ARPA Update as of October 3, 2025

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

Welcome to the first update in October. Autumn has been an extension of the summer weather in NJ – dry and hot! I’m writing this post from cloudy Florida (FPPTA) where it is humid and hot! When will I finally get those crisp, clear days that autumn promises?

Regarding ARPA news, we are quickly closing in on the end of 2025, and the PBGC still has a significant list of initial applications (73) that have not been submitted for review. As far as I can tell, only those applications that have been submitted by December 31, 2025, can continue to be reviewed until the end of 2026. It should prove to be an interesting time.

So, what did the week of 9/29/25 provide? Access to the PBGC’s eFiling portal is currently defined as “limited” to those funds at the top of the waitlist. They did allow for three funds, Asbestos Workers Local No. 8 Retirement Trust Plan, Iron Workers Local No. 12 Pension Fund, and Bricklayers Local No. 55 Pension Plan to submit initial applications seeking SFA support. The three non-Priority Group plans are seeking modest SFA grants totaling $55.5 million for their combined 1,593 participants. As per the legislation, the PBGC has 120-days to act on these applications.

In other ARPA news, the PBGC did approve the SFA for Retail Food Employers and United Food and Commercial Workers Local 711 Pension Plan, which will receive $77.6 million for their 25,306 members. Also, Building Trades Pension Fund of Western Pennsylvania, a non-Priority Group member, is asking for $55.5 million in SFA for their nearly 4k plan participants.

Finally, there were no non-Priority Group pension plans asking to be added to the waitlist during the past week, but there were three funds currently on the list that have chosen to lock-in their valuation date. Greater St. Louis Service Employees Pension Plan, Twin Cities & Vicinity Conference Board Pension Plan, and Oregon Printing Industry Pension Trust each chose June 30, 2025, for that purpose.

Despite the recent cut in the Fed Funds Rate, yields on longer-dated U.S. Treasuries have risen. As a result, the yield curve has steepened providing plan sponsors and their advisors an opportunity to secure the SFA assets at a time when additional cost savings may be achievable. Furthermore, the greater the cost reduction the longer the coverage period. Please don’t let this opportunity pass you by.

ARPA Update as of August 29, 2025

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

We are pleased to share with you the last update for August 2025. Welcome to the final third of the calendar year. We wish for you and your children heading back to school a great year! Always an exciting time of year despite some understandable anxiousness. I still have a daughter heading off to her last year of grad school and six of our 11 grandkids going to grammar school.

The PBGC certainly ramped up activity during the prior week. They absolutely earned their Labor Day break. We’ll provide more detail, but in summary there was one revised application received, five applications approved, two applications withdrawn, and two waitlisted plans decided to lock-in their valuation date.

Alaska United Food and Commercial Workers Pension Fund and Local 73 Retirement Plan, both non-Priority Group members withdrew initial applications. However, Alaska United resubmitted a revised application three days later. They are seeking $95.3 million in SFA for 6,106 plan participants. The PBGC has until December 27, 2025, to act on this submission.

I’m not sure that I remember a week in which the PBGC approved five applications, but as we’ve been saying, with 105 applications yet to be approved and in many cases, even submitted, the PBGC’s pace of approval is bound to speed up. Pension funds receiving approval included Local 1102 Retirement Trust, IBEW Eastern States Pension Plan, Local 1922 Pension Plan, Local 888 Pension Fund (Elmwood Park, NJ), and Local 807 Labor-Management Pension Fund. They are seeking a combined $349.6 million for 13,441 members. The PBGC has now approved the SFA application for 137 funds.

Lastly, two plans, Employee Pension Benefit Plan of Local 640 IATSE and Southern Council of Industrial Workers United Brotherhood of Carpenters and Joiners of America AFL-CIO Pension Plan have locked in their valuation date as of May 31, 2025. Given the number of funds still on the waitlist, there should be some doubt as to whether these initial applications will even be submitted before the December 31, 2025 deadline for initial applications.

ARPA Update as of June 6, 2025

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

Pleased to provide you with another weekly update on the PBGC’s implementation of the critically important ARPA pension legislation. We are roughly 1 1/2 years from the completion of this program and yet, more pension funds are seeking to be added to the waitlist. In just the past week, another six funds were added to the list, including Bakery and Sales Drivers’ Local 33 Partitioned Pension Fund, Oregon Printing Industry Pension Trust, Local No. 171 Pension Plan, Licensed Tugmen’s and Pilots’ Pension Fund, San Diego Plasterers Pension Trust, and the Ironworkers Local No. 6 Pension Plan. In total 132 funds sought SFA that weren’t part of the original six priority groups that became five after further review.

