Tag Archives: sfa

09.23.24
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ARPA Update as of September 20, 2024

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

Welcome to Autumn! It has always been my favorite season since I was a young boy. I would often listen to NY Giants football on the radio as I spent Sunday afternoons outside in the crisp fall air while raking leaves or lying in a freshly created pile. Unfortunately, the Giants weren’t very good in the ’60s and ’70s. I guess what goes around comes around.

I knew that this day would come since I publish an update on the weekly activity associated with the ARPA pension legislation. There was no obvious activity by the PBGC last week. In their latest update, the PBGC is not reporting any new applications received (the efiling portal remains temporarily closed), no applications were approved, denied, or withdrawn, no plans repaid a portion of the SFA due to census errors, and finally, no multiemployer plans sought inclusion on the waiting list. Oh, well. Even the PBGC needs a rest once in a while.

Perhaps the PBGC was focused on the Fed’s interest rate policy decision like the rest of us. So, I’ll take advantage of the clean slate and use my weekly update to summarize where we are at this stage of the PBGC’s implementation of the ARPA pension legislation which began in July 2021. To date, 92 multiemployer plans have received Special Financial Assistance totaling $68.0 billion in grants (inclusive of supplemental awards, interest, and FA Loan Repayments). Of the 92 approved applications, 38 (41.3%) were the initial application attempt. There has been only one plan that had its application denied for ineligibility. Bakery Drivers Local 550 and Industry Pension Fund had its initial application denied in January 2023. A subsequent application was withdrawn in July 2023.

There are currently 23 applications before the PBGC. Five of those 23 will have the 120-day review period elapse in October. There is still one Priority Group 1 member that hasn’t filed an application out of the 30 funds identified as Priority Group 1 eligible. In addition, there are currently 18 applications that were withdrawn that have yet to refile. As I’ve previously reported, 14 funds have repaid a portion of the SFA received because of overpayment due to incorrect census data. There may be more to come.

The Waitlist had 115 multiemployer plans at one time. Twenty-one of those plans have received SFA grants, another 21 are presently under review, while five applications were withdrawn and not refiled. That leaves 69 plans that have yet to get PBGC approval to submit the initial application. While last week may have been “quiet” for the PBGC from an external point of view, a tremendous effort has been put forth to get to this point with potentially lots more to go.

09.16.24
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ARPA Update as of September 13, 2024

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

Will it be 25 or 50? That is the big question on nearly every investor’s mind this week. Will the Federal Open Market Committee cut rates by 0.25% or 0.5% on Wednesday. Any cut would mark the first such move by the Federal Reserve since 2020. Despite the uncertainty as to the Fed’s potential action, the PBGC was undaunted as they had another busy week implementing the ARPA pension legislation.

There is plenty to highlight from last week’s activity, as three funds received approval of their applications seeking Special Financial Assistance (SFA), one fund repaid a portion of its SFA grant, while another withdrew its initial application. There were no applications filed this past week as the PBGC’s filing portal is temporarily closed. Multiemployer plans seeking SFA may still “request to be placed on the waiting list in accordance with the instructions in PBGC guidance.”

The three funds receiving SFA were Teamsters Local Union No. 469 Pension Plan, Pension Plan Private Sanitation Union, Local 813 I.B. of T., and Local Union No. 226 International Brotherhood of Electrical Workers Open End Pension Trust Fund. These funds were each non-Priority Group members and the applications were the initial filings for each. In total, these pension plans will receive $238.3 million in SFA and interest for just over 6k members.

Local 1783 I.B.E.W. Pension Plan, an Armonk, NY non-Priority Group member, withdrew its initial application. They were seeking $42.2 million in SFA for the 850 plan participants. The Alaska Iron Workers Pension Plan received approval for its application in January 2023. They have just agreed to return $384,111.74 from the $53.5 million received in February 2023, as a result of a census error. This is the fourteenth plan to return a portion of the SFA due to overpayment.

As one can see, the PBGC has approved 92 of a potential 202 applications (45.5%) at this time for a total of $68 billion in SFA, including interest FA loan repayments. As a reminder, plans receiving SFA proceeds must keep those separated from the plan’s current fund (legacy assets). Despite the recent decline in US interest rates, defeasing benefits and expenses as far into the future as the SFA grant will cover is still the proper course of action. I produced a post last Friday on the correct approach to cash flow matching for those considering such a strategy.

