ARPA Update as of February 7, 2025

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

Welcome to February! I am a day late in reporting on the PBGC’s activity from last week, as I was an instructor at the IFEBP’s Advanced Trustee and Administrator’s Conference. Fortunately, it is in Orlando and not New Jersey, where the weather remains cold, snowy, and wet! For one of the first times in my 43-year professional career I’m hoping for a significant flight delay of perhaps three days!

The PBGC’s eFiling portal is now open but defined as limited. During the previous week there was one new application submitted. The Retail Food Employers and United Food and Commercial Workers Local 711 Pension Plan is seeking $64.2 million in Special Financial Assistance (SFA) for their 25,306 plan participants or $2,538.65 per member, which seemed modest, and in fact it is, as the average SFA payout has been $46,385 per beneficiary on applications that have been approved.

In addition to the one new application, two non-priority plans, Laborers’ Local No. 130 Pension Fund and Pension Plan of the Asbestos Workers Philadelphia Pension Fund each withdrew an initial application. Collectively, they are seeking $72.4 million for 2,124 members.

There were no applications denied or approved during the past week. In addition, there were no plans required to repay an overpayment of SFA due to census errors. There hasn’t been a repayment since December 2024. Finally, there were no plans seeking to be added to the waitlist. There are still 49 plans waiting to submit an initial application to the PBGC.

The U.S. interest rate environment remains favorable for plans looking to defease the pension liabilities with the proceeds from the SFA. Investment-grade corporate bond portfolios are currently producing yields above 5% despite very tight spreads between corporates and the comparable maturity Treasury. Given the elevated valuations for domestic equities, particularly large cap stocks, now is the time to use 100% of the SFA to secure the promises.

Not Crunch Time, But the Program is Nearing Its End

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

I frequently get terrific questions following the publishing of one of my blog posts. Today’s question of the day was related to the ARPA pension legislation. I was asked, “Russ when does this legislation expire and when is the final date that a plans application must be submitted?” Terrific question. I’ve been meaning to provide this information as part of one of my weekly ARPA updates. Thanks for the prompt.

According to the final language in the Bill, ‘‘(f) APPLICATION DEADLINE.—Any application by a plan for special financial assistance under this section shall be submitted to the corporation (and, in the case of a plan to which section 432(k)(1)(D) of the Internal Revenue Code of 1986 applies, to the Secretary of the Treasury) no later than December 31, 2025, and any revised application for special financial assistance shall be submitted no later than December 31, 2026.

Furthermore, “The corporation (PBGC) shall not pay any special financial assistance after September 30, 2030.” As an aside, I’m not quite sure how a “revised” application that must be filed by 12/31/26 would not be paid before 2030 is beyond me, especially given the 120-day window to have an application acted on.

As reported in yesterday’s blog post, of the potential 202 applications, 109 have been approved, 21 are currently under review, while another 21 plans have withdrawn the applications. That leaves 51 plans that have yet to file (remember the 12/31/25 deadline) including a Priority Group 1 fund.

So, despite the terrific effort to date, the PBGC clearly has its work cut out for it. Currently, the eFiling portal to submit applications is closed. The PBGC has been opening and closing access to the filing portal based on its ability to meet the 120-day deadline. They may need to accelerate the pace of submissions and approvals in the coming months in order to complete the process by 12/31/26. Obviously, more to come from the PBGC. Also, keep your questions coming!

ARPA Update as of January 31, 2025

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

Somewhat shockingly, one month of 2025 is now in the books. That said, the PBGC continues to implement the ARPA legislation, which will soon celebrate its fourth anniversary since being signed into law on March 11, 2021. By all measures, this has been an incredibly successful program, with much yet to be accomplished with 93 pension plans still in the process of securing Special Financial Assistance (SFA).

The last few weeks have witnessed a moderation in the pace of implementation. The prior week saw no new applications received or approved. There was one application withdrawn, as Rocky Hill, CT-based, Sheet Metal Workers’ Local No. 40 Pension Plan withdrew their initial application seeking $18.8 million in SFA for 984 plan participants. In addition, there was one plan, St. Louis Motion Picture Machine Operators Pension Fund, that locked in the measurement date (liability valuation) as of October 31, 2024. They submitted the request as of January 24, 2025. With this action, there are only 2 plans of the 115 non-priority plans to have not locked in a valuation date.

