ARPA Update as of October 24, 2025

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

If it is a Monday, it is ARPA/SFA update day. I’m bringing you this update from Fort Lauderdale, FL, where I’m attending and speaking at the NCPERS Fall conference. It looks like a wonderful agenda for the next few days. Regarding ARPA, how did the PBGC do last week? Let’s explore.

Last week saw limited action with only two applications received, including a revised application from a Priority Group 1 member. As you may recall, this was the first group permitted to submit applications all the way back in July 2021! Only 25 of the 30 members of that cohort have received Special Financial Assistance to date. Richmond, VA based Bricklayers Union Local No. 1 Pension Fund of Virginia, submitted a revised application seeking $12.9 million for its 395 participants, while International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Local No. 79 Pension Fund, submitted an initial application hoping to secure $14.6 for 462 members. As an aside, the Ironworkers would be golden if the SFA desired was based on the length of the plan’s name.

In other ARPA news, or lack thereof, there were no applications approved, and fortunately, none denied. There were no pension plans forced to withdraw an application and none asked to repay a portion of the SFA received due to census errors. However, there was one more plan added to the burgeoning waitlist. The Soft Drink Industry Pension Fund is the 178th none-priority group fund to add its name to the list.

The next couple of months should be quite exciting for the PBGC as it works through the abundant list of applications for non-priority group members. U.S. interest rates have pulled back recently reducing some of the potential coverage period through a CFM strategy, but rates are still significantly higher than they were in 2021 when ARPA began to be implemented. Please reach out to us if you’d like to get a free analysis on what is possible once the SFA is received.

And Now Utility Bills!

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

Electric payment company Payless Power released a report showing how Americans are being forced to choose between keeping the lights on, buying groceries, or paying for medicine. They conducted a survey of 1,069 people, including nearly half of whom came from low-income households, and regrettably 39% said they’d fallen behind on electricity payments in the past year.

Incredibly, more than 30% received at least one shutoff notice, while 11% had their power cut off due to missed payments. “Beyond the financial stress, high electricity prices are creating real safety risks,” Payless Power said. “More than half of low-income households said they went without heat or air conditioning for several days in the past year because they couldn’t afford it.”

The impact of having one’s electricity shut off has led roughly 30% of the respondents to feel physically unsafe at home during extreme temperatures. Not unlike the challenging economic times found during the Great Depression, nearly one in four sent children or pets away from their home to escape dangerous indoor conditions.

More than half (52%) of low-income households cut back on groceries to pay utility bills, while 16% skipped medication or medical care. Another 19% reduced transportation or internet spending, and 5% missed rent or mortgage payments. As you can imagine, larger families are hit hardest, as households with five or more people were nearly twice as likely to fall behind as those homes with two or fewer individuals at home.

Rising utility costs come as households are already stretched thin by higher housing costs and food prices compounded by a deteriorating labor market. Research from Goldman Sachs shows consumers are absorbing >50% of the cost of President Trump’s widespread tariffs. In a Harris/Axios poll, 47% of Americans said groceries are more difficult to afford than they were in September 2024.

Lastly, as of Q2’25, Moody’s and the Federal Reserve estimate that the top 10% of income earners in the U.S. account for 49.2% of the consumption. This is the highest percentage on record dating back to when data collection began in 1989. A level of concentration such as this is NOT good for the long-term viability of the U.S. economy.

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.

Remember: NO Free Lunch!

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

In 1938, journalist Walter Morrow, Scripps-Howard newspaper chain, wrote the phrase “there ain’t no such thing as a free lunch”. The pension community would be well-served by remembering what Mr. Morrow produced more than eight decades ago. Morrow’s story is a fable about a king who asks his economists to articulate their economic theory in the fewest words. The last of the king’s economists utters the famous phrase above. There have been subsequent uses of the phrase, including Milton Friedman in his 1975 essay collection, titled “There’s No Such Thing as a Free Lunch”, in which he used it to describe the principle of opportunity cost.

I mention this idea today in the context of private credit and its burgeoning forms. I wrote about capacity concerns in private credit and private equity last year. I continue to believe that as an industry we have a tendency to overwhelm good ideas by not understanding the natural capacity of an asset class in general and a manager’s particular capability more specifically. Every insight that a manager brings to a process has a natural capacity. Many managers, if not most, will eventually overwhelm their own ideas through asset growth. Those ideas can, and should be, measured to assess their continuing viability. It is not unusual that good insights get arbitraged away just through sheer assets being managed in the strategy.