07.29.24
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ARPA Update as of July 26, 2024

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

The “dog days” of summer don’t seem to be impacting the activity level at the PBGC, as we had a plethora of activity last week. As mentioned on the PBGC website, the e-filing website is open, but limited. “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.” That’s interesting, as there are still 16 pension plans in Priority Groups 1-6 that have potential applications that are not currently being reviewed. Are they excluded, too?

During the week, three funds that had been on the waitlist submitted applications, including, Local 810 Affiliated Pension Plan, the Upstate New York Engineers Pension Fund, and the Alaska Plumbing and Pipefitting Industry Pension Plan. They are seeking a total of $282.1 million for the 9,620 plan participants. This is each plan’s initial submission. As always, the PBGC has 120 from the filing date to conclude the review.

In other news, two plans received approval of their applications, including the Pension Plan of the Moving Picture Machine Operators Union Local 306, a Priority Group 5 member, and the New England Teamsters Pension Plan, that was a Priority Group 6 member. The Moving Picture machinists will receive $20.7 million to support its 542 members, while the NE Teamsters get a whopping $5.7 billion for just over 72k participants. With these latest approvals, the PBGC has now granted through ARPA $67.7 billion in Special Financial Assistance (SFA) that will support the financial futures of 1.34 million American retirees.

On July 23, the Production Workers Pension Plan was added to the waitlist, becoming the 115th member on that list, with 47 having seen some activity (approved, under review, or withdrawn) regarding their applications. In other news, there were no applications denied or withdrawn. Furthermore, none of the previous SFA recipients were asked to repay a portion of the grant due to overpayment. Have a great week, and don’t hesitate to reach out to us if we can provide any assistance to you as you think through your investment strategy as it relates to the SFA grant.

07.22.24
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ARPA Update as of July 19, 2024

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

After a very hectic June, in which the PBGC approved nine applications for SFA, July has seen a replenishing of submitted applications seeking SFA grant money with 9 being filed in the first three weeks of the month. In the last week alone, we had Local 734 Pension Plan, Teamsters Local 210 Affiliated Pension Plan, Pension Plan of the Marine Carpenters Pension Fund, and the Pension Plan of the Automotive Machinists Pension Trust submit applications seeking nearly $411.5 million for the combined 20,111 plan participants.

There is really nothing else of note to those of us on the outside of this process. According to the PBGC’s website, there were no applications for SFA approved or denied in the previous week. No funds were asked to return excess payments, no multiemployer plans were added to the waitlist, and no applications were withdrawn.

There are still 16 funds with Priority Group standing (1-6) that are not currently under review, including 1 Priority Group 1 member that hasn’t filed an initial application, while all the others have withdrawn at least initial applications. In addition, there are still 71 waiting list applicants that have not yet submitted an initial application. Despite the successful implementation of ARPA to date, the PBGC still has a ton of work to do.

07.15.24
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ARPA Update as of July 12, 2024

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

Not only has the weather heated up, but so has the activity at the PBGC as it relates to the implementation of the ARPA pension legislation. During the past week two non-priority group plans submitted applications. In the case of the Carpenters Pension Trust Fund – Detroit & Vicinity, it was a revised application seeking nearly $600 million in Special Financial Assistance (SFA), while the Laborers’ Local No. 265 Pension Plan put forward its initial filing seeking $55.6 million. In total, more than 24,000 plan participants would enjoy a more secure retirement with the approval of these applications.

In other ARPA news, the American Federation of Musicians and Employers’ Pension Plan finally received approval. This fund had multiple filings throughout the process, which began on March 10, 2023 with the initial filing followed by two other applications. The wait was certainly worth it, as they will receive >$1.5 billion to reinforce the pensions of nearly 50,000 eligible participants.

There were no applications denied during the past week, but one fund, the United Food and Commercial Workers Union and Participating Food Industry Employers Tri-State Pension Plan, withdrew its application that had been seeking $638.3 million in SFA for 29+k members. There were no plans that were forced to repay excess SFA assets and no new plans added to the waitlist.