I’ve previously mentioned the onerous impact of MPRA which passed in 2014. Fortunately, the PBGC/ARPA provided SFA of $477 million to restore to the 18 plans affecting 11 unions that under MPRA had reduced benefits an average of 22% for 60,620 retirees in pay status with some plans reducing benefits as much as 55 percent. These plans received an additional $3.5 billion in SFA to help ensure they remain solvent and able to pay all 87,862 participants in those plans their full retirement benefits through at least 2051.

ARPA Update as of January 17, 2025

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

I hope that you enjoyed the long holiday weekend. For many of us on the East coast, the holiday’s days and nights were likely spent inside given the frigid temps. Unfortunately, the upcoming week is not going to provide any weather relief.

However, this should warm your heart, as the PBGC continued to be active implementing the ARPA legislation that is nearing its fourth anniversary (3/11/21). To date, the PBGC has approved the Special Financial Assistance (SFA) for 109 multiemployer plans. The grants have totaled $70.9 billion and 1,528,409 American workers/retirees have had the promised pension benefit protected, and in some cases, restored.

During the last week, the PBGC accepted one new application, as Greendale, WI based United Food and Commercial Workers Unions and Employers Pension Plan filed a revised application seeking $54.3 million for its 15,420 plan participants. In other news, two funds, Cement Masons Local No. 524 Pension Plan and Local 1922 Pension Plan each withdrew their initial application. The two funds were seeking just over $20 million for roughly 2k members. Finally, the Legacy Plan of the UNITE HERE Retirement Fund, a Priority Group 6 member, received approval of its revised application. They have been awarded $868.8 million in SFA and interest that will go to protecting the retirements for 91,744 participants. Congrats!

The PBGC’s eFiling portal is temporarily closed. According to the PBGC’s website, “the PBGC will accept as many applications as the agency estimates it can process within the statutory 120-day review period. When the number of applications under review reaches that level, the application e-Filing Portal will temporarily close until PBGC has capacity to receive more applications.” There are still an estimated 93 funds going through the process of filing applications SFA grants. 

ARPA Update as of December 27, 2024

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

We, at Ryan ALM, Inc., wish for you a happy, healthy, and prosperous New Year in 2025. May the markets continue to treat you well. However, nothing grows to the heavens, so it may be wise to alter one’s asset allocation and reduce risk as the year begins given inflated valuations, particularly for large cap US equities.

Regarding ARPA and the PBGC’s on-going effort implementing this critical legislation, there was a pause in activity during the last week. Good for them, as 2024 has been an incredibly busy and successful year. Regarding last week, the PBGC’s eFiling portal remains temporarily closed, so there were no new applications filed. There also weren’t any applications denied, withdrawn, or approved. Finally, there were no repayments made by funds that had received excess SFA.

To recap 2024, the PBGC approved 36 applications, awarding more than $16.2 billion in SFA grants that went to support the promised benefits for 458,446 plan participants. WOW! As the chart below highlights, only 15 of the 87 Priority Group members have yet to have the applications for SFA approved. Three of those applications are currently under review. Of the 115 funds seeking support that weren’t initially identified as a Priority Group member, 64 pension plans have participated to some extent in this program with 33 of those applications approved.

US Treasury note and bond yields (longer maturities) have risen sharply in the last few months. They are at levels not witnessed since early this year. As a result, they are providing plan sponsors with a wonderful opportunity to reduce risk without giving up potentially higher returns. We’d be happy to provide a free analysis on what could be achieved within your plan. Don’t hesitate to reach out to us.

Again, Happy New Year!

ARPA Update as of December 20, 2024

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

Happy Holidays from all of us at Ryan ALM, Inc. We wish you and yours a joyous holiday season and a spectacular 2025 filled with great health, abundant friendships, and calm markets.

