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.

Good Question!

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

We occasionally post questions received in reaction to our blogs in new blog posts since many of our readers might have similar thoughts/ideas. In reaction to yesterday’s post, “All-time High Funded Ratio” a reader calling themselves LoudlyObservant (great name) stated the following:

Why wouldn’t such well-funded plans take steps to lock in the funding of their beneficiary payments through a cash flow matching portfolio? Isn’t the first fiduciary duty of loyalty expressed in controlling the relevant risk to the beneficiaries, which involves BOTH securing adequate assets and then actually funding the payments? Many of these plans have hit the first goal but are still exposed to funding risk. With a ready solution at hand, the plan sponsors open themselves to criticism for not acting on their second responsibility.

Thank you, Loudly! Great questions and observations. We often talk about the fact that pension plans at all funding levels need liquidity, not just well-funded plans, but when you have a universe of plans that on average are fully funded, why not dramatically reduce risk. We witnessed what happened to DB pension plans at the end of 1999, when most plans were well overfunded only to see the funded status plummet and contribution expenses explode following two major market corrections.

I’m neither smart enough nor is my crystal ball better than anyone else’s to know if a major market correction is on the horizon but why take the chance unnecessarily. We’ve seen a significant percentage of Special Financial Assistance (SFA) recipients engage in cash flow matching to secure the SFA assets and the benefits that they will protect. Why not adopt CFM for the legacy assets, too? As we’ve mentioned, we are providing a service to you and your plan participants. It isn’t just another product. Time to get off the proverbial rollercoaster of returns and secure the promises and your plan’s funded status.

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.

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.

ARPA Update as of December 12, 2025

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

Unlike the Northeast, access to the PBGC’s e-Filing portal is thawing. According to the PBGC’s website, “the e-Filing Portal is open only to plans at the top of the waiting list that have been notified by PBGC that they may submit their applications. Applications from any other plans will not be accepted at this time.” Despite the dozens of multiemployer plans that remain on the waitlist, the floodgates have certainly not opened.

In fact, only two plans were permitted to submit applications last week. UFCW – Northern California Employers Joint Pension Plan, a Priority Group 6 member, submitted a revised application seeking >$2.3 billion for nearly 140k members, while UFCW, Local 23 and Giant Eagle Pension Plan, a non-priority group member, filed an initial application hoping to garner $40 million in SFA for 7,100 plan participants.

In other news, Dairy Industry-Union Pension Plan for Philadelphia and Vicinity, Warehouse Employees Union Local No. 730 Pension Trust Fund, and Cleveland Bakers and Teamsters Pension Plan received approval for SFA grants. Collectively they will receive $303.4 million (including interest and loan repayments) for 13,533 plan participants. There have now been 150 plans approved for SFA totaling just over $75 billion in grants.

Fortunately, there were no plans asked to repay a portion of the SFA due to census errors, no plans denied a filing, and no withdrawals of previously submitted applications. There were two more funds added to the waitlist and nine that locked in their valuation dates, including the two most recent additions to the waitlist. There remain 85 applications that have yet to be submitted to the PBGC.

Recent Federal Reserve interest rate action has rates on the long-end of the yield curve ratcheting higher. The 30-year Treasury Bond’s yield is at 4.83% (12:-5 pm). Comparable 30-year IG corporates are trading at yields close to 6% at this time. It remains an excellent time to secure the promised benefits through a CFM strategy.

ARPA Update as of December 5, 2025

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

Welcome to the first review of December 2025. We aren’t quite at the beginning of winter, but you could sure fool me, as New Jersey is gripped by cold front and we saw our first modest snowfall just in time for me to start decorating my house for Christmas. I hope that you had a wonderful weekend.

With regard to ARPA and the PBGC’s implementation of this critical legislation, there was a little reported activity last week, but certainly not enough to make a dent in the current waitlist. Unfortunately, the PBGC’s e-Filing portal remains temporarily closed. Despite that fact, pension plans continue to be added to the waitlist. USW District 10, Local 286 Pension Plan is the latest fund, making it the 186th non-priority group plan added since the start of the program. By my estimate, there are still 83 pension funds sitting on the waitlist hoping to get a chance to submit an application for SFA grant $.