There were no new applications submitted during the prior 7-day period, as the PBGC’s eFiling portal remains temporarily closed. There are currently 19 applications with the PBGC, including one Priority Group 1 member and a recently submitted Priority Group 2 application. There remains one application with a June 2025 deadline for action. Happy to report that two funds received approval for their applications, including New Bedford Longshoremen’s Pension Plan and Cement Masons Local No. 524 Pension Plan, both of which are non-priority group members. In total, they will receive just under $6 million in SFA plus interest for the 280 plan participants.

There were no plans asked to repay a portion of the SFA due to census errors and no plans had their applications denied. There were two plans running up against the PBGC’s 120-day window that withdrew applications, including Teamsters Local 277 Pension Fund and Laborers National Pension Fund.

Given uncertainty related to the impact of the tariffs on consumption, jobs, earnings, etc. The Federal Reserve remains cautious in its approach to future rate movements. As a result, U.S. interest rates have migrated higher providing plan sponsors with a wonderful opportunity to defease the promised benefit payments and in the process extend the potential coverage period. As always, we are willing to provide a free analysis to help any SFA recipient think through an appropriate asset allocation framework.

ARPA Update as of May 30, 2025

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

Welcome to the last update for May 2025. It sure seems like the year is flying by. Are we having fun yet?

It has been nearly four years (July 2021) since the PBGC began implementing the ARPA pension legislation. Despite a few stumbles, I think that the program has been a huge success. Somewhat surprisingly, we are still seeing multiemployer pension plans being added to the waitlist as they seek a share of the Special Financial Assistance (SFA). In fact, an additional 5 funds were added to the waitlist in the last week.

In other news, there were no applications submitted to the PBGC for review, as their eFiling portal remains temporarily closed. There are currently 24 applications in the PBGC’s queue, with seven needing to be completed in some way by the end of June and another seven by the end of July. There was one application approved, as Sheet Metal Workers’ Local No. 40 Pension Plan received approval for an SFA grant of $9.9 million including interest for the plan’s nearly 1,000 participants.

There was one application withdrawn, as Retail Food Employers and United Food and Commercial Workers Local 711 Pension Plan withdrew a revised application seeking $64.2 million in SFA for the plans 25,306 participants. Perhaps the third submission will prove successful. Lastly, there were no applications denied nor asked to repay a portion of the SFA grant. As I’ve been reporting, we are likely very near the end of the census error issue repayments.

When the original Butch Lewis Act (BLA) was being legislated it was estimated that approximately 114 multiemployer plans would be eligible for a “loan”. There are currently 100 more funds seeking support. If I remember correctly, everything needs to wrap up regarding this legislation by December 31, 2026. Clearly, there is still a ton of work ahead for the PBGC.

Milliman’s Multiemployer Study Released

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

Milliman released the 2024 year-end results of its Multiemployer Pension Funding Study (MPFS). The MPFS analyzes the funded status of ALL U.S. multiemployer DB pension plans. As of December 31, 2024, Milliman estimated multiemployer plans have an aggregate funded ratio of 97%, up from 89% as of December 31, 2023. Impressive!

Milliman determined that the improved funded status was largely due to investment gains, but they also highlighted the critical contribution from the special financial assistance (SFA) granted under the ARPA. Milliman highlighted that as of year-end 2024, 102 plans have received nearly $70 billion in SFA funding, including $16 billion paid during 2024. Incredibly, without the support of SFA grants, the MPFS plans’ aggregate funded percentage at year-end 2024 would be approximately 89% or the same as the end of December 2023. As my chart below highlights, as of today, 109 plans have now received $71 billion in SFA grants.

Chart provided by Ryan ALM, Inc.

According to Milliman, “53% (627 of 1,193 plans) are 100% funded or more, and 84% (1,005) are 80% funded or better.” They also highlighted the more challenged members of this cohort, stating that “7% of plans (85) are below 60% funded and may be headed toward insolvency. Many are likely eligible and expected to apply for SFA in 2025.” As the chart above highlights, there still 93 plans going through the process of submitting applications with the PBGC to receive SFA support.