We’ve all heard the phrase with uncertainty comes opportunity, and that may very well be true, but the uncertainty comes with a certain level of risk, too. Given all of the uncertainty in the economic and political spheres at this time, is the opportunity greater than the risk? We would encourage plan sponsors of all plan types to look to reduce some of the risk in their funds, especially given the elevated multiples on which the equity markets are currently trading. The higher US interest rates are providing a unique opportunity not available to us in the past two decades. Secure some of the promises (benefits) by defeasing your liabilities through a cash flow matching strategy. We are happy to discuss this suggestion in far greater detail or you can go to RyanALM.com to read myriad research articles and blog posts on the subject.

07.08.24
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ARPA Update as of July 5, 2024

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

We hope that you had an enjoyable long holiday weekend. We once again provide you with an update on ARPA and the PBGC’s implementation of this key pension legislation. Following a busy June, in which nine multiemployer plans received Special Financial Assistance (SFA) approval for $6.4 billion for roughly 233k participants, the PBGC’s application portal has been reopened and three applications were filed during the past week. PA Local 47 Bricklayers and Allied Craftsmen Pension Plan, Local 111 Pension Plan, and Bricklayers Pension Fund of West Virginia have each filed its initial application seeking SFA. In total, these three smallish plans are requesting $25.7 million for 2,066 participants.

In other developments, there was little obvious activity during the holiday shortened week, as there were no plans receiving approval for SFA, no applications that were denied or withdrawn, and no plans agreed to repay excess SFA grant money. Finally, there were no additional plans added to the waitlist at this time. Currently, 37 non-priority plans, from a list of 114, have seen some action on their application – approved, submitted, or withdrawn.

There remains great uncertainty within the US economy. Is the US labor market weakening? Is inflation truly under control? With the recent fall in Q2’24 GDP growth estimates from 3.1% to 1.5% by the Atlanta Fed (GDPNow model), will the Fed finally have the information that they’ve been seeking to reduce US interest rates? Will these trends begin to weigh on US corporate profits? If so, elevated valuations for US stocks could begin to pressure US stock prices, which seem to have been immune to bad news in the last couple of years. It may be time to rebalance or reduce any exposure to stocks within the SFA bucket and lock in these higher US rates.

07.01.24
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ARPA Update as of June 28, 2024 – A Time to Celebrate!

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

As we complete the first half of 2024 and get ready for the Fourth of July celebrations with family and friends, we believe that it is fitting to celebrate the success to date of the ARPA pension legislation and the PBGC’s implementation that has positively impacted so many Americans. Here are the highlights:

ARPA’s Special Financial Assistance has been awarded to 84 plans to date.

Those 84 pension plans are responsible for >1.2 million American Workers, who now have their promised retirement benefit secured.

The 84 multiemployer plans have received roughly $60.4 billion in SFA to date.

Furthermore, there are roughly another 115-120 pension plans that might be eligible to receive the SFA before the program comes to its end. Just think of all those hard-working Americans who might have lost a significant % of their benefit, if not the whole promise, through no fault of their own. Congratulations, to all involved in creating and implementing this incredible legislation.

Despite all of the success of this program to date, there is much still to be done. During the previous week, the PBGC allowed two pension plans to file applications for SFA grants, including I.B.E.W. Pacific Coast Pension Fund and Midwestern Teamsters Pension Plan, with each submitting its initial application. In total, these two funds are looking for about $91.7 million in SFA proceeds for just under 4,000 plan participants. The PBGC will now have 120 days to act on these requests.

In other ARPA news, the Kansas Construction Trades Open End Pension Trust Fund received approval of its revised application. They will receive $43.1 million for the 8,145 participants in their program. There were no applications denied or withdrawn, and no funds were forced to repay excess SFA grants. Lastly, no new funds have been added to the waitlist.

We wish for you a wonderful Fourth of July holiday. Please remember those that sacrificed so much so that we can celebrate the independence and freedom that we enjoy in this country. Stay safe.

06.25.24
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ARPA Update as of June 21, 2024

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

I suspect (can only hope) that you woke up yesterday morning just itching to see what news I was going to share as it related to ARPA and the PBGC’s implementation of that critical legislation. Sorry to have disappointed you. Like most everyone else, my day just got away from me.

