ARPA Update as of November 14, 2025

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

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

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

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

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

The Times They Are A-Changin’

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

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

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

“Asset Allocation for Today’s Markets”

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

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

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

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

“Entering the Green Zone and Staying There”

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

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

Hey Ryan ALM – What if…?

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

We hope that you are enjoying a wonderful summer season. Thanks for taking the time to visit our blog, where we’ve now produced >1,650 mostly pension-related posts.

I wanted to share the following email exchange from earlier this week. I received an email at 6:40 pm on Monday from a senior member of the actuarial community who is familiar with our work. He said that he had a client meeting on Wednesday and he was wondering if we could model some potential outcomes should the plan decide to take some risk off the table by engaging a cash flow matching strategy (CFM).

The actuary gave us the “net” liabilities (after contributions) for the next 10-years and then asked two questions. How far out into the future would $200 million in AUM cover? If the client preferred to defease the next 10-years of net liabilities, how much would that cost? We were happy to get this inquiry because we are always willing to be a resource for members of our industry, including plan sponsors, consultants, and actuaries.

We produced two CFM portfolios, which we call the Liability Beta Portfolio™ or LBP, in response to the two questions that had been posed. In the first case, the $200 million in AUM would provide the client with coverage of $225.8 million in future value (FV) liabilities through March 31, 2031 for a total cost of $196.3 million. Trying to defease the next 10-years of liabilities would cost the plan $334.8 million in AUM to defease $430 million in net liabilities.

 $200 million in AUM10-year coverage
End Date3/31/31 7/01/35
FV$225,750,000$430,000,000
PV$196,315,548$334,807,166
YTM  4.52%  4.75%
MDur  2.73 years  4.45 years
Cost Savings $-$29,424,452-$95,192,834
Cost Savings %  13.04%   22.14%
Excess CF$230,375$679,563
RatingBBB+  A-

As we’ve mentioned on many occasions, the annual cost savings to defease liabilities averages roughly 2%/year, but as the maturity of the program lengthens that cost savings becomes greater. We believe that providing the necessary liquidity with certainty is comforting for all involved. Not only is the liquidity available when needed, but the remaining assets not engaged in the CFM program can now grow unencumbered.

If you’d like to see how a CFM program could improve your plan’s liquidity with certainty, just provide us with the forecasted contributions, benefits, and expenses, and we’ll do the rest. Oh, and by the way, we got the analysis completed and to the actuary by 12:30 pm on Tuesday in plenty of time to allow him to prepare for his Wednesday meeting. Don’t be shy. We don’t charge for this review.

When Should I Use CFM?

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

Good morning. I’m currently in Chicago in the midst of several meetings. Yesterday’s meetings were outstanding. As you’d expect, the conversations were centered on DB pension plans and the opportunity to de-risk through a Cash Flow Matching strategy (CFM) in today’s economic environment. The line of questioning that I received from each of my meeting hosts was great. However, there does seem to be a misconception on when and how to use CFM as a de-risking tool. Most believe that you engage CFM for only the front-end of the yield curve, while others think that CFM is only useful when a plan is at or near full funding. Yes, both of those implementations are useful, but that represents a small sampling of when and how to implement CFM. For instance:

As a plan sponsor you need to make sure that you have the liquidity necessary to meet you monthly benefits (and expenses). Do you have a liquidity policy established that clearly defines the source(s) of liquidity or are you scurrying around each month sweeping dividends, interest, and if lucky, capital distributions from your alternative portfolio? Unfortunately, most plan sponsors do not have a formal liquidity policy as part of their Investment Policy Statement (IPS). CFM ensures that the necessary liquidity is available every month of the assignment. There is not forced selling!

Do you currently have a core fixed income allocation? According to a P&I asset allocation survey, public pension plans have an average 18.9% in public fixed income. How are you managing that interest rate risk, which remains the greatest risk for an actively managed fixed income portfolio? As an industry, we enjoyed the benefits of a nearly four decades decline in U.S. interest rates beginning in 1982. However, the prior 28-years witnessed rising rates. Who knows if the current rise in rates is a blip or the start of another extended upward trend? CFM defeases future benefit payments which are not interest rate sensitive. A $2,000 payment next month or 10-years from now is $2,000 whether rates rise or fall. As a result, CFM mitigates interest rate risk.

As you have sought potentially greater returns from a move into alternatives and private investments, not only has the available liquidity dried up, but you need a longer time horizon for those investments to mature and produce the expected outcome. Have you created a bridge within your plan’s asset allocation that will mitigate normal market gyrations? A 10-year CFM allocation will not only provide your plan with the necessary monthly liquidity, but it is essentially a bridge over volatile periods as it is the sole source of liquidity allowing the “alpha” assets to just grow and grow. That 10-year program coincides nicely with many of the lock-ins for alternative strategies.

There has been improvement in the funded status of public pension plans. According to Milliman, as of June 30, 2025, the average funded ratio for the constituents in their top 100 public pension index is now 82.9%, which is the highest level since December 2021. That’s terrific to see. Don’t you want to preserve that level of funding and the contribution expenses that coincide with that level? Riding the rollercoaster of performance can’t be comforting. Given what appears to be excessive valuations within equity markets and great uncertainty as it relates to the economic environment, are you willing to let your current exposures just ride? By allocating to a CFM program, you stabilize a portion of your plan’s funded status and the contributions associated with those Retired Lives Liability. Bringing a level of certainty to a very uncertain process should be a desirable goal for all plan sponsors and their advisors.

If I engage a CFM mandate, don’t I negatively impact my plan’s ability to meet the return objective (ROA) that we have established? NO! The Ryan ALM CFM portfolio will be heavily skewed to investment-grade corporate bonds (most portfolios are 100% corporates) that enjoy a significant premium yield relative to Treasuries and agencies. As mentioned previously, public pension plans already have an exposure to fixed income. That exposure is already included in the ROA calculation. By substituting a higher yielding CFM portfolio for a lower yielding core fixed income program benchmarked to the Aggregate index, you are enhancing the plan’s ability to achieve the ROA while also eliminating interest rate risk. A win-win in my book!

So, given these facts, how much should I allocate to a CFM mandate? The answer is predicated on many factors, including the plan’s current funded status, the ability to contribute, whether or not the plan is in a negative cash flow situation, the Board’s risk appetite, the current ROA, and others. Given that all pension systems’ liabilities are unique, there is no one correct answer. At Ryan ALM, we are happy to provide a detailed analysis on what could be done and at what cost to the plan. We do this analysis for free. When can we do yours?