ARPA’s pension reform legislation has clearly been a godsend to many struggling multiemployer plans (roughly 10% of ME plans to date). That said, a review of the universe of all multiemployer plans points to terrific stewardship of the retirement assets on the part of a significant percentage of plans. My one concern is that the use of the return on Asset (ROA) assumption by most of these plans as the discount rate for plan liabilities is overstating the true funded status relative to a discount rate of a blended AA corporate rate used by the private sector. Milliman’s other DB pension plan studies have public sector plans at an 81.2% funded ratio and private plans at 105.8%.

ARPA Update as of February 7, 2025

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

Welcome to February! I am a day late in reporting on the PBGC’s activity from last week, as I was an instructor at the IFEBP’s Advanced Trustee and Administrator’s Conference. Fortunately, it is in Orlando and not New Jersey, where the weather remains cold, snowy, and wet! For one of the first times in my 43-year professional career I’m hoping for a significant flight delay of perhaps three days!

The PBGC’s eFiling portal is now open but defined as limited. During the previous week there was one new application submitted. The Retail Food Employers and United Food and Commercial Workers Local 711 Pension Plan is seeking $64.2 million in Special Financial Assistance (SFA) for their 25,306 plan participants or $2,538.65 per member, which seemed modest, and in fact it is, as the average SFA payout has been $46,385 per beneficiary on applications that have been approved.

In addition to the one new application, two non-priority plans, Laborers’ Local No. 130 Pension Fund and Pension Plan of the Asbestos Workers Philadelphia Pension Fund each withdrew an initial application. Collectively, they are seeking $72.4 million for 2,124 members.

There were no applications denied or approved during the past week. In addition, there were no plans required to repay an overpayment of SFA due to census errors. There hasn’t been a repayment since December 2024. Finally, there were no plans seeking to be added to the waitlist. There are still 49 plans waiting to submit an initial application to the PBGC.

The U.S. interest rate environment remains favorable for plans looking to defease the pension liabilities with the proceeds from the SFA. Investment-grade corporate bond portfolios are currently producing yields above 5% despite very tight spreads between corporates and the comparable maturity Treasury. Given the elevated valuations for domestic equities, particularly large cap stocks, now is the time to use 100% of the SFA to secure the promises.

Not Crunch Time, But the Program is Nearing Its End

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

I frequently get terrific questions following the publishing of one of my blog posts. Today’s question of the day was related to the ARPA pension legislation. I was asked, “Russ when does this legislation expire and when is the final date that a plans application must be submitted?” Terrific question. I’ve been meaning to provide this information as part of one of my weekly ARPA updates. Thanks for the prompt.

According to the final language in the Bill, ‘‘(f) APPLICATION DEADLINE.—Any application by a plan for special financial assistance under this section shall be submitted to the corporation (and, in the case of a plan to which section 432(k)(1)(D) of the Internal Revenue Code of 1986 applies, to the Secretary of the Treasury) no later than December 31, 2025, and any revised application for special financial assistance shall be submitted no later than December 31, 2026.

Furthermore, “The corporation (PBGC) shall not pay any special financial assistance after September 30, 2030.” As an aside, I’m not quite sure how a “revised” application that must be filed by 12/31/26 would not be paid before 2030 is beyond me, especially given the 120-day window to have an application acted on.

As reported in yesterday’s blog post, of the potential 202 applications, 109 have been approved, 21 are currently under review, while another 21 plans have withdrawn the applications. That leaves 51 plans that have yet to file (remember the 12/31/25 deadline) including a Priority Group 1 fund.

So, despite the terrific effort to date, the PBGC clearly has its work cut out for it. Currently, the eFiling portal to submit applications is closed. The PBGC has been opening and closing access to the filing portal based on its ability to meet the 120-day deadline. They may need to accelerate the pace of submissions and approvals in the coming months in order to complete the process by 12/31/26. Obviously, more to come from the PBGC. Also, keep your questions coming!

ARPA Update as of January 31, 2025

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

Somewhat shockingly, one month of 2025 is now in the books. That said, the PBGC continues to implement the ARPA legislation, which will soon celebrate its fourth anniversary since being signed into law on March 11, 2021. By all measures, this has been an incredibly successful program, with much yet to be accomplished with 93 pension plans still in the process of securing Special Financial Assistance (SFA).

The last few weeks have witnessed a moderation in the pace of implementation. The prior week saw no new applications received or approved. There was one application withdrawn, as Rocky Hill, CT-based, Sheet Metal Workers’ Local No. 40 Pension Plan withdrew their initial application seeking $18.8 million in SFA for 984 plan participants. In addition, there was one plan, St. Louis Motion Picture Machine Operators Pension Fund, that locked in the measurement date (liability valuation) as of October 31, 2024. They submitted the request as of January 24, 2025. With this action, there are only 2 plans of the 115 non-priority plans to have not locked in a valuation date.