Now, we are beginning to see some cracks in the facade of private credit. We have witnessed a significant bankruptcy in First Brands, a major U.S. auto parts manufacturer. Is this event related to having too much money in an asset class, which is now estimated at >$4 trillion.? I don’t know, but it does highlight the fact that there are more significant risks investing in private deals than through public, investment-grade bond offerings. Again, there is no free lunch. Chasing the higher yields provided by private credit and thinking that there is little risk is silly. By the way, as more money is placed into this asset class to be deployed, future returns are naturally depressed as the borrower now has many more options to help finance their business.

In addition, there is now a blurring of roles between private equity and private credit firms, which are increasingly converging into a more unified private capital ecosystem. This convergence is blurring the historic distinction between equity sponsors and debt providers, with private equity firms funding private credit vehicles. Furthermore, we see “pure” credit managers taking equity stakes in the borrowers. So much for diversification. This blurring of roles is raising concerns about valuations, interconnected exposures, and potential conflicts of interest due to a single manager holding both creditor and ownership stakes in the same issue.

As a reminder, public debt markets are providing plan sponsors with a unique opportunity to de-risk their pension fund’s asset allocation through a cash flow matching (CFM) strategy. The defeasement of pension liabilities through the careful matching of bond cash flows of principal and interest SECURES the promised benefits while extending the investing horizon for the non-bond assets. There is little risk in this process outside of a highly unlikely IG default (2/1,000 bonds per S&P). There is no convergence of strategies, no blurring of responsibilities, no concern about valuations, capacity, etc. CFM remains one of the only, if not the only, strategies that provides an element of certainty in pension management. It isn’t a free lunch (we charge 15 bps for our services to the first breakpoint), but it is as close as one will get!

MV versus FV

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

There seems to be abundant confusion within certain segments of the pension industry regarding the purpose and accounting (performance) of a Cash Flow Matching (CFM) portfolio on a monthly basis. Traditional monthly reports focus on the present value (PV) of assets in marking those assets to month-end prices. However, when utilizing a CFM strategy, one is hoping to defease (secure) promised benefits which are a future value (FV). As a reminder, FVs are not interest rate sensitive. The movement in monthly prices become irrelevant.

If pension plan A owes a participant $1,000 next month or 10-years from now, that promise is $1,000 whether interest rates are at 2% or 8%. However, when converting that FV benefit into a PV using today’s interest rates, one can “lock in” the relationship between assets and liabilities (benefit payment) no matter which way rates go. To accomplish this objective, a CFM portfolio will match those projected liabilities through an optimization process that matches principal, interest, and any reinvested income from bonds to those monthly promises. The allocation to the CFM strategy will determine the length of the mandate (coverage period).

Given the fact that the FV relationship is secured, providing plan sponsors with the only element of certainty within a pension fund, does it really make any sense to mark those bonds used to defease liabilities to market each month? Absolutely, NOT! The only concern one should have in using a CFM strategy is a bond default, which is extremely rare within the investment grade universe (from AAA to BBB-) of bonds. In fact, according to a recent study by S&P, the rate of defaults within the IG universe is only 0.18% annually for the last 40-years or roughly 2/1,000 bonds.

A CFM portfolio must reflect the actuaries latest forecast for projected benefits (and expenses), which means that perhaps once per year a small adjustment must be made to the portfolio. However, most pension plans receive annual contributions which can and should be used to make those modest adjustments minimizing turnover. As a result, most CFM strategies will purchase bonds at the inception of a mandate and hold those same issues until they mature at par. This low turnover locks in the cost reduction or difference in the PV vs. FV of the liabilities from day 1 of the mandate. There is no other strategy that can provide this level of certainty.

To get away from needing or wanting to mark all the plan’s assets to market each month, segregate the CFM assets from the balance of the plan’s assets. This segregation of assets mirrors our recommendation that a pension plan should bifurcate a plan’s asset allocation into two buckets: liquidity and growth. In this case, the CFM portfolio is the liquidity bucket and the remaining assets are the growth or alpha assets. If done correctly, the CFM portfolio will make all the necessary monthly distributions (benefits and expenses), while the alpha assets can just grow unencumbered. It is a very clean separation of the assets by function.

