and no crystal ball to help with longevity considerations is just poor policy doomed to failure. We are the wealthiest country in the world, yet we can’t seem to figure out how to control costs associated with retirement, healthcare, education, childcare, etc. and in the process, we are crippling a majority of American families. It isn’t right!

Cash Flow Matching: Bringing Certainty to Pension Plans

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

Imagine a world, or at least the United States, where pension plans are no longer subject to market swings and the uncertainty those swings create. What if you could “guarantee” (outside of any corporate bond defaults) the promises made to your plan participants, ensuring their financial security with confidence? In today’s highly unpredictable investing environment, relying solely on the pursuit of investment returns is a risky ride—one that guarantees volatility and sleepless nights but not necessarily success. It’s time to rethink how we manage defined benefit (DB) pension plans and embrace a strategy that brings true certainty: Cash Flow Matching (CFM). Discover through the hypothetical conversation below how CFM can transform your investing approach, protect your plan, and deliver peace of mind for everyone involved. Let’s go!

Why are we talking about Cash Flow Matching (CFM) today?

First off, thanks for taking a few minutes to chat with me. As you may have heard me say before, our mission at Ryan ALM, Inc. is simple — to protect and preserve defined benefit (DB) pension plans and to secure the promises made to participants.

We believe that Cash Flow Matching (CFM) is one of the few strategies that can help us keep those promises with real certainty.


Why Now?

Because the world feels more uncertain than ever.

And if we’re honest, most of us don’t like uncertainty. Yet somehow, in the pension world, many plan sponsors have gotten used to it. Why is that?

Over the years, we’ve been taught that managing a DB plan is all about chasing returns. But that’s not really the case. When a plan invests 100% of its assets purely with a return objective, it locks itself into volatility — not stability or success.

That approach also puts your plan on the “asset allocation rollercoaster,” where markets rise and fall, and contributions swing higher and higher along with them. It’s time to step off that ride — at least for part of your portfolio.


So if it’s not all about returns, what is the real objective?

Managing a DB pension plan is all about cash flows — aligning the cash coming in (from principal and interest on bonds) with the cash going out (for benefits and expenses).

The real goal is to secure those promised benefits at a reasonable cost and with prudent risk. That’s the foundation of a healthy plan.


Does bringing more certainty mean I have to change how I manage the plan?

Yes — but only a little. The adjustments are modest and easy to implement.


How can I adopt a CFM strategy without making major changes?

The first step is to reconfigure your asset allocation. Most DB plans are currently 100% focused on returns. It’s time to split your assets into two clear buckets:

  1. Liquidity bucket – designed to provide cash flow to pay benefits and expenses.
  2. Growth bucket – focused on long-term return potential.

What goes into the liquidity bucket?

Most plans already hold some cash and core fixed income. Those assets can move into the liquidity bucket to fund benefit payments and expenses.


And what happens with the remaining assets?

Nothing changes there. Those assets stay in your growth or alpha bucket. The difference is that you’ll no longer need to sell from that bucket during market downturns, which helps protect your fund from the negative impact of forced selling.


Is that all I need to do to create more certainty?

Not quite. You’ll also want to reconfigure your fixed income exposure.

Instead of holding a generic, interest-rate-sensitive bond portfolio (like one tied to the Bloomberg Aggregate Index), you’ll want a portfolio that matches your plan’s specific liabilities — using both principal and income to accomplish the objective.

That’s where true cash flow matching comes in.


How does the matching process work?

We start by creating a Custom Liability Index (CLI) — a model of your plan’s projected benefit payments, expenses, and contributions. This serves as the roadmap for funding your monthly liquidity needs.


What information do you need to build that index?

Your plan’s actuary provides the projected benefits, expenses, and contributions as far out into the future as possible. The more data we have, the stronger the analysis. From there, we can map out your net monthly liquidity needs after accounting for contributions.


Which bonds do you use to match the cash flows?

We invest primarily in U.S. Treasuries and U.S. investment-grade corporate bonds. We stick with these because they provide dependable cash flows without introducing currency risk.

We limit our selections to bonds rated BBB+ or higher, and the longest maturity we’ll buy matches the length of the mandate. For example, if you ask us to secure 10 years of liabilities, the longest bond we’ll buy will mature in 10 years.


Do you build a laddered bond portfolio?

No — a traditional ladder would be inefficient for this purpose.

Here’s why: the longer the maturity and the higher the yield, the lower the overall cost of funding those future liabilities. So instead of a simple ladder, we use a proprietary optimization process to build the portfolio in a way that maximizes efficiency and minimizes cost.


It sounds manageable — not a big overhaul. Am I missing something?

Not at all. That’s exactly right.

Dividing assets into liquidity and growth buckets and reshaping your bond portfolio into a CFM strategy is typically all that’s required to bring more certainty to part of your plan.

Every plan is unique, of course, so each implementation will reflect its own characteristics. But generally speaking, CFM can reduce the cost of future benefits by about 2% per year — or roughly 20% over a 10-year horizon.

On top of that, it helps stabilize your funded status and contribution requirements.


How much should I allocate to CFM?

A good starting point is your existing cash and bond allocation. That’s the least disruptive way to begin.

Alternatively, you can target a specific time horizon — for example, securing 5, 7, or 10 years of benefits. We’ll run an analysis to show what asset levels are needed to meet those payments, which may be slightly more or less than your current fixed income and cash allocations.


Once implemented, do I just let the liquidity bucket run down?

