Tag Archives: Ryan ALM

09.05.25
by

Today is National 401(k) Day. Where is National DB Pension Plan Day?

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

I suspect that most of us have no idea that today, September 5, 2025, is National 401(k) Day. This day is recognized every year on the Friday following Labor Day. The day is supposed to be an opportunity for retirement savings education and for companies to inform their employees about their ability to invest in company sponsored 401(k)s. Did you get your update today? Unfortunately, like many small company employees, I don’t have access to one or a DB plan.

For the uninformed, 401(k) plans are defined contribution plans (DC). This plan type was created in the late 1970s (Revenue Act of 1978) as a “supplemental” benefit. Corporate America liked the idea of a DC offering because it helped them recruit middle and senior management types who wouldn’t accrue enough time in the company’s traditional pension plan. Again, the benefit was supplemental to the traditional monthly pension payment and not in lieu of it!

I think that defined contribution plans are fine as long as they remain supplemental to a DB plan. Asking untrained individuals to fund, manage, and then disburse a retirement benefit is a ridiculous exercise, especially given their lack of disposable income, investment acumen, and NO crystal ball to help with longevity issues. In fact, why do we think that 99.9% of Americans have this ability? Regrettably, we have a significant percentage (estimated at 28%) of our population living within 200% of the poverty line. Do you think that they have any discretionary income that would permit them to fund a retirement benefit when housing, health insurance, food, education, childcare, and transportation costs eat up most, if not all, of an individual’s take home pay? Remember, these plans are only “successful” based on what is contributed. Sure, there may be a company match of some kind, but we witnessed what can happen during difficult economic times, when the employer contribution suddenly vanishes.

Defined benefit plans are the gold standard of retirement vehicles. They once covered more than 40% of the private sector workforce, most union employees, and roughly 85% of public sector workers. What happened? Did we lose focus on the primary objective in managing a DB plan which is to SECURE the promised benefits in a cost-effective manner with prudent risk? Did our industry’s focus on the return on asset assumption (ROA) create an untenable environment? Yes, we got more volatility and less liquidity! Did we did we get the commensurate return? Not consistently. It was this volatility of the funded ratio/status that impacted the financial statements and led to the decision to freeze and terminate a significant percentage of private DB plans. It is a tragic outcome!

What we have today is a growing economic divide among the haves and haves-not. This schism continues to grow, and the lack of retirement security is only making matters worse. DB plans can be managed effectively where excess volatility is not tolerated, where the focus is on the promised benefit and not some made up ROA, and where decisions that are made relative to investment structure and asset allocation are predicated on the financial health of the plan: mainly the funded status. We need DB plans more than ever and ONLY a return to pension basics will help us in this quest. Forget about all the newfangled investment products being sold. Replacing one strategy for another is no better than shifting deck chairs on the Titanic. We need improved governance and a renewed focus on why pensions were provided in the first place.

09.03.25
by

Ryan ALM discount rates: ASC 715 and ASC 842

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

As we enter the final third of 2025 (how is that possible?), actuaries, accounting firms, and pension plan sponsors may begin reviewing their current discount rate relationship(s). If you are one of those, you may want to speak with us about the Ryan ALM discount rates. Since FAS 158 became effective December 15, 2006, Ryan ALM has created a series of discount rates in conformity to then FAS 158 (now ASC 715). Our initial and continuous client is a BIG 4 accounting firm, which hopefully testifies to the integrity of our data.

The benefits of the Ryan ALM ASC 715 Discount Rates are:

  1. Selection – we provide four yield curves: High End Select (top 10% yields), Top 1/3, Above Median (top 50%), Full Universe
  2. Transparency – we provide very detailed info for auditors to assess accuracy and acceptability of our rates
  3. Precision – precise and consistent reflection of current/changing market environment (more maturity range buckets, uses actual bond yields rather than spreads added to Treasury yield curve, no preconceived curve shape/slope bias relative to maturity/duration) than most other discount rate alternatives  
  4. Competitive Cost – our discount rates are quite competitive versus other vendors and can be purchased with a monthly, quarterly, or annual subscription
  5. Flexibility – we react monthly to market environment (downgrades, gaps at certain maturities) with flexibility in model parameters to better reflect changing environment through variable outlier exclusion rules, number of maturity range buckets, and minimum numbers of bonds in each maturity range bucket to better capture observed nuances in the shape of the curve, especially at/near the 30 year maturity point where the market is sparse or nonexistent at times.
  6. Clients – our rates are used by individual plan sponsors, several actuarial and accounting firms including, as stated above, a Big 4 accounting firm
  7. Integration into Ryan ALM products – we use ASC 715 discount rates for our Custom Liability Index and Liability Beta Portfolio™ (cash flow matching) products

Development of our discount rates is the first step in our turnkey system to defease pension liabilities through a cash flow matching (CFM) implementation. Our Custom Liability Index (CLI) and Liability Beta Portfolio (LBP) are the other two critical products in our de-risking process/capability.

