ARPA Update as of January 24, 2025

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

We are pleased to bring you our weekly update of the PBGC's implementation of the ARPA legislation. What has been a busy start to 2025 came to a screeching halt during the last week. The freeze gripping much of the United States clearly impacted the activity out of DC, as there is nothing to report.

The PBGC's e-Filing portal remains closed to new applications being submitted. As mentioned previously, the PBGC will accept applications "in a manner that facilitates an expeditious and thorough review process and provides every eligible plan an opportunity to file its SFA application with the PBGC." Importantly, the PBGC will only accept as many applications as the agency estimates it can process within the statutory 120-day review period. Currently, the PBGC has 22 applications under review. Two of those will have the 120-day review period eclipsed in February and another 10 funds in March.

The activity surrounding the repayment of "excess" SFA has slowed down, too. To date, 33 funds have repaid a portion of the grant that they received. In total, $164.5 million has been repaid representing 0.39% of the total assets received. I'm not sure how many more funds might be required to rebate some of the grant money.