Most clients choose to rebalance annually to maintain the original maturity profile. That keeps the strategy consistent over time. Of course, the rebalancing schedule can be customized to your plan’s needs and the broader market environment.


This all sounds great — but what does it cost?

In line with our mission to provide stability at a reasonable cost and with prudent risk, our fee is about half the cost of a typical core fixed income mandate.

If you’d like, we can discuss your specific plan details and provide a customized proposal.


Final thoughts

Thank you for taking the time to explore CFM. Many plan sponsors haven’t yet heard much about it, but it’s quickly becoming a preferred approach for those who value stability and peace of mind.

At the end of the day, having a “sleep well at night” strategy benefits everyone — especially your participants.

Uncertainty versus Change

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

Seems like we have a conflict within the management of defined benefit plans. On one hand, human beings (plan sponsors) despise uncertainty. But nearly all public DB pension plans are embracing uncertainty in how they are managed. How? Through a traditional asset allocation framework that focuses the fund’s assets on a performance objective – the return on asset assumption (roughly 7% for the average public plan). Each second that the capital markets are operating, uncertainty is abundant, as price movements are out of one’s control. So let’s change how plans are managed. Not so simple, as those same human beings hate change. Oh, boy.

I have the privilege of speaking at the NCPERS Fall conference tomorrow. The title of my presentation is “Bringing an Element of Certainty to Pension Management”. Folks should absolutely eat up this topic, but given the conflict cited above, it will be interesting to see if the trustees in the audience embrace the concept of achieving some certainty despite having to implement change to their current operating practices.

Given that both uncertainty and change are difficult for humans, what are we to do? Well, psychological research suggests that uncertainty is generally more challenging because it disrupts our ability to predict, control, and prepare for outcomes, and in the process it triggers more anxiety and stress than change itself. According to the research:

  • Uncertainty introduces ambiguity about outcomes, which activates heightened anxiety in the brain. When people lack information about what will happen (such as market movements), they tend to experience more stress and feelings of helplessness.
  • Change, while uncomfortable, becomes easier to adapt to when the outcome is known, even if it’s negative. Humans can plan, adjust, and find coping strategies if they know what to expect. As a result, predictable change is less stressful than unpredictable change.

Why is uncertainty more challenging? Again, according to the research:

  • The human brain is wired to seek patterns and predict the future; uncertainty undermines this process, making adaptation feel more difficult.
  • Studies show that people prefer even certain bad news to ambiguous situations, because they can prepare for and process what’s coming.
  • Chronic uncertainty can lead to anxiety disorders and impaired decision-making, while change tends to prompt growth and learning once people know what they’re facing.

Uncertainty is usually more psychologically challenging than change because it creates anxiety about the unknown, whereas change with a known outcome—though still difficult—allows people to adapt and regain control. Given this reality, it would seem that reducing uncertainty within the management of a DB pension plan would outweigh the changes necessary to accomplish that objective. BTW, the changes needed aren’t great. All one needs to do to bring some certainty to the process is to convert the current core fixed income allocation to a cash flow matching (CFM) strategy that will SECURE the promised benefits for as far into the future as that allocation will cover. In the process you improve the fund’s liquidity profile and extend the investing horizon for the residual assets. A win/win!

How nice would it be to communicate to your plan participants that no matter what happens in the markets (uncertainty) the promised benefits are protected for the next 5-, 7-, 10- or more years. Talk about a “sleep well at night” strategy! Now that’s certainty that even change can live with.

Milliman: Another good month for pension funding

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

Whether one is referring to public pensions or private DB plans, September was a continuation of the positive momentum experienced for most of 2025. Milliman has reported on both the Milliman 100 Pension Funding Index (PFI), which analyzes the 100 largest U.S. corporate pension plans and its Public Pension Funding Index (PPFI), which analyzes data from the nation’s 100 largest public defined benefit plans.

Milliman estimates that public pension funds saw aggregate returns of 1.7%, while corporate plans produced an average return for the month of 2.5%. As a result of these gains (sixth consecutive gain), public pension funded ratios stand at 85.4% up from 84.2% at the end of August. Corporate plans are now showing an aggregate funded ratio of 106.5%, marking the highest level since just before the Great Financial Crisis (GFC).

Public pension fund assets are now $5.66 trillion versus liabilities of $6.63 trillion, while corporate plans added $26 billion to their collective net assets increasing the funded status surplus to $80 billion. For corporate plans, the strong 2.5% estimated return was more than enough to overcome the decline in the discount rate to 5.36%, a pattern that has persisted for much of 2025.

“Robust returns helped corporate pension funding levels improve for the sixth straight month in September,” said Zorast Wadia, author of the Milliman PFI. “With more declines in discount rates likely ahead, funded ratios may lose ground unless plan assets move in lockstep with liabilities.”

“Thanks to continued strong investment performance, public pension funding levels continued to improve in September, and unfunded liabilities are now below the critical $1 trillion threshold for the first time since 2021,” said Becky Sielman, co-author of the Milliman PPFI. “Now, 45 of the 100 PPFI plans are more than 90% funded while only 11 are less than 60% funded, underscoring the continued health of public pensions.”

Discount rates have so far fallen in October. It will be interesting to see if returns can once again prop up funded status for corporate America. It will also be interesting to see how the different accounting standards (GASB vs. FASB) impact October’s results. A small gain for corporate plans may not be enough to overcome the potential growth in liabilities, as interest rates decline, but that small return may look just fine for public pension plans, that don’t mark liabilities to market only assets.

View this Month’s complete Pension Funding Index.

View the Milliman 100 Public Pension Funding Index.