Tag Archives: multiemployer-plans

11.24.25
by

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.

11.17.25
by

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.

10.20.25
by

ARPA Update as of October 17, 2025

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

The PBGC is doing its best to get through an imposing list of applicants for Special Financial Assistance (SFA). However, it seems more like one step forward, 1 1/2 steps backward for that organization as they grapple with late arrivals to the waitlist. In the latest week, the PBGC didn’t allow any additional applications to be submitted through the eFiling portal, but they did manage to approve two applications for SFA, while a third withdrew its initial application.

Despite the apparent progress, the PBGC saw four additions to the waitlist, which now numbers 176, of which 72 have yet to see any action taken on their potential submission. I can’t see how the PBGC is going to get through the remaining applications by year-end, when the filing of an initial application needs to be completed based on the language within the ARPA legislation.

Those pension funds receiving approval for the SFA in this latest week included, Local 153 Pension Fund and (initial application) Roofers Local 88 Pension Plan (revised application). Together they will collect $239.7 in SFA and interest for 12,335 plan participants. There have now been 144 pension plans approved to receive SFA for a total of $74.5 billion in grants. Amazing!

Happy to report that there were no applications denied and none of the previous SFA recipients were asked to refund a portion of the grant due to census errors. However, there was one plan that withdrew the initial application. Cumberland, Maryland Teamsters Construction and Miscellaneous Pension Plan, is seeking a SFA grant of $8.7 million for its 101 members.

The four latest (late) additions to the waitlist include, Local 29 R.W.D.S.U. Pension Fund, United Optical Workers Local 408 Pension Fund, Millwrights and Machinery Erectors Local No. 1545 Pension Plan, and Painters and Allied Trades Paint Makers Pension Plan. Only the Millwrights plan locked in its valuation date as of July 31, 2025. They were joined by the New Bedford Fish Lumpers Pension Plan which also chose July 31, 2025, for its valuation date. Do you know what a fish lumper is or does? You’ll have to see next week’s ARPA post for the answer, or you can go to your friendly AI app like I did.

10.13.25
by

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.

09.22.25
by

ARPA Update as of 9/19/25

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

Good morning and welcome to the first full day of Fall. Autumn has always been my favorite season. How about you?

Regarding the implementation of ARPA’s pension legislation by the PBGC, we are now about 3 1/2 months away from the deadline to have all initial applications seeking Special Financial Assistance (SFA) submitted. Unfortunately, there are still dozens of multiemployer pension plans sitting on the PBGC’s waitlist.

Last week witnessed a slower pace of activity, as the PBGC is only reporting the submission of three applications and the repayment of excess SFA by one fund. There were no applications approved, denied, or withdrawn during the previous week. Furthermore, there were no pension funds seeking to be added to the waitlist and none of the plans currently sitting on that list locked-in the valuation date. We may not see any new plans being added to the list given the rapidly approaching deadline for initial application submission. As a reminder, those plans that submit an application before 12/31/25 can submit a revised application until 12/31/26 – the legislation’s deadline.

Pleased to report that Pension Trust Fund Agreement of St. Louis Motion Picture Machine Operators, Teamsters Local 837 Pension Plan, and Iron Workers’ Pension Trust Fund for Colorado each submitted an initial application seeking SFA. These non-Priority Group members are hoping to secure >$30 million for the nearly 3,200 plan participants. As a reminder, the PBGC has 120-days to act on these applications.

Finally, there was one plan asked to rebate a portion of the SFA based on a census error. Western Pennsylvania Teamsters and Employers Pension Fund, a recipient of $994.6 million has agreed to rebate $8.8 million or 0.89% of the grant. To date, 61 multiemployer pension funds have repaid $260.7 million in excess SFA on grants totaling $53.4 billion or 0.49%.

We hope that you have a great week. Check back in next Monday for the next ARPA legislation update.

09.15.25
by

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.

