Tag Archives: PBGC

08.31.26
by

ARPA Update as of August 28, 2026

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

Good morning! I hope that you enjoyed the last weekend in August. If you live around NJ, you likely had a top-10 weather day for 2026. It was spectacular.

Regarding ARPA and the PBGC’s implementation of this critical pension legislation, the proverbial floodgates have opened, as a plethora of new applications are being reviewed. For much of 2026, the PBGC had between 8-10 applications under review at any point in time. There are currently 32 funds, including many new applications that fall within the Second Circuit related to plans that suffered a mass withdrawal prior to 2020, that are seeking Special Financial Assistance. If those applications are approved, another $1.4+ billion will go to support 63.4k plan participants.

However, there is one wrinkle for which I need to get more info. California Winery Workers’ Pension Plan, Fresno, CA, which is NOT located in NY, CT, or VT, submitted an application on 8/21/26. This is the first non-Second Circuit mass withdrawal plan to submit an application for SFA. We were led to believe that only plans from the three states within the Second Circuit would be permitted to file for SFA. Will this development prove to be a one-off?

In other ARPA news, Retail Bakers’ Pension Trust Fund of St. Louis, a non-priority plan, had its revised application approved. They will receive $6.5 million for the 566 members.

Pleased to report that no applications were denied or withdrawn during the previous week, and one fund, Defined Benefit Plan for the Operative Plasterers’ and Cement Masons’ International Association Local Union 394 Pension Trust Fund, was added to the waitlist, as another mass withdrawal casualty prior to 2020.

Clearly, we have some homework to do to understand the circumstances surrounding the application submitted by the Winery Workers. In the meantime, it is great to see that fourteen Second Circuit plans are now in the queue to potentially receive SFA.

08.24.26
by

ARPA Update as of August 21, 2026

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

Welcome to the last full week of August. How is that possible? What does the final third of 2026 have in store for us? Equity investors will hope that the good times roll, while active fixed income managers/investors hope that something changes to stabilize U.S. rates and their near-term prospects. Let’s not forget the mid-terms. The next four months should be quite interesting.

Regarding the PBGC’s implementation of the ARPA pension legislation, last week proved to be busy, as 6 pension funds submitted applications seeking special financial assistance (SFA). One of the five, Bindery Industry Employers GCC/IBT Pension Plan, a Priority Group 1 plan, submitted a revised application. Bindery first submitted an application back in February 2023. They are seeking $18.8 million for 686 members of its plan. The other five applicants are all listed as having been impacted by mass withdrawal prior to 2020. Collectively they are requesting $128.4 million for 3,272 participants. As reported previously, the PBGC is accepting applications from those plans located in the Second Circuit (NY, CT, and VT), and each of these five plans are domiciled in NY.

In other news, there were no plans receiving approval, but there were also no plans being denied based on ineligibility. Furthermore, there were no plans withdrawing an application in the prior week, too.

There remains plenty of work for the PBGC as they currently sit with 19 applications in front of them. The good news for those potential SFA recipients: U.S. interest rates remain inflated providing those plans with the potential to significantly reduce the cost of those future benefits that they will be covering. I implore those plans to secure the promises through a cash flow matching (CFM) implementation. There is so much more downside risk to potential reward by choosing to go active with allocations to both core fixed income and equities.

08.17.26
by

ARPA Update as of August 14, 2026

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

This post is being produced on my flight to Chicago, where I will be speaking at the NCPERS conference on Wednesday. Importantly, I will once again be talking about cash flow matching (CFM), but in the context of a successful implementation of the strategy for a defined benefit pension plan. As many recipients of the Special Financial Assistance (SFA) have found, CFM SECURES the promised benefits, while providing the necessary monthly liquidity to meet ongoing benefits (and expenses) chronologically. I hope that you have a great week.

This past week saw revised applications submitted by Building Trades Pension Fund of Western Pennsylvania and Iron Workers’ Pension Trust Fund for Colorado. They are seeking a combined $55.7 million in SFA for their 5,573 participants.

Non-priority group member, Building Trades Pension Fund of Western Pennsylvania, withdrew its revised application. They’d been seeking $39.7 million in SFA for the 3,907 members of their plan.

Happy to report that there were no pension funds denied the opportunity to file an SFA application and none required to refund a portion of the SFA due to census errors. I think that it is safe to assume that we’ve seen the last of the census problems that plagued initial application filers.