Despite the onset of the holiday season, the PBGC was still at work implementing the ARPA legislation. Santa arrived early for one plan, as Roofers Local No. 75 Pension Fund received approval for its SFA grant. They will receive $6.8 million for the 275 plan participants. This was the initial filing for this non-priority group member. Congrats!

In other ARPA-related news, there were no new applications submitted as the PBGC’s efiling portal remains temporarily closed. There are currently 28 applications under review, including one Priority Group 5 member and two Priority Group 6 members. Fortunately, there were no applications denied or withdrawn during the previous week.

Lastly, there was one fund that repaid excess SFA assets due to census errors. Gastronomical Workers Union Local 610 and Metropolitan Hotel Association Pension Fund repaid $696k (or 2.09%) after receiving $33.3 million in SFA. This fund is one of only 3 to repay SFA in excess of 2% of the grant received. In total, $159.3 million has been repaid on grants of more than $41 billion or 0.38% of the allocations.

The Bloomberg chart below demonstrates the significant rise in U.S. rates during the last month. Recipients of SFA funds would be wise to secure the promised benefits with 100% of the grant money. Equity markets appear to be quite frothy. Time to reduce risk, while taking full advantage of the higher interest rates.

ARPA Update as of December 13, 2024

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

Welcome to the last full week before the Christmas season kicks off. Most investors will be sorry to see 2024 come and go. For the PBGC, 2024 has been a year of great accomplishments, with the approval of Special Financial Assistance (SFA) for 35 multiemployer plans covering 458,171 participants with SFA grants totaling $16.2 billion – wow!

The last week was a continuation of the PBGC’s activity with seven more funds submitting applications seeking $638.2 million for nearly 27k members. The applications included five new submissions and 2 revised applications. The applicants included the Dairy Industry-Union Pension Plan for Philadelphia and Vicinity, Bricklayers Pension Fund of West Virginia, United Wire, Metal and Machine Pension Plan, Distributors Association Warehousemen’s Pension Trust, Local 945 I.B. of T. Pension Plan, Alaska Teamster – Employer Pension Plan, and the Local 888 Pension Fund. Grant requests ranged from United Wire’s $228.5 million to the Bricklayers $1.96 million for their 170 participants.

In addition to the new submissions, there was one approval. Teamsters Local 11 Pension Plan will receive $29.3 million for the 2,012 members of its plan. This North Haledon, NJ fund submitted a revised application on August 29, 2024. In other ARPA news, there were no applications denied or withdrawn during the previous 7 days. In addition, there were no new plans added to the waitlist or forced to repay a portion of the SFA due to census errors.

US Treasury interest rates backed up fairly significantly last week as inflation data came in a little higher than recent trends giving bonds investors reason to challenge the narrative that the Fed would continue pushing down the Fed Funds rate. The higher rates are providing plan sponsors with greater cost savings on future benefits through cash flow matching strategies.

ARPA Update as of December 6, 2024

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

You have to be excited as a Mets fan given yesterday’s news that Juan Soto will be joining the organization on a massive contract. The $765 million is a staggering figure. Let’s see what happens to ticket prices and TV streaming services from a cost standpoint.

Since ARPA was passed in 2021 and signed into law in March of that year, there have been folks upset that the government is using “tax revenue” to rescue pensions for multiemployer plans. Well, in the latest update provided by the PBGC, we note that the Pressroom Unions’ Pension Plan, a non-priority group member, will receive $63.7 million to protect and preserve the promised pensions for 1,344 plan participants. That seems very reasonable since this grant will likely cover these benefit payments for roughly the same time frame that Soto will be a Met (15 years), at only $12.7 million more than just one year of Soto’s contract.

In other ARPA news, the e-filing portal is listed as “limited”, which according to the PBGC means that “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.” PA Local 47 Bricklayers and Allied Craftsmen Pension Plan was the only plan to file an application (revised) last week. They are seeking $8.3 million in SFA for 296 members in the fund.

In other news, three funds, including Toledo Roofers Local No. 134 Pension Plan, Freight Drivers and Helpers Local Union No. 557 Pension Plan, and PACE Industry Union-Management Pension Plan, were asked to repay a total of $7 million in excess SFA due to census issues. The rebate represented 0.45% of the $1.6 billion received in SFA grants. Happy to report that there were no applications denied or withdrawn during the prior 7-day period.