Yes, bond prices move every minute of every day that markets are open. If your bond allocation is being compared to a generic bond index such as the Aggregate index, then calculating a MV monthly return makes sense given that the market value of those assets changes continuously. But if a CFM strategy can secure the cost reduction to fund FVs on day 1, should a changing MV really bother you? Again, NO. You should be quite pleased that a segment of your portfolio has been secured. As the pension plan’s funded status improves, a further allocation should be made to the CFM mandate securing more of the promised benefits. This is a dynamic and responsive asset allocation approach driven by the funded status and not some arbitrary return on asset (ROA) target.

I encourage you to reach out to me, if you’d appreciate the opportunity to discuss this concept in more detail.

ARPA Update as of October 10, 2025

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

Welcome to Columbus and Indigenous Peoples’ Day. Bond markets are closed and the equity markets remain open. Columbus Day remains a federal holiday, but with most federal employees already furloughed, it will not be a day to celebrate for many.

Regarding ARPA and the PBGC’s activity implementing this critical legislation, last week proved a busy one as there were three new applications received, two approved, and one withdrawn. There was also a plan added to the burgeoning waitlist. Happy to report that there were no applications denied or required to rebate a portion of the SFA as a result of census errors.

Now for the details. Ironworkers’ Local 340 Retirement Income Plan, Operative Plasterers & Cement Masons Local No. 109 Pension Plan, and Dairy Employees Union Local #17 Pension Plan, each a non-priority group member, filed their initial applications seeking a combined $60.4 million in SFA for nearly 3k plan participants. The PBGC has 120-days to act on these applications.

Pleased to report that two plans, Local 734 Pension Fund and the Retirement Plan of the Millmen’s Retirement Trust of Washington received approval for their initial applications, and they will receive $89.5 and $7.2 million, respectively for their combined 2,597 members. The PBGC has now awarded $74.3 billion in SFA grants to support the pensions for 1.828 million workers.

In other ARPA news, Pension Plan of the Pension Fund for Hospital and Health Care Employees – Philadelphia and Vicinity has withdrawn its initial application seeking $229.8 million in SFA that would support 11,084 members. Finally, the Buffalo Carpenters Pension Fund has added their name to the waitlist. They immediately secured the valuation date as July 31, 2025. Good luck to them as there are 67 plans currently on the waitlist that have yet to submit an application.

I’ve mentioned on several occasions the approaching deadline to file an initial application seeking SFA approval. I do hope that an extension of the filing deadline is approved. There are a lot of American workers who should be provided the full benefits that they have been promised and could secure through the ARPA legislation. This should be a bi-partisan effort.

An Alternative Pension Funding Formula

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

I’ve spent the last few days attending and speaking at the FPPTA conference in Sawgrass, Florida. As I’ve reported on multiple occasions, I believe that the FPPTA does as good a job as any public fund organization of providing critical education to public fund trustees. A recent change to the educational content for the FPPTA centers on the introduction of the “pension formula” as one of their four educational pillars. In the pension formula of C+I = B+E, C is contributions, I is investment income (plus principal appreciation or depreciation), B is benefits, and E represents expenses.

To fund B+E, the pension fund needs to contribute an annual sum of money (C) not covered by investment returns (I) to fully fund liability cash flows (B+E). That seems fairly straightforward. If C+I = B+E, we have a pension system in harmony. But is a pension fund truly ever in harmony? With market prices changing every second of every trading day, it is not surprising that the forecasted C may not be enough to cover any shortfall in I, since the C is determined at the start of the year. As a result, pension plans are often dealing with both the annual normal cost (accruing benefits each year) and any shortfall that must be made up through an additional contribution amortized over a period of years.

As a reminder, the I carries a lot of volatility (uncertainty) and unfortunately, that volatility can lead to positive and negative outcomes. As a reminder, if a pension fund is seeking a 7% annual return, many pension funds are managing the plan assets with 12%-15% volatility annually. If we use 12% as the volatility, 1 standard deviation or roughly 68% of the annual observations will fall between 7% plus or minus 12% or 19% to -5%. If one wants to frame the potential range of results at 2 standard deviations or 19 out of every 20-years (95% of the observations), the expected range of results becomes 31% to -17%. Wow, one could drive a couple of Freightliner trucks through that gap.