In addition to ASC 715, Ryan ALM provides ASC 842 rates, which is the lease accounting standard issued by the Financial Accounting Standards Board (FASB). This standard supersedes ASC 840 and became effective December 15, 2018, for public companies and December 15, 2021, for private companies and nonprofit organizations. Given the widespread prevalence of off-balance sheet leasing activities, the revised lease accounting rules are intended to improve financial reporting and increase transparency and comparability across organizations. ASC 842 will provide management better insight into the true extent of their lease obligations and lead to improvements in capital allocation, budgeting and lease versus buy decisions.

The discount rate to be used is the rate implicit in each lease. This could be difficult and not readily determined. In that case ASC 842 requires the lessee to use the rate that the company borrows at based on their credit rating. Ryan ALM can provide the ASC 842 discount rates based on each lessee borrowing rate or credit rating (i.e. A or BBB). We can provide these discount rates monthly, quarterly or whatever frequency is needed.

We’d be pleased to discuss with you our discount rates or any element of this state-of-the-art capability.

09.02.25
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.

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.

08.22.25
by

Confusing the Purpose!

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

There recently appeared in my inbox an article from an investment advisory firm discussing Cash Flow Driven Investing (CDI). Given that CDI, or as we call it Cash Flow Matching (CFM), is our only investment strategy, I absorb as much info from “competitors” as I can.

The initial point in the article’s summary read “There is no one-size-fits-all approach for cashflow driven investment strategies.” We concur, as each client’s liabilities are unique to them. Like snowflakes, there are no two pension plan liability streams that are the same. As such, each CDI/CFM portfolio needs to reflect those unique cash flows.

The second point in their summary of key points is where we would depart in our approach. They stated: “While most will have a core allocation to investment grade credit, the broader design can vary greatly to reflect individual requirements.” This is where I believe that the purpose in using CFM is confused and unnecessarily complicated. CFM should be used to defease a plan’s net outflows with certainty. At Ryan ALM, Inc. we use 100% of the bond assets to accurately match the liability cash flows most often through the use of investment-grade corporate bonds. Furthermore, It is a strategy that will reduce risk, while stabilizing the plan’s funded status and contribution expenses associated with the portion of the liability cash flows that is defeased. It is not an alpha generator, although the use of corporate bonds will provide an excess yield relative to Treasuries and STRIPS, providing some alpha.

As we’ve discussed many times in this blog, traditional asset allocation approaches having all of the plan’s assets focused on a return objective is inappropriate for the pension objective to secure and fully fund benefits in a cost-efficient manner despite overwhelming use. We continue to espouse the bifurcation of the assets into liquidity and growth buckets. The liquidity bucket should be an investment-grade corporate bond portfolio that cash flow matches the liability cash flows chronologically from the next month as far out as the allocation will cover. The remaining assets are the growth or alpha assets that now have time to grow unencumbered.

Why take risk in the CFM portfolio by adding emerging markets debt, high yield, and especially illiquid assets, when the purpose of the portfolio is to create certainty and liquidity to meet ongoing benefits and expenses? If the use of those other assets is deemed appropriate, include them in the alpha bucket. As a reminder, CFM has been used successfully for many decades. Plan sponsors live with great uncertainty every day, as markets are constantly moving. Why not embrace a strategy that gives you a level of certainty not available in other strategies? Use riskier strategies when they have time to wade through potentially choppy markets. CFM provides such a bridge. If you give most investment strategies a 10-year time horizon without the need to provide liquidity, you dramatically enhance the probability of achieving the desired or expected outcome.

Unfortunately, we have a tendency in our industry to over-complicate the management of pensions. Using a CFM strategy focused on the plan’s liabilities, and not the ROA, brings the management of pensions back to its roots. Take risks when you have the necessary time. Focusing the assets on the ROA creates a situation in which one or more assets may have to be traded (sold) in order to meet the required outflows. Those trades might have to be done in environments in which natural liquidity does not exist.