You may recall that I mentioned Retirement Plan of Local 1102 Retirement Fund as being the first of the “Mass Withdrawal” plans to be allowed to submit an application. I now have a better understanding of the likely direction that the PBGC will be taking thanks to Rich Hudson, First Actuarial. According to Rich, the PBGC will only allow multiemployer plans located in the Second Circuit (VT, CT, and NY) to submit applications since it was the Second Circuit that ruled that the Plans Terminated by Mass Withdrawal before 2020 Plan Year were eligible to seek SFA provided that met the other requirements. It appears that plans located in the other Circuits – there are 13 U.S. federal Courts of Appeal, including the D.C. Circuit and the Federal Circuit – will not get the opportunity to file before the ARPA legislation concludes at the end of 2026. I’m sure that there will be more on this issue to discuss.

03.24.26
by

ARPA Update as of March 20, 2026

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

I’m sure that folks were very (perhaps bitterly) disappointed not to get my weekly update yesterday on the PBGC’s implementation of the ARPA pension legislation. I was traveling for business yesterday, but unlike many travelers, my experience at Newark Airport was shockingly positive. I have heard of 4-6 hour waits to get through security and planes that are forced to leave the gate with as few as 5 passengers. Various estimates put the daily impact of these disruptions at $285 million to $580 million once a 10% reduction in flights occurs.

What about ARPA? As regular readers know, the PBGC has worked through a significant majority of non-mass withdrawal applicants. There remains just one fund – Plasterers Local 79 Pension Plan – that hasn’t gotten to submit an initial application form those on the waitlist. There are still a few pension funds from the original Priority Groups that haven’t filed an initial application seeking SFA.

During the prior week, Cumberland, Maryland Teamsters Construction and Miscellaneous Pension Plan received approval of its revised SFA application. They will receive $9.5 million for their 101 plan members. Congrats!

In other news, there is no other news, as there were no new applications submitted, as the PBGC’s eFiling portal remains temporarily closed. Also, there were no applicants denied, no plans were asked to repay a portion of the SFA, and no applications were withdrawn or added to the waitlist.

The treatment of the 80 plans (from potentially 131) currently on the waitlist that fall under the category of plans suffering mass withdrawal prior to 2020 is the last remaining significant issue that the PBGC must still work through.

U.S. Treasury yields have risen sharply since the beginning of the Iran conflict. As challenging as that development is on existing bond funds, the entry point for SFA recipients wanting to use CFM to secure the benefits and expenses is as good as it has been in more than 1-year. As a reminder, higher yields reduce the cost of those future promises.

03.16.26
by

ARPA Updated as of March 13, 2026

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

I’ll be wearing my green tomorrow. How about you? Perhaps the luck of the Irish will carry some weight with the PBGC during the upcoming week, but it didn’t have much sway last week.

The PBGC accepted two revised applications for Special Financial Assistance (SFA) for the week ending March 13th. Iron Workers Local No. 12 Pension Fund and the Iron Workers-Laborers Pension Plan of Cumberland, Maryland submitted revised applications. Together they are seeking a modest $24.2 million for their 1,413 plan participants. The PBGC will have 120-days to act on the applications.

According to the PBGC’s website, their e-Filing Portal remains temporarily closed. As discussed previously, there is one fund currently on the waitlist that hasn’t submitted an initial application that is not classified as a Plan Terminated by Mass Withdrawal before 2020 Plan Year.

In other ARPA news, there were no applications approved or denied in the past week, and none withdrawn. The PBGC currently has 15 applications under review, including nine that are an initial application. Fortunately, it seems as if any SFA recipient that might have had to repay a portion of the grant due to census issues has done so at this point. There have been no payments of excess funds since last September.

There has not yet been a public, plan‑by‑plan PBGC resolution of the mass‑withdrawal‑terminated plans on the SFA waitlist. As previously mentioned, the legal landscape has changed (2025) which puts pressure on the PBGC oversight. What changed from the original interpretation of “eligible plans” was the Second Circuit’s decision held that the SFA statute does not exclude multiemployer plans that had previously terminated by mass withdrawal, reversing PBGC’s denial of SFA to a fund that terminated in 2016. Furthermore, the court read ARPA’s “critical and declining” language to focus on status in the 2020–2022 window, and rejected PBGC’s position that lack of ongoing “zone status” or prior termination automatically barred eligibility.

As a result, the PBGC’s Office of Inspector General (OIG) issued a 2025 risk advisory flagging that the appellate decision opens the door for 123 terminated plans to seek SFA (80 currently on the waitlist), 91 of which are terminated and insolvent and 32 that are terminated but not yet insolvent and have not received traditional financial assistance.​ The OIG estimates that if SFA is ultimately provided to that group, gross SFA exposure could be on the order of billions of dollars. But, just think about the American Workers that might eventually recoup their promised benefits.

03.02.26
by

ARPA Update as of February 27, 2026

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

Welcome to March and all the “madness” that comes with it!