Are you still comfortable with your current asset allocation? Remember, when the I fails to achieve the 7% ARC the C must make up the shortfall. This is what transpired in spades during the ’00s decade when we suffered through two major market corrections. Yes, markets have recovered, but the significant increase in contributions needed to make up for the investment shortfalls haven’t been rebated!

I mentioned the word uncertainty above. As I’ve discussed on several occasions within this blog, human beings loathe uncertainty, as it has both a physiological and mental impact on us. Yet, the U.S. public fund pension community continues to embrace uncertainty through the asset allocation decisions. As you think about your plan’s asset allocation, is there any element of certainty? I had the chance to touch on this subject at the recent FPPTA by asking those in the room if they could identify any certainty within their plans. Not a single attendee raised their hand. Not surprising!

As I result, I’d like to posit a slight change to the pension formula. I’d like to amend the formula to read C+I+IC = B+E. Doesn’t seem that dramatic – right? So what is IC? IC=(A=L), where A are the plan’s assets, while L= plan liabilities. As you all know, the only reason that a pension plan exists is to fund a promise (benefits) made to the plan participant. Yet, the management of pension funds has morphed from securing the benefits to driving investment performance aka return, return, and return. As a result, we’ve introduced significant funding volatility. My subtle adjustment to the pension formula is an attempt to bring in some certainty.

By carefully matching assets to liabilities (A=L) we’ve created an element of certainty (IC) not currently found in pension asset allocation. By adding some IC to the C+I = B+E, we now have brought in some certainty and reduced the uncertainty and impact of I. The allocation to IC should be driven by the pension plan’s funded status. The better the funding, the greater the exposure to IC. Wouldn’t it be wonderful to create a sleep-well-at-night structure in which I plays an insignificant role and C is more easily controlled?

To begin the quest to reduce uncertainty, bifurcate your plan’s assets into two buckets, as opposed to having the assets focused on the ROA objective. The two buckets will now be liquidity and growth. The liquidity bucket is the IC where assets and liabilities are carefully matched (creating certainty) and providing all of the necessary liquidity to meet the ongoing B+E. The growth portfolio (I) are the remaining plan assets not needed to fund your monthly outflows.

The benefits of this change are numerous. The adoption of IC as part of the pension formula creates certainty, enhances liquidity, buys-time for the growth assets to achieve their expected outcomes, and reduces the uncertainty around having 100% of the assets impacted by events outside of one’s control. It is time to get off the asset allocation and performance rollercoaster. Yes, recent performance has been terrific, but as we’ve seen many times before, there is no guarantee that continues. Adopt this framework before markets take no prisoners and your funded status is once again challenged.

Buy on the Rumor…

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

After 44-years in the investment industry I’ve pretty much heard most of the sayings, including the phrase “buy on the rumor and sell on the news”. I suspect that most of you have probably heard those words uttered, too. However, it isn’t always easy to point out an example. Here is graph that might just do the trick.

There had been significant anticipation that the U.S Federal Reserve would cut the Fed Funds Rate and last week that expectation was finally realized with a 0.25% trimming. However, it appears that for some of the investment community that reduction wasn’t what they were expecting. As the graph above highlights, the green line representing Treasury yields as of this morning, have risen nicely in just the last 6 days for most maturities 3 months and out, with the exception of the 1-year note. In fact, the 10- and 30-year bonds have seen yields rise roughly 10 bps. Now, we’ve seen more significant moves on a daily basis in the last couple of years, but the timing is what has me thinking.

There are still many who believe that this cut is the first of several between now and the end of 2025. However, there is also some trepidation on the part of some in the bond world given the recent rise in inflation after a prolonged period of decline. As a reminder, the Fed does have a dual mandate focused on both employment and inflation, and although the U.S. labor force has shown signs of weakening, is that weakness creating concerns that dwarf the potential negative impact from rising prices? As stated above, there may also have been some that anticipated the Fed surprising the markets by slicing rates by 0.50% instead of the 0.25% announced.

In any case, the interest rate path is not straight and with curves one’s vision can become obstructed. What we might just see is a steepening of the Treasury yield curve with longer dated maturities maintaining current levels, if not rising, while the Fed does their thing with short-term rates. That steepening in the curve is beneficial for cash flow matching assignments that can span 10- or more years, as the longer the maturity and the higher the yield, the greater the cost reduction to defease future liabilities. Please don’t let this attractive yield environment come and go before securing some of the pension promises.