08.25.25
by

ARPA Update as of August 22, 2025

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

Welcome to the last week of “summer”. I don’t know about you, but I can believe that Labor Day is next weekend. I suspect that the PBGC is feeling the same way as they continue to work their way through an imposing list of applicants with a December 31, 2025, deadline for initial applications to be reviewed. As the chart below highlights, they have their work cut out for them.

Regarding last week’s activity, the PBGC did not accept any new applications as the e-Filing portal remains temporarily closed. However, they did approve the revised applications for two funds. Laborers’ Local No. 91 Pension Plan (Niagra Falls) and the Pension Plan of the Asbestos Workers Philadelphia Pension Fund have been awarded a total of $96.2 million in SFA and interest that will support 2,057. This brings the total of approved applications to 132 and total SFA to $73.5 billion – wow!

In other ARPA news, I’m pleased to announce that there were no applications denied or withdrawn during the previous week, but there were two more funds that were asked to repay a portion of the SFA received due to census errors. Sixty-four funds have been reviewed for potential census errors, with 60 having to rebate a small portion of their grants, while four funds did not have any issues. In total, $251.7 million has been repaid from a pool of $52.3 billion in SFA received or 0.48% of the grants awarded. The $251.7 relative to the $73.5 billion in total SFA grants would be only 0.34% of the total awards.

Lastly, three more funds have been added to the waitlist. There have been 165 non-Priority Group members on the waitlist including 56 that have received SFA awards, while another 26 are currently being reviewed. That means that 82 funds must still file an application reviewed and approved in a short period of time.

As stated above, pension funds sitting on the waitlist must have the initial application reviewed by the PBGC by 12/31/25. Any fund residing on the waitlist after that date loses the ability to seek SFA support. Applications that have been reviewed prior to 12/31/25 may still get approval from the PBGC provided the approval arrives before 12/31/26. I don’t see them getting through the remaining 74 waitlist funds by the end of 2025.

08.04.25
by

ARPA Update as of August 1, 2025

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

Talk about jumping out of the frying pan into the fire! I left New Jersey’s wonderful heat and humidity only to find myself in El Paso, TX, where the high temperature is testing the limits of a normal thermometer. Happy to be speaking at the TexPERS conference this week, but perhaps they can do an offsite in Bermuda the next time.

Regarding the ARPA legislation and the PBGC’s implementation of this critical pension program, we continue to see the PBGC ramp up its activity level. This past week witnessed five multiemployer plans submitting applications of which four were initial filings and the fifth was a revised offering. Another plan received approval, while one fund added its name to the waitlist. Finally, two funds have locked-in the measurement dates (valuation purposes).

Now the specifics: The four funds submitting initial applications were Colorado Cement Masons Pension Trust Fund, Iron Workers-Laborers Pension Plan of Cumberland, Maryland, Cumberland, Maryland Teamsters Construction and Miscellaneous Pension Plan, and Exhibition Employees Local 829 Pension Fund that collectively seek $50.8 million in SFA for their 1,260 plan participants. This week’s big fish, UFCW – Northern California Employers Joint Pension Plan, a Priority Group 6 member, is seeking $2.3 billion for its 138.5k members.

The plan receiving approval of its application for SFA is Laborers’ Local No. 130 Pension Fund, which will receive $33.3 million in SFA and interest for its 641 participants. In an interesting twist, Laborers’ Local No. 130 Pension Fund, has added the fund to a growing list of waitlist candidates. If the Laborers name seems to resemble the name of the recipient of the latest SFA grant you wouldn’t be wrong. I was as confused as you are/were until I realized that these entities have different that there are two different EIN #s.

Happy to report that there were no applications withdrawn, none denied, and no SFA recipients were asked to return a portion of the proceeds due to incorrect census information. However, there are still 119 funds going through the process. There is a tremendous amount of work left to be done at this time. This comes on the heels of 131 funds being approved for a total of $73.4 billion in SFA and interest supporting the retirements for 1.77 million American workers/retirees. What an incredible accomplishment!

07.08.25
by

ARPA Update as of July 3, 2025

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

Welcome to the Summer doldrums. The PBGC’s ARPA activity appears to have been impacted by the holiday-shortened week. We hope that you and your family had a terrific Fourth of July weekend.