Regarding ARPA and the PBGC’s implementation of this critical pension legislation, last week proved to be fairly quiet, and I imagine it will continue to be so, as the PBGC works through the remaining applications currently under review (14) and those that will likely be resubmitted (25). Quiet, unless some action is taken on the 80 plans sitting on the waitlist that were terminated by mass withdrawal prior to 2020.

During the past week there were no applications approved or denied, no pension plans were asked to repay a portion of their SFA and no pension funds asked to be added to the waitlist.

In other news, there was one revised application filed. Bricklayers Local No. 55 Pension Plan, a non-priority group member, is seeking $6.4 million for its 483 members. The PBGC has 120-days to review and approve the application before it is automatically accepted. The only other news of note related to two pension funds that withdrew applications. Non-priority group member, Retail Bakers’ Pension Trust Fund of St. Louis, withdrew its initial application. They’d been seeking $5.7 million for 566 plan members. Warehouse Employees Union Local 169 and Employers Joint Pension Plan, another non-priority group member, withdrew an already revised application in which they were hoping to secure $77.8 million for 3,609 plan participants.

The uncertainty related to action in Iran has U.S. Treasury yields rising across the Treasury yield curve as inflation concerns once again come into focus. Rising rates are challenging for bond investors unless a cash flow matching (CFM) strategy has been used. As a reminder, CFM will secure the promised benefits (and expenses, if desired) for as long as the SFA allocation lasts. As a reminder, those B&E are future values which are not interest rate sensitive. Importantly, higher interest rates will create more cost savings related to those future promises for pension plans still waiting to receive their SFA.

02.10.26
by

ARPA Update as of February 6, 2026

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

It looks like those of us in the Northeast will finally get some respite from the bitter cold, as temps will moderate this week and actually hit the 30s. However, those multiemployer pension plans currently sitting on the waitlist and classified as a Plan Terminated by Mass Withdrawal before 2020 Plan Year, continue to be frozen in place. According to the PBGC’s latest update, there are 80 plans that fall under the Mass Withdrawal classification. I’ll share more info on this subject later in this post.

Regarding last week’s activity, the PBGC is reporting that one fund, Operative Plasterers & Cement Masons Local No. 109 Pension Plan, a Troy, MI, construction union, will receive $13.7 million for the 1,439 plan members. In addition to the one approval, there was another fund that withdrew its initial application. Norfolk, VA-based International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Local No. 79 Pension Fund was seeking $14.6 million in SFA for 462 participants in the plan.

There were no applications submitted for review. It appears that only one non-mass withdrawal plan, Plasterers Local 79 Pension Plan, remains on the waitlist. Fortunately, there were no plans asked to rebate a portion of the SFA grant due to census errors or any funds deemed no eligible.

Regarding the 80 mass withdrawal funds currently sitting on the waitlist, MEPs terminated by mass withdrawal under ERISA §4041A(a)(2) are explicitly ineligible for SFA under ARP/IRA rules, regardless of application timing. Furthermore:

No “initial application” option exists post-termination date.

Mass withdrawal means that all/substantially all employers completely withdraw leading to a plan termination.

PBGC SFA statute excludes §4041A(a)(2) terminated plans.

For the 80 funds sitting on the waitlist, it seems like a long shot that the APRA legislation will be amended to accommodate these funds seeking SFA. I’ll continue to monitor this situation in future posts.

02.02.26
by

ARPA Update as of January 30, 2026

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

So much for escaping the bitter cold in New Jersey by flying to Orlando, FL. The reality is that Orlando is sitting at 25 degrees this morning (Sunday 2/1). Someone is playing a nasty trick on all those snowbirds. It is a good thing for me that I’ll be spending most of my time in a conference room until Wednesday (FPPTA). I hope that you have a great week.

Regarding ARPA and the PBGC’s continuing implementation of this critical legislation, there was activity last week, and some of it was surprising. As I’ve mentioned on several occasions, the ARPA legislation specifically states that all initial applications seeking special financial assistance (SFA) needed to be submitted to the PBGC by 12/31/25. Revised applications could be resubmitted after that date and until 12/31/26. That said, there were three initial applications filed with the PBGC during the week ending January 30th. What gives?

In other news, Cincinnati-based Asbestos Workers Local No. 8 Retirement Trust Plan received approval for SFA. They will get $40.1 million to support their 451 plan participants. In other news, Local 1814 Riggers Pension Plan, withdrew its initial application which had been filed through the PBGC’s e-Filing portal last October. They are hoping to secure a $2.5 million SFA grant for their 65 members.

Fortunately, there were no previous recipients of SFA asked to repay a portion of the grant due to census errors nor were any applications denied due to eligibility issues. Lastly, no new pension plans asked to be added to the waitlist which currently numbers more than 80 systems.