Houston, We Have A Problem!

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

That famous phrase from the movie Apollo 13, is actually modified from the original comment spoken by Jack Swigert, the command module pilot, who said, “Okay, Houston…we’ve had a problem here”. In any case, I am not referencing our space program, the City of Houston or for that matter, any other municipality. However, I am acknowledging that we continue to have an issue with how the debt of companies, municipalities, and other government entities get rated and how those rating agencies get compensated.

There was a comment in New Jersey Spotlight News (a daily email newsletter) that stated “New Jersey is facing uncertain economic times, to say the least, but its state government got a vote of confidence from Wall Street this week.” Of course, I was intrigued to understand what this vote of confidence might be especially given my knowledge of the current economic reality facing my lifelong state of residence. It turns out that Moody’s has elevated NJ’s debt rating. Huh?

Moody’s action in raising the rating to Aa3 follows a similar path that S&P took several months ago. Yes, NJ was able to recently close its budget gap by $600 million through tax increases but given that the state has one of the greatest tax burdens of any U.S. state, the ability to further raise taxes is likely significantly curtailed unless they want to witness a mass exodus of residents, including the author of this post!

According to Steve Church, Piscataqua Research, a highly experienced and thoughtful actuary, “New Jersey’s public employees, teachers, police and fire systems are $96B underfunded by reference to their actuaries’ contribution liability calculations and $154B underfunded using their actuaries’ LDROM calculations!” Ouch! Furthermore, they offer an OPEB that is funded at <10%. In addition, New Jersey, like many states, will be negatively impacted by the cuts in Medicaid and other social safety net programs. These cuts are likely to put significant pressure on the state’s budget, which has already risen significantly in just the last 5 years from $38.3 billion in fiscal year 2020 to nearly $60 billion today.

So, how is it possible that NJ could see a ratings increase given the significant burden that it continues to face in meeting future pension and OPEB funding, while also protecting the social safety net that so many Jersey residents are depending on. Well, here’s the rub. Rating agencies are paid under the practice called “issuer-pays”. This process has often been criticized, especially during the GFC when a host of credit ratings were called into question. Unfortunately, few alternatives have been put into practice today. How likely will a municipality or corporate entity pay an agency for a rating that puts the sponsor in a poor light? We’ve been extremely fortunate to have mostly weathered recent economic storms, but as history has shown, there is likely another just around the corner. How will these bonds hold up during the next crisis?

ARPA Update as of September 12, 2025

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

Welcome to FOMC week. I wouldn’t ordinarily mention the Federal Reserve in the ARPA update, but we could see an interest rate cut, and perhaps one that is larger than currently anticipated. The implications from falling interest rates are potential large, as it raises the costs to defease pension liabilities (benefits and expenses) that would be secured through the SFA grant by reducing the coverage period. This impact could be potentially diminished if the yield curve were to steepen given recent inflationary news.

Enough about rates and the Fed. The PBGC is still plugging away on the plethora of applications before them and those yet to be accepted. Currently, there are 20 applications under review. Teamsters Industrial Employees Pension Plan is the latest fund to submit an application seeking SFA. They are hoping to secure $27.4 million for the 1,888 participants. The PBGC has 6-7 applications that must be finalized in each of the next 3 months.

Happy to report that both Alaska Teamster – Employer Pension Plan and Hollow Metal Pension Plan received approval for their applications. The two non-priority pension funds will receive a combined $240.1 million for >13k members.

In other ARPA news, Bakery Drivers Local 550 and Industry Pension Fund, a Priority Group 2 member, whose initial application was originally denied because they were deemed ineligible, has had their revised application denied because of “completeness”. Will three times be the charm? In their latest application they were seeking $125.8 million to support 1,122 plan participants.

Lastly, Greater Cleveland Moving Picture Projector Operators Pension Fund, became the most recent fund added to the waitlist. They are the 167th fund on the waitlist of non-priority members, with 74 still to submit an application. According to the PBGC’s website, their e-Filing portal is limited at this time.

We’ll keep you updated on the activity of the U.S. Federal Reserve and the potential implications from their interest rate decision. Hopefully, concerns related to inflation will offset the current trends related to employment providing future SFA recipients with an environment conducive to defeasing the promised benefits at higher yields and thus, lower costs.