As the chart above highlights, there are still 57 plans that have yet to file an application seeking SFA support. Estimates range from another $10 – $20 billion being allocated to the remaining entities.

Good Job, PBGC!

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

Did you know that there exists an oversight body for the Pension Benefit Guaranty Corporation (PBGC)? The 1988 amendments to the Inspector General Act of 1978 created the PBGC Office of the Inspector General (OIG) of the PBGC. They are responsible for providing independent and objective audits, inspections, evaluations, and investigations to help Congress, the PBGC Board of Directors, and the PBGC itself to protect pension benefits for both multiemployer and private plans.

The latest report, covering the period April 1-September 30, 2024, has been sent to Congress. The PBGC has received mostly positive results. As a reminder, the PBGC ensures the pension benefits of more than 31 million American workers and retirees who participate in more than 24,500 private-sector pension plans through its single-employer and multiemployer insurance programs. Quite the effort!

Furthermore, as regular readers of this blog know, the PBGC has been engaged since 2021 in implementing the Special Financial Assistance (SFA) program, that was housed in the ARPA legislation. As of September 30, 2024, the report highlights the following stats regarding the PBGC’s effort:

  • received 165 SFA applications requesting $76 billion;
  • approved 127 of the SFA applications; (includes supplemental applications of which there were 35)
  • provided $68 billion in SFA; and
  • was reviewing 22 SFA applications, requesting a total of $2.5 billion.

One area of concern, which seems to have been corrected, was the census data possibly being wrong in the various applications leading to overpayment of SFA grants. According to the OIG report, there could be incorrect census data on applications leading to as much as $250 million in overpayments. To date, the PBGC has recouped $144 million from 19 plans. This sum is a small percentage (<0.5%) of what has been paid out to date.

The OIG says it “determined that the PBGC’s SFA procedures were generally sufficient to ensure that increases in projected benefit payments were (1) consistently identified, (2) evaluated against appropriate criteria, and (3) documented. In addition, the OIG reports that the PBGC responded to its findings and recommendations regarding the SFA program, which is says has significantly improved the PBGC’s SFA procedures.”

According to our analysis, there are potentially 202 applicants seeking SFA grants. With 102 funds having received approval to date, there remains much work is left to be done. There is no time to sit on one’s laurels!

ARPA Update as of November 29, 2024

By: Russ Kamp, Managing Director, Ryan ALM, Inc.

We hope that you had a very enjoyable holiday weekend. Welcome to December. That doesn’t seem possible.

Despite the holiday shortened week, the PBGC was quite busy, announcing that four multiemployer plans had submitted applications seeking Special Financial Assistance (SFA). Those funds included Laborers’ Local No. 91 Pension Plan, Southwestern Pennsylvania and Western Maryland Area Teamsters and Employers Pension Fund, Oregon Processors Seasonal Employees Pension Plan, and The Legacy Plan of the UNITE HERE Retirement Fund. Local 91’s application was its initial attempt at getting the SFA, while the other three submitted revised applications. In total, these four are seeking a total of just over $1 billion for the 102,356 plan participants. A significant majority of the assets being requested and plan members are in the UNITE HERE fund.

With regard to the Teamsters’ plan, they withdrew and then resubmitted the application on November 27th. That plan is hoping to receive $120.7 million in SFA for the 2,759 members of its fund. In other news, two funds received approval for their applications, including Lumber Industry Pension Plan and Local 1034 Pension Plan. Both plans had submitted revised applications. In total, they will get $159.6 million in SFA and interest for 7,155 plan participants. I suspect that the announcement of a successful PBGC approval made for a wonderful Thanksgiving celebration.

Finally, there were no applications denied, no funds repaid excess SFA, and no plans sought to be added to the waitlist at this time, which continues to list 53 non-priority plans that have not yet been allowed to submit an initial application.

The two plans that received approval for the SFA last week brings to 102 the number of plans that have been awarded SFA grants ($69.7 billion) since the program launched in July 2021. There are still 100 plans that may be eligible to receive this special financing.