In other APRA news, two pension funds received approval to receive the SFA. Teamsters Local 210 Affiliated Pension Plan and Local Union 1710 I.B.E.W. Pension Trust Fund, both non-priority plans, will receive a total of $149.2 million in SFA for just over 9,500 participants. As mentioned above, the PBGC’s e-Filing portal remains temporarily closed, so there were no additional applications received during the week. There are currently 24 applications in front of PBGC staff.

In addition, there were no plans asked to rebate a portion of their SFA grant due to census errors, and there haven’t been since mid-September. Fortunately, no plans were denied the ability to submit an application due to the lack of eligibility and no applications were withdrawn. However, there were six plans that locked-in a valuation date, as each chose 9/30/25 as the plan’s measurement date. There are still 14 plans on the waitlist that haven’t chosen to lock-in a valuation date.

With the two approvals from last week, there are now 147 plans that have or will soon receive Special Financial Assistance totaling $74.7 billion supporting the earned pensions for 1.85 million American workers and retirees. Outstanding! That is a lot of economic stimulus that helps more than just the recipient of the retirement benefit, but also the communities in which they reside.

ARPA Updated as of November 28, 2025

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

We hope that you enjoyed a fabulous Thanksgiving holiday with your family and friends. This update is the last one for November. Wow, that month went by quickly.

Regarding the ARPA legislation, have we entered the last month for new applications to be received by the PBGC? As I’ve mentioned multiple times, the ARPA pension legislation specifically states that initial applications must be submitted to the PBGC by 12/31/25. Revised applications can be submitted through 12/31/26. If this is the case, we have roughly 83 applications yet to be submitted. Compounding this issue is the fact that the PBGC’s e-Filing portal is temporarily closed.

The PBGC’s recorded activity was light last week which shouldn’t surprise anyone given the holiday last week. There were no applications received, denied, or withdrawn. Furthermore, there were no recipients of Special Financial Assistance (SFA) requested to rebate a portion of the grant payment due to census issues. Thankfully, it has been more than two months since we last had a plan pay back a small percentage of the proceeds.

There was some good news, as Exhibition Employees Local 829 Pension Fund, a non-priority group member, received approval of its initial application. The fund will receive $14.2 million in SFA for the 242 plan participants. This pension plan became the 70th non-priority plan to receive SFA and the 145th overall. To-date, $72.8 billion in SFA grants have been awarded!

Despite the near unanimity by market participants that U.S. Treasury yields will fall as the Fed’s FOMC prepares another Fed Funds Rate cut, interest rates are rising today. The current level of Treasury yields and bonds that price off that curve are still providing SFA recipients with attractive rates in which to secure the promised benefits through a cash flow matching (CFM) strategy. Don’t subject the SFA to the whims of the markets, especially given so much uncertainty and currently high valuations.

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.

ARPA Update as of October 24, 2025

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

If it is a Monday, it is ARPA/SFA update day. I’m bringing you this update from Fort Lauderdale, FL, where I’m attending and speaking at the NCPERS Fall conference. It looks like a wonderful agenda for the next few days. Regarding ARPA, how did the PBGC do last week? Let’s explore.

Last week saw limited action with only two applications received, including a revised application from a Priority Group 1 member. As you may recall, this was the first group permitted to submit applications all the way back in July 2021! Only 25 of the 30 members of that cohort have received Special Financial Assistance to date. Richmond, VA based Bricklayers Union Local No. 1 Pension Fund of Virginia, submitted a revised application seeking $12.9 million for its 395 participants, while International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Local No. 79 Pension Fund, submitted an initial application hoping to secure $14.6 for 462 members. As an aside, the Ironworkers would be golden if the SFA desired was based on the length of the plan’s name.

In other ARPA news, or lack thereof, there were no applications approved, and fortunately, none denied. There were no pension plans forced to withdraw an application and none asked to repay a portion of the SFA received due to census errors. However, there was one more plan added to the burgeoning waitlist. The Soft Drink Industry Pension Fund is the 178th none-priority group fund to add its name to the list.

The next couple of months should be quite exciting for the PBGC as it works through the abundant list of applications for non-priority group members. U.S. interest rates have pulled back recently reducing some of the potential coverage period through a CFM strategy, but rates are still significantly higher than they were in 2021 when ARPA began to be implemented. Please reach out to us if you’d like to get a free analysis on what is possible once the SFA is received.

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.