The U.S. Treasury yield curve remains steep, with 30-year bond yields exceeding the yield on the 2-year note by 1.34% as of Friday’s closing prices. This steepening provides plan sponsors and grant recipients with attractive yields on longer maturity cash flow matching programs used to secure the promised benefits.

01.20.26
by

ARPA Update as of January 16, 2026

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

We hope that the continuing success of the ARPA pension legislation warms your heart despite ridiculously cold temperatures in New Jersey and elsewhere.

Regarding last week’s activity, pleased to report that two plans received approval for their SFA applications. Pension Trust Fund Agreement of St. Louis Motion Picture Machine Operators and Teamsters Local 837 Pension Plan, both non-priority group members, will receive a combined $19.9 million in SFA and interest for their 1,431 members. These approvals are the first for the PBGC in just under one month.

In other ARPA news, there were no new applications filed, as the e-Filing portal remains temporarily closed. In addition, as we’ve been reporting, the window for initial applications to be submitted was to close on 12/31/25. From this point forward, only revised applications should be received by the PBGC. Despite that impediment, two more funds, NMU Great Lakes Pension Fund and UFCW Pension Fund of Northeastern Pennsylvania, added their names to the extensive waitlist seeking Special Financial Assistance. These plans and the others currently on the list must believe that the current deadline in place will be amended.

There was one application withdrawn during the prior week, as the Dairy Employees Union Local #17 Pension Plan pulled their initial application seeking $3.5 million in SFA for the 633 plan participants. Under the current rules, they have until 12/31/26 to resubmit a revised application.

Lastly, there were no applications denied nor were any of the previous recipients of SFA asked to rebate a portion due to census errors.

The U.S. interest rate environment is reacting to some of the global uncertainty. As a result, longer dated Treasury yields are marching higher. As of 9:51 am, the yield on the 30-year Treasury bond is 4.93%, while the 10-year Treasury note yield is at 4.29%. These yields are quite attractive for plans receiving SFA and wanting to secure benefits and expenses with the proceeds. Don’t miss this opportunity to significantly reduce the cost of those future benefits.

12.29.25
by

A Time to Look Back

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

Nearly eight years ago (2/28/18), I produced a blog post titled, “Let’s Just Cut Them Off!”, in which I took offense to an article trashing pension legislation then referred to as the “Butch Lewis Act” (BLA). The writer of the article, Rachel Greszler, The Heritage Foundation, stated that the BLA (as well as other potential solutions at that time) were nothing more than tax-payer bailouts.  She estimated that these bailouts could amount to as much as $1 trillion. I stated at that time that “I don’t know where she has gotten this figure, but it is not close to reality.”

Ms. Greszler defined the potential recipients of these loans (now grants) as the entire universe of multi-employer plans totaling roughly 1,375 (at that time) with an unfunded liability of $500 billion.  However, the Butch Lewis Act, and subsequently ARPA) was only designed for those plans that were designated as “Critical and Declining”.  The total amount of underfunding for that cohort was roughly $70 billion.  A far cry from the $1 trillion that she highlighted above.

So, where are we today? I’m happy to report that as of 12/19/25, the PBGC has approved Special Financial Assistance to 151 pension plans totaling $75.2 billion. These grants are ensuring that 1,873,112 American workers will receive the retirement benefits they were promised! Amazing!

In my original post, I wrote “given the author’s concern for the million or so union workers whose benefits may be trashed, she certainly doesn’t propose any solutions other than to say that a “bailout” is a horrible way to go.  If these plans don’t receive assistance, they are likely to fail, placing a greater burden on the Pension Benefit Guaranty Corporation (PBGC), which is already financially troubled.” Fortunately, through the ARPA pension legislation, the PBGC’s multiemployer insurance fund is stronger today than it has been in decades.

I finished my post with the following thoughts: “Retirement benefits stimulate economic activity, and usually on the local level. The loss of retirement benefits will have a direct impact on these economies. Also, these benefits are taxed, which helps pay for a portion of the loans (now grants). Doing nothing is not an answer. I applaud the effort of those individuals who are driving the Butch Lewis Act. I encourage everyone to reach out to your legislatures to educate them on the BLA and to gain their support. There are millions of Americans who need your support.  Thank you!”

I was thrilled to work with Ron Ryan and the BLA team headed by John Murphy and David Blitzstein. It remains one of the highlights of my 44-year career. Who knew when I began working with Ron and that team it would lead me to eventually join Ryan ALM, Inc. We continue to fight to protect and preserve DB pensions for the masses. There is a ton of work remaining to do. Securing those promises through cash flow matching (CFM) is an important first step. Let us help you accomplish that objective.