I’ve previously mentioned the onerous impact of MPRA which passed in 2014. Fortunately, the PBGC/ARPA provided SFA of $477 million to restore to the 18 plans affecting 11 unions that under MPRA had reduced benefits an average of 22% for 60,620 retirees in pay status with some plans reducing benefits as much as 55 percent. These plans received an additional $3.5 billion in SFA to help ensure they remain solvent and able to pay all 87,862 participants in those plans their full retirement benefits through at least 2051.

ARPA Update as of January 17, 2025

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

I hope that you enjoyed the long holiday weekend. For many of us on the East coast, the holiday’s days and nights were likely spent inside given the frigid temps. Unfortunately, the upcoming week is not going to provide any weather relief.

However, this should warm your heart, as the PBGC continued to be active implementing the ARPA legislation that is nearing its fourth anniversary (3/11/21). To date, the PBGC has approved the Special Financial Assistance (SFA) for 109 multiemployer plans. The grants have totaled $70.9 billion and 1,528,409 American workers/retirees have had the promised pension benefit protected, and in some cases, restored.

During the last week, the PBGC accepted one new application, as Greendale, WI based United Food and Commercial Workers Unions and Employers Pension Plan filed a revised application seeking $54.3 million for its 15,420 plan participants. In other news, two funds, Cement Masons Local No. 524 Pension Plan and Local 1922 Pension Plan each withdrew their initial application. The two funds were seeking just over $20 million for roughly 2k members. Finally, the Legacy Plan of the UNITE HERE Retirement Fund, a Priority Group 6 member, received approval of its revised application. They have been awarded $868.8 million in SFA and interest that will go to protecting the retirements for 91,744 participants. Congrats!

The PBGC’s eFiling portal is temporarily closed. According to the PBGC’s website, “the PBGC will accept as many applications as the agency estimates it can process within the statutory 120-day review period. When the number of applications under review reaches that level, the application e-Filing Portal will temporarily close until PBGC has capacity to receive more applications.” There are still an estimated 93 funds going through the process of filing applications SFA grants. 

ARPA Update as of September 20, 2024

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

Welcome to Autumn! It has always been my favorite season since I was a young boy. I would often listen to NY Giants football on the radio as I spent Sunday afternoons outside in the crisp fall air while raking leaves or lying in a freshly created pile. Unfortunately, the Giants weren’t very good in the ’60s and ’70s. I guess what goes around comes around.

I knew that this day would come since I publish an update on the weekly activity associated with the ARPA pension legislation. There was no obvious activity by the PBGC last week. In their latest update, the PBGC is not reporting any new applications received (the efiling portal remains temporarily closed), no applications were approved, denied, or withdrawn, no plans repaid a portion of the SFA due to census errors, and finally, no multiemployer plans sought inclusion on the waiting list. Oh, well. Even the PBGC needs a rest once in a while.

Perhaps the PBGC was focused on the Fed’s interest rate policy decision like the rest of us. So, I’ll take advantage of the clean slate and use my weekly update to summarize where we are at this stage of the PBGC’s implementation of the ARPA pension legislation which began in July 2021. To date, 92 multiemployer plans have received Special Financial Assistance totaling $68.0 billion in grants (inclusive of supplemental awards, interest, and FA Loan Repayments). Of the 92 approved applications, 38 (41.3%) were the initial application attempt. There has been only one plan that had its application denied for ineligibility. Bakery Drivers Local 550 and Industry Pension Fund had its initial application denied in January 2023. A subsequent application was withdrawn in July 2023.

There are currently 23 applications before the PBGC. Five of those 23 will have the 120-day review period elapse in October. There is still one Priority Group 1 member that hasn’t filed an application out of the 30 funds identified as Priority Group 1 eligible. In addition, there are currently 18 applications that were withdrawn that have yet to refile. As I’ve previously reported, 14 funds have repaid a portion of the SFA received because of overpayment due to incorrect census data. There may be more to come.

The Waitlist had 115 multiemployer plans at one time. Twenty-one of those plans have received SFA grants, another 21 are presently under review, while five applications were withdrawn and not refiled. That leaves 69 plans that have yet to get PBGC approval to submit the initial application. While last week may have been “quiet” for the PBGC from an external point of view, a tremendous effort has been put forth to get to this point with potentially lots more to go.