There isn’t a whole lot to discuss about last week. There were no applications received as the PBGC’s e-Filing portal remains temporarily closed. No applications were approved or denied, and there were no pension funds looking to be added to a very crowded waiting list.

However, there was one fund, Trucking Employees of North Jersey Welfare Fund, Inc. Pension Plan, that repaid a portion of the Special Financial Assistance (SFA) received earlier. The $7.7 million repayment represents 0.99% of the $774.3 million grant. The Truckers’ fund is the 55th fund to repay a portion of the SFA grant. There are four funds that had no census errors. It was estimated that roughly 60 pension funds had been granted SFA prior to the PBGC’s use of the Social Security Master Death file. In total, $229.4 million has been recouped from $50.9 billion in grants (0.45%).

In other ARPA news, eight funds currently on the waitlist have elected their measurement lock-in date. As a reminder, the measurement date refers to the date on which a plan submits a lock-in application to PBGC. This date is crucial because it sets and permanently establishes the plan’s SFA measurement date and base data for its eventual SFA application, regardless of when the full application is later submitted. Specifically, the lock-in application fixes: 1) the non-SFA and SFA interest rates, 2) the SFA measurement date, and 3) participant census data. Five of the funds chose March 31, 2025, while the other three selected April 30, 2025, as the measurement date for their pension plans.

According to the ARPA legislation, the PBGC is prohibited from accepting initial applications after December 31, 2025. They may receive and review revised applications until December 31, 2026. They currently have about 70 plans on the waitlist, in addition to the 46 that are under review or have been withdrawn. It will take a tremendous effort to process these initial applications prior to the legislation’s deadline.

06.18.25
by

Eligible For SFA

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

Regular followers of this blog know that I provide a weekly update on the ARPA pension legislation and the PBGC’s progress implementing this critical support for multiemployer pension plans. We reported way back in January 2023 that the Bakery Drivers Local 550 and Industry Pension Fund’s application seeking Special Financial Assistance (SFA) had been denied due to ineligibility. We also reported that the Bakery Drivers had submitted a revised application on May 30, 2025. We observed at the time that unlike all the other applications that had been submitted, this one did not have a 120-day window for the PBGC to act on the submission. We now know why.

The Bakers were cooking up an argument that was presented to the courts on why their application seeking SFA was appropriate and they were right. “The U.S. 2nd Circuit Court of Appeals says that a multiemployer pension plan that qualifies for a grant under the Pension Benefit Guaranty Corporation’s (PBGC) Special Financial Assistance (SFA) program cannot be excluded just because that plan was previously terminated.”

“Because we do not read the pertinent provision of the SFA statute to exclude plans based solely on a prior termination,” the court ruled, the plan should be eligible for a SFA grant. As a result, the court ruled in favor of the fund, “vacated the PBGC’s denial and remanded the application to the PBGC for reconsideration.”

A little history. The Bakery Drivers Local 550 and Industry Pension Fund, a fund based in Floral Park, NY. The plan covered 1,094 participants in 2022 and was 6.3% funded, according to their Form 5500. Regrettably, the plan terminated in 2016 by mass withdrawal after Hostess Brands, Inc., its largest contributor, went bankrupt. However, the court stated, that despite terminating in 2016, the plan “continued to perform audits, conduct valuations, file annual reports, and make payments to more than 1,100 beneficiaries.”

The court ruled that the statute said that any multiemployer plan that was in critical and declining status from 2020 to 2022 was potentially eligible, and the plan was in critical and declining status in Sept. 2022 when it applied. Importantly, “these provisions do not, by their terms, exclude a plan that was terminated by mass withdrawal.”

According to the PBGC’s status of applications weekly report, the United Food and Commercial Workers Unions and Employers Pension Plan, a non-priority group member, is the only other applicant to have its submission denied due to ineligibility. I wonder if they will have a similar argument as the Bakery Drivers. More to come.