However, I do have some exciting news to share which might just make up for the disappointment of having to wait one day to get the weekly update. As we’ve been writing, the PBGC was running up against many application review and determination deadlines this month. As a result, they have announced that five funds had their applications approved for Special Financial Assistance (SFA). Terrific!

The five funds are the Retail, Wholesale and Department Store International Union and Industry Pension Plan, the Bakery and Confectionery Union and Industry International Pension Fund, United Food and Commercial Workers Unions and Employers Midwest Pension Plan, GCIU-Employer Retirement Benefit Plan, and the Pacific Coast Shipyards Pension Plan. These funds represent three Priority Group 6 members and two that came through the non-priority waitlist. In total, they will receive nearly $5.8 billion in SFA for just over 200k in plan participants. The Kansas Construction Trades Open End Pension Trust Fund is the last application that needs action in June. There are four that have July deadlines.

There were no new applications submitted to the PBGC, as the portal remains temporarily closed, no applications denied or withdrawn, and none of the plans that have received SFA were forced to return a portion of the proceeds as a result of overpayment identified through a death audit of the plan’s population.

Fortunately, the US interest rate environment and current economic conditions remain favorable for those potential SFA recipients to SECURE promised benefits far into the future without subjecting the grant proceeds to unnecessary risk associated with a non-cash flow matching assignment. Remember that the sequencing of returns is a critical variable when contemplating an asset allocation framework. If your SFA portfolio suffers significant losses in the early years, you negatively impact the coverage period. We’ll be happy to model your plan’s liabilities for free. Don’t hesitate to reach out to us if we can be a resource for you.

06.17.24
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ARPA Update as of June 14, 2024

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

We hope that you enjoyed a wonderful Father’s Day. I’m blessed to still have my Dad with us (95 years young). In addition, I have two sons and two sons-in-law who are wonderful fathers. It was a terrific day!

Regarding ARPA and the PBGC’s implementation of that critical pension legislation, there was some activity during the previous week. However, the filing portal remains temporarily closed for those plans still seeking relief through the SFA grants. That said, there are still 17 applications that are currently being reviewed with 6 of those nearing the 120 deadline for action. Those six plans are seeking nearly $5.5 billion in SFA. As a result, the rest of June is going to be busy for the PBGC.

The Pension Plan for the Arizona Bricklayers’ Pension Trust Fund received approval for its application. They will receive $10.7 million to protect the pensions for the 666 members of the plan. This non-priority plan received approval on their initial application. In other news, there were no applications either denied or withdrawn. However, the Graphic Communications Conference of the International Brotherhood of Teamsters National Pension Fund joined Central States as the only other plan to repay excess SFA as a result of a death audit. In this case, they are repaying just over $8 million.

Have a great week. Don’t hesitate to reach out to us if you like to learn more about cash flow matching and how it can be used to extend and protect the SFA grant assets so vital to ensuring that the pension promises are met for your participants.

06.10.24
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ARPA Update as of June 7, 2024

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

We are pleased to provide you with another ARPA update. The PBGC approved the applications for two New Jersey funds seeking Special Financial Assistance (SFA). CWA/ITU Negotiated Pension Plan and the Pension Plan of Local 102, both non-priority funds, will receive $545.6 million and $12.5 million, respectively, in order to ensure that their 24,796 participants will receive the promised benefits.

Unfortunately, there isn’t much else to report, as there were no new applications submitted, and the queue remains at 18. There were no applications rejected or withdrawn and no pension systems were added to the waitlist, with 32 of 114 having had some activity (submissions, withdrawals, and approvals) to date. Central States remains the only plan to pay back excess SFA proceeds.

The 18 plans that are currently under review carry some heft, as they are collectively seeking >$13 billion in SFA for nearly 370K participants. Seven of those plans have application “deadlines” in June. As a reminder, the PBGC has 120 days to act on an application once it has been submitted. Fortunately, US interest rates remain elevated providing plan sponsors with the opportunity to use cash flow matching to secure the SFA assets and significantly reduce the risk associated with a traditional asset allocation. Sponsors would be wise to use the legacy assets to assume a more traditional asset allocation since those assets now have the benefit of an extended investing horizon.

We hope that you have a wonderful week.