08.20.25
by

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.

08.18.25
by

ARPA Update as of August 15, 2025

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

Hard to believe that we are nearly 2/3rds of the way through 2025. I suspect that the PBGC is having a hard time with that reality given the workload that remains with 119 multiemployer plans still seeking a successful review of their SFA application. Seventy-one applications have yet to be submitted through the PBGC’s e-Filing portal.

As for last week, there were no applications approved and none have been since July 29, when Laborers’ Local No. 130 Pension Fund received $33.3 million in SFA to support its 641 plan participants. However, there were 3 applications submitted for review. These applications were from none-priority group members submitting revised applications. There are currently 30 applications before the PBGC, which has 120-days to act on each or they are automatically approved.

I’m pleased to report that no applications were denied or withdrawn during the previous week. There were also no pension funds required to repay a portion of the SFA deemed excessive due to census errors. It has been since August 1, 2025, that we’ve had a fund repay a portion of the SFA. There was one new fund added to the waitlist, which now stands at 162 members. Chicago Foundry Workers Pension Plan added its name to the list on August 11th. As reported above, there are still 71 multiemployer plans that have not submitted applications at this time.

As you may recall, when the Butch Lewis Act was first contemplated, the folks at Cheiron initially defined the potential universe of SFA recipients as 114 funds. Today there are 249 funds seeking SFA support, of which 130 have already been approved. As a reminder, eligible plans must apply for SFA by December 31, 2025. Those filing revised applications have until December 31, 2026. Any distribution of SFA must be completed by September 30, 2030, due to legislative sunset rules.

The PBGC is averaging about 6-7 submissions per month. Based on that pace, it doesn’t seem possible that many of the 71 members on the waitlist that haven’t submitted applications will be able to meet that 2025 deadline. More to come.

08.14.25
by

Are Investors About to Get Their Comeuppance?

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

As we’ve discussed in this blog on many occasions, the U.S. interest rate decline from 1982 to 2022 fueled risk assets well beyond their fundamentals. During the rate decline, investors became accustomed to the US Federal Reserve stepping in when markets and the economy looked dicey. There seems to be a massive expectation that the “Fed” will once again support those same risk assets by initiating another rally through a rate decline perhaps as soon as September. Is that action justified? I think not!

Recent inflation data, including today’s PPI that came in at 0.9% vs. 0.2% expected, should give pause to the crowd screaming for lower rates. Yes, employment #s published last week were very weak, and they got weaker when Erika McEntarfer, the commissioner of the Bureau of Labor Statistics, was fired after releasing a jobs report that angered President Donald Trump. In addition, we have Secretary of the Treasury, Scott Bessent, demanding rates be cut by as much as 150-175 bps, claiming that all forecasting “models” suggest the same direction for rates. Is that true? Again, I think not.

You may recall that I published a blog post on July 10, 2025 titled “Taylor-Made”, in which I wrote that the Taylor Rule is an economic formula that provides guidance on how central banks, such as the Federal Reserve, should set interest rates in response to changes in inflation and economic output. The rule is designed to help stabilize an economy by systematically adjusting the central bank’s key policy rate based on current economic conditions. It is designed to take the “guess work” out of establishing interest rate policy.

In John Authers (Bloomberg) blog post today, he shared the following chart:

Calling for a roughly 2.6% Fed Funds rate in an environment of 3% or more core and sticky inflation is not prudent, and it is not supported by history. Furthermore, the potential impact from tariffs will only begin to be felt as most went into effect as of August 1, 2025.

Getting back to the Taylor Rule, Authers also provided an updated graph suggesting that the Fed Funds rate should be higher today. In fact, it should be at a level about 100 bps above the current 4.3% and more than 270 bps above the level that Bessent desires.

Investors would be wise to exit the lower interest rate train before it fuels a significant increase in U.S. rates as inflation once again rises. The impact of higher rates will negatively impact all risk assets. Given that a Cash Flow Matching (CFM) strategy eliminates interest rate risk through the defeasement of benefits and expenses that are future values and thus not interest rate sensitive, one could bring an element of certainty to this very uncertain economic environment before investors get their comeuppance! Don’t wait for the greater inflation to appear, as it might just be too late at that point to get off the lower interest rate train before it plummets into a ravine.

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!

07